The Central Bank of Nigeria (the “Bank” or the “CBN”), pursuant to its powers under the Central Bank of Nigeria Act, 2007 and the Banks and Other Financial Institutions Act, 2020 (BOFIA), has issued the Guidelines for the Operations of Agent Banking in Nigeria, 2025 (the “Guidelines”) via circular dated 6 October 2025. The Guidelines, which take effect on 1 April 2026, consolidate and supersede all previous CBN regulations governing agent banking and agent banking relationships, including the 2013 Guidelines and the 2015 Super-Agent Licensing Framework.
They provide a comprehensive framework for the appointment, management, and supervision of agent banking stakeholders in Nigeria, including Principals, Super-Agents, Agents, and Payment Terminal Service Aggregators (PTSAs) with a view to strengthening operational safety, consumer protection, and financial inclusion across the country.
Six Key Things to Note from the Guidelines for Agent Banking Operations in Nigeria:
- Consolidation and Scope
The Guidelines consolidate all extant policy instruments on agent banking into a single regulatory framework that now applies to all CBN-licensed financial institutions authorised to engage in agent banking activities including commercial banks, microfinance banks, payment service banks, mobile money operators, and other deposit-taking institutions. They are intended to set minimum operational standards, promote responsible market conduct, and improve service quality in the delivery of agent-banking services to the under-banked and unbanked population.
- Agent Exclusivity and Relationship Structure.
A pivotal innovation in the new Guidelines is the exclusivity requirement. This means an agent can represent only one licensed financial institution at a time, while a Super-Agent may contract with multiple Principals. The CBN provides a transition window until 1 April 2026 for existing multi-principal agents to align with this single-principal regime. Each Agent relationship must be governed by a formal Agent Banking Agreement approved by the Principal’s Board, covering key terms such as duration, authorised services, fees, AML/CFT obligations, confidentiality, liability, dispute resolution, and termination.
- Appointment, Qualification and Due Diligence
The Guidelines introduce stricter pre-appointment due diligence and eligibility standards. A prospective Agent, whether individual or non-individual, must demonstrate capability to perform permitted activities, provide BVN/NIN (and TIN for non-individuals), have no record of non-performing loans or criminal convictions, undergo risk assessment, KYC/KYA verification, and training on AML/CFT, customer service, and transaction processes. Principals must retain complete documentation and evidence of due diligence for inspection by the CBN.
- Permissible and Non-Permissible Activities
Permissible agent-banking services include:
- Cash-in and cash-out within prescribed limits
- Bill payments and funds transfers (naira-denominated)
- Account-balance inquiries, mini-statements, chequebook requests;
- Submission of account-opening forms and collection of bank correspondence
- Other services expressly approved by the CBN.
Non-permissible activities include:
- Undertaking lending, foreign-exchange, or investment services
- Delegating agent services to another party
- Operating automated or non-human agent outlets; and
- Engaging in any unapproved or misleading marketing practices.
- Operational and Risk-Management Requirements
The Guidelines establish extensive operational obligations for Principals, notably:
- Dedicated Agent Accounts: All transactions must pass through a CBN-monitored, dedicated account or wallet maintained with the Principal.
- Real-Time Transactions & ICT Standards: Principals must deploy secure, interoperable technology enabling instant value, automatic reversals, electronic receipts, and two-factor authentication.
- Geo-Fencing: POS devices and terminals must be locked to operate only within the registered agent location.
- Data and Network Security: Principals must implement encryption, logical security, incident logs, and data-retention measures for at least five years.
- Risk and AML/CFT Compliance: Comprehensive risk frameworks and adherence to the Money Laundering (Prohibition) Act 2022 and Financing of Terrorism Act 2022 are mandatory.
- Consumer Protection, Branding and Transparency
The Guidelines dedicate to consumer protection and branding obligations. Principals must:
- Enable customers to identify their authorised Agents easily;
- Provide complaint-resolution channels and resolve issues within seven working days;
- Ensure all Agents issue receipts for every transaction; and
- Display clear signage showing:
- the Principal’s name and logo,
- agent-banking services offered,
- applicable fees and contact information.
Agents are expressly prohibited from misrepresenting themselves as banks or using restricted terms such as “financial institution” or “bank”.
Conclusion
The CBN’s 2025 Guidelines introduce clear transaction ceilings, robust reporting standards, and strengthened enforcement measures designed to improve operational discipline and mitigate risk. Principals are required to render periodic returns on agent activities, fraud incidents, and customer complaints, while maintaining auditable records and technology infrastructure capable of real-time transaction monitoring. The CBN retains broad supervisory powers, including the authority to inspect, suspend, or blacklist defaulting agents and impose monetary sanctions ranging from ₦2 million to ₦20 million for non-compliance. Severe violations such as unlicensed operations, false reporting, or AML/CFT breaches may attract licence suspension or revocation.
Overall, the Guidelines for the Operations of Agent Banking in Nigeria (2025) represent a transformative step in tightening governance, consumer protection, and risk management within Nigeria’s agent-banking ecosystem. By enforcing exclusivity, dedicated accounts, geo-fencing, data security, and stricter compliance oversight, the CBN aims to strengthen public confidence in agent-led financial services. Stakeholders including Principals, Super-Agents, and Agents are advised to align existing structures, contracts, and technology systems with the new framework well ahead of the 1 April 2026 effective date to ensure compliance, avoid sanctions, and support the sustainable expansion of Nigeria’s digital financial landscape.
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