Introduction
The Central Bank of Nigeria (“CBN”) has, in furtherance of its mandate to promote a sound, stable and inclusive financial system under the Central Bank of Nigeria Act 2007 (“CBN Act”) and the Banks and Other Financial Institutions Act 2020 (“BOFIA”), issued the Guidelines for the Operations of Agent Banking in Nigeria (the “Guidelines”) on 6 October 2025.
The Guidelines, issued through the Payments System Management Department, repeal and consolidate the 2013 Guidelines for the Regulation of Agent Banking and Agent Banking Relationships and the 2015 Regulatory Framework for the Licensing of Super Agents, thereby providing a unified regulatory framework for agent banking operations in Nigeria.
Agent banking has evolved into a critical channel for achieving Nigeria’s financial inclusion objectives by expanding access to basic financial services, especially in underbanked and remote communities. The CBN’s revised framework, therefore, seeks to address new operational, technological, and consumer protection risks that have emerged with the rapid expansion of agent networks across the country.
Regulatory Objectives and Scope
The Guidelines apply to all CBN-licensed financial institutions authorized to conduct agent banking[1], including commercial banks, non-interest banks, microfinance banks, payment service banks, and mobile money operators, as well as Super Agents licensed to recruit and manage agent networks. They also supersede all previous CBN regulations on Agent Banking.
The objectives of the Guidelines are threefold; to set minimum operational standards for agent banking in Nigeria; to enhance its effectiveness as a vehicle for financial inclusion; and to promote responsible market conduct, improved service delivery, and strong customer confidence.[2]
Key Provisions
Governance Structure and Stakeholders
Under the new framework, the agent banking ecosystem is anchored on three key stakeholders: Principals, Super Agents, and Agents with Payment Terminal Service Aggregators (PTSAs) playing a supporting technological role. In addition, the CBN also plays a stakeholder role with supervisory and regulatory powers.
A Principal is a licensed deposit-taking financial institution that contracts third parties to provide specified financial services on its behalf.[3] A Super-Agent, on the other hand, is an incorporated entity licensed by the CBN solely to recruit, aggregate and manage a network of agents for one or more Principals.[4] Agents may be individuals or registered business entities authorized to perform permissible services under a duly executed agency agreement.[5]
Each agent must operate exclusively for one Principal at any given time, though a Super Agent may represent multiple Principals. All agent banking relationships must receive prior board approval and be governed by a written contract addressing, among other things, the duration of the relationship, authorized services, remuneration, liability, AML/CFT compliance and dispute resolution.
Permissible Activities and Compliance Obligations
The Guidelines delineate the services that may be offered through agent banking channels. Permissible activities include cash-in and cash-out transactions, domestic fund transfers, bill payments, and balance enquiries. Agents may also facilitate account opening processes by providing and forwarding forms to customers, but may not open accounts independently.[6]
Conversely, activities such as foreign exchange dealings, loan underwriting, investment services, or the delegation of agency functions to third parties are strictly prohibited.[7] The principal institution bears ultimate responsibility for all acts and omissions of its agents, including any unauthorized transactions carried out in the course of their agency.
Agent Appointment, Due Diligence and Onboarding
The Guidelines impose stringent eligibility and due diligence requirements on the appointment of agents.[8] A prospective agent must demonstrate capacity to provide relevant services and maintain a clean credit and criminal record. Individuals with non-performing loans, bankruptcy proceedings, or convictions for fraud or dishonesty are disqualified.
Before onboarding, Principals are required to conduct enhanced due diligence, including verification of business addresses, assessment of sources of funds, and review of prior agency relationships. Once approved, agents undergo a structured onboarding process involving biometric registration, linkage of Bank Verification Numbers (BVN) or Tax Identification Numbers (TIN) to dedicated agent accounts, and completion of “Know Your Agent” registration on the institution’s database.[9]
Training is an integral part of this process. Principals and Super Agents must ensure that agents receive comprehensive instruction on KYC obligations, transaction handling, fraud detection, customer protection, and liquidity management. Such training must be repeated at least twice yearly or as may be directed by the CBN.[10]
Operational and Technological Requirements
The CBN has introduced heightened operational controls to strengthen transparency, security, and accountability. All transactions must be routed through dedicated agent accounts or wallets maintained with the Principal. Any agent operation conducted outside such accounts constitutes a regulatory breach.[11]
Furthermore, transactions are required to be processed in real time, supported by an interoperable payment infrastructure with encryption, two-factor authentication, and automatic audit trails. Point-of-sale terminals must be geo-fenced to the agent’s registered business location, and each device linked to the agent’s BVN or TIN for traceability. Principals must also publish and periodically update the list of their authorized agents and operating locations on their official websites.
These requirements are complemented by comprehensive data protection obligations, mandating the physical and logical security of all systems, encryption of customer data, and maintenance of transaction records for a minimum of five years.
Transaction Limits and Customer Protection Measures
To mitigate fraud and liquidity risks, the Guidelines establish transaction ceilings. Customer deposits, withdrawals, and bill payments are each limited to N100,000 per day, while an agent’s total daily cash-out operations must not exceed N1.2 million.[12]. Irrespective of the aforementioned limits, the CBN retains the discretion to vary the limits.
Equally significant are the enhanced customer protection provisions. Principals are required to ensure that agents issue receipts or electronic confirmations for every transaction,[13] display their Principal’s identity and approved branding,[14] and make public the applicable fees and charges. Complaints from customers must be addressed and resolved within seven (7) working days, with Principals maintaining detailed logs of all complaints and resolutions.[15] These measures reinforce the CBN’s commitment to customer confidence and market integrity.
Reporting, Supervision and Sanction
The Guidelines underscore the CBN’s expanded supervisory powers. Principals are required to submit monthly regulatory returns to the CBN no later than the 10th day of the following month, detailing transaction volumes, incidents of fraud, agent classifications, and training records.[16] The CBN reserves the right to conduct spot inspections, request additional information, and exercise full access to systems, records, and staff of Principals and Super Agents.
To ensure compliance, the CBN has introduced a comprehensive sanctions regime. Administrative penalties range from N2 million for late rendition of returns to N10 million for operating without a valid Super-Agent license, while persistent or material breaches may attract blacklisting, suspension of operations, or even revocation of licenses.
Implications for Financial Institutions
The revised framework places a renewed emphasis on governance, risk management, and consumer protection. Financial institutions must now review their internal controls, contractual documentation, and operational processes to ensure compliance. Boards of Directors are expected to exercise more active oversight over agent operations, while compliance and risk management functions must be recalibrated to reflect the heightened due diligence and reporting requirements.
In addition, institutions may need to upgrade their technology infrastructure to support real-time monitoring and regulatory data submissions through the CBN’s Automated Regulatory Data Solutions (CARDS) platform. The focus on exclusivity of agents also requires Principals to strengthen contractual protections and ensure continuous engagement with both Super Agents and field agents.
Conclusion
The Guidelines represent a significant evolution in the regulatory landscape for financial service delivery. By consolidating prior instruments and tightening operational and consumer protection requirements, the CBN has reaffirmed its commitment to a secure, transparent, and inclusive financial system.
For financial institutions, the challenge lies not only in technical compliance but also in embedding sound governance and ethical practices within their agent networks. As regulatory scrutiny intensifies, proactive engagement with the CBN and timely review of agent-banking frameworks will be critical in ensuring sustained compliance and preserving institutional integrity.
For further clarification or assistance regarding compliance with new regulations or any related legal matters, you can contact us via email – lawyers@credence-law.com
[1] Section 1.2 of the Guidelines
[2] Ibid., Section 1.1
[3] Ibid., Section 2.2
[4] Ibid., Section 2.3
[5] Ibid., Section 2.4
[6] Ibid., Section 3.
[7] Ibid., Section 3.2
[8] Ibid., Section 7
[9] Ibid., Section 8.4
[10] Ibid., Section 8.4.2
[11] Ibid., Section 10.1
[12] Ibid., Section 11.0
[13] Ibid., Section 10.9
[14] Ibid., Section 10.10
[15] Ibid., Section 10.9A(v)
[16] Ibid., section 12.0