Nigeria
- Currency
- NGN
- Services available
- 112
- Obligations tracked
- 19
Regulatory landscape
Nigeria is the deepest fintech market in Africa and the most demanding to operate in. Payment activity is licensed by the Central Bank of Nigeria across distinct categories — Payment Solution Service Provider, Payment Terminal Service Provider, Switching and Processing, Mobile Money Operator, Payment Service Bank and International Money Transfer Operator — each with its own capital requirement and permissible activities.;
Financial crime obligations sit under the Money Laundering (Prevention and Prohibition) Act 2022 and the CBN AML/CFT Regulations, with reporting to the Nigerian Financial Intelligence Unit through goAML. Professional services firms, including this one, are designated non-financial businesses and professions and register with SCUML.;
Data protection is governed by the Nigeria Data Protection Act 2023. Annual compliance audit returns are filed through a Data Protection Compliance Organisation licensed by the Nigeria Data Protection Commission.;
Banks, payment service providers and other financial institutions are also subject to the CBN Risk-Based Cybersecurity Framework, which carries its own annual return.
Regulators
- CBN
- NFIU
- SCUML
- SEC Nigeria
- NDPC
- NAICOM
- PENCOM
- FCCPC
- NDIC
- FRC
- CAC
Recurring obligations
What a licensed entity in Nigeria has to do, and how often. Which of these apply to you depends on your entity type and the licences you hold. In the portal, the applicable ones attach to your organisation automatically and appear on a calendar with reminders.
CAC
| Obligation | Frequency | When | Service |
|---|---|---|---|
| Annual return to the Corporate Affairs Commission File the company's annual return with the Corporate Affairs Commission. | Annual | Not later than 30 June each year, other than the year of incorporation | — |
| Persons with Significant Control register update Maintain and update the register of persons with significant control, and notify the Commission of changes. | On event | Within the period prescribed after a change in significant control | View |
CBN
| Obligation | Frequency | When | Service |
|---|---|---|---|
| AML/CFT staff and board training Deliver role-appropriate AML/CFT training to staff and to the board, and retain evidence of completion. | Annual | At least annually | View |
| Board risk and audit committee meetings Convene board risk and audit committee meetings at the minimum frequency required by the governance code. | Quarterly | At least quarterly | View |
| Customer float reconciliation and safeguarding attestation Reconcile customer funds held in pool or settlement accounts and evidence that they are safeguarded and not commingled. | Monthly | Reconciled at least monthly; attested as required by the regulator | View |
| Enterprise-wide ML/TF/PF risk assessment Document an enterprise-wide assessment of money laundering, terrorist financing and proliferation financing risk, and refresh it as the business changes. | Annual | At least annually and on any material change to products, customers or markets | View |
| Independent AML/CFT audit Commission an independent test of the AML/CFT programme, conducted by a party not responsible for designing or operating it. | Annual | At least annually, or as directed by the regulator | View |
| Periodic regulatory returns Submit periodic prudential and operational returns in the form and frequency specified for the licence category. | Monthly | As specified per return type in the CBN returns schedule | View |
| Risk-Based Cybersecurity Framework self-assessment return Complete the cybersecurity self-assessment required by the CBN Risk-Based Cybersecurity Framework and submit the return. | Annual | Annually, in the form and time specified by the CBN | View |
| Statutory external audit and audited financial statements Have the annual financial statements audited by a registered audit firm and submit them to the regulator. | Annual | Within the period specified by the CBN following the financial year end | View |
FCCPC
| Obligation | Frequency | When | Service |
|---|---|---|---|
| Digital lending registration renewal Maintain digital lending registration with the FCCPC and comply with its conduct conditions. | Annual | Annually, on the registration anniversary | View |
FIRS
| Obligation | Frequency | When | Service |
|---|---|---|---|
| Companies income tax return File the annual companies income tax return with self-assessment. | Annual | Within 6 months of the financial year end | View |
| Value added tax return File the monthly VAT return and remit VAT collected. | Monthly | On or before the 21st day of the month following the transaction month | View |
| Withholding tax remittance Remit withholding tax deducted from payments to third parties. | Monthly | By the 21st day of the month following deduction | View |
NDPC
| Obligation | Frequency | When | Service |
|---|---|---|---|
| Data protection compliance audit return File the annual compliance audit return with the Nigeria Data Protection Commission through a licensed Data Protection Compliance Organisation. | Annual | Annually, by the date prescribed by the NDPC | View |
| Personal data breach notification Notify the NDPC, and where required the affected data subjects, of a personal data breach within the statutory window. | On event | Within 72 hours of becoming aware of the breach | View |
NFIU
| Obligation | Frequency | When | Service |
|---|---|---|---|
| Currency Transaction Report filing Report cash transactions above the prescribed threshold to the NFIU through goAML. | Monthly | Within 7 days of the transaction | View |
| Suspicious Transaction Report filing Report suspicious transactions to the Nigerian Financial Intelligence Unit through goAML as soon as the suspicion is formed. | On event | Immediately on forming a suspicion, and no later than the statutory period | View |
SCUML
| Obligation | Frequency | When | Service |
|---|---|---|---|
| SCUML registration and renewal Register as a designated non-financial business or profession with the Special Control Unit against Money Laundering and keep the registration current. | Annual | On commencement of business, and renewed as required | — |