Editor’s note: This update follows our August 2025 coverage — “Nigeria’s POS Market Faces Shake-Up as CBN Imposes ISO 20022 and Geo-Tagging Rules” — which outlined the tech mandates now being operationalized by today’s circular.
The Central Bank of Nigeria (CBN) has released a new circular—PSP/DIR/CON/CWO/001/049—that resets how agent banking and POS operations run nationwide. Signed by Musa I. Jimoh, the directive takes immediate effect and is designed to strengthen stability, deepen inclusion, and elevate consumer protection through tighter supervision, richer data, and stronger technology controls.
Headline Changes at a Glance
- Daily caps: POS/agent cumulative transactions capped at ₦1.2m per agent per day; individual customers limited to ₦100,000 per day.
- Mandatory monthly reporting: Institutions must file detailed returns by the 10th, covering transaction volumes/values, fraud incidents, complaints and remediation, active agent counts, device specs, training, and on-site visit notes.
- Designated accounts only: All agent transactions must pass through a dedicated account or wallet maintained by the principal; using non-designated accounts is a breach.
- Real-time rails & instant reversals: Transactions must process in real time on secure, interoperable infrastructure with immediate reversals for failed/erroneous debits.
- Geo-tagging/fencing: Devices must be geo-tagged and locked to the registered location; receipts must include agent name and GPS coordinates.
- Data retention: Maintain audit trails and settlement records for at least five years.
How This Builds on the August Report
In August 2025, the CBN set the industry’s technology foundation by mandating ISO 20022 payments messaging and mandatory geo-tagging/geofencing of terminals, with clear certification timelines. Today’s circular operationalizes that agenda—adding transaction caps (₦1.2m per agent; ₦100k per individual), monthly, data-rich reporting (due by the 10th), designated accounts/wallets, real-time processing with instant reversals, public agent registers, and graduated sanctions. Together, the two policies move the market from rapid, loosely governed expansion to trusted, auditable, tech-secure scale.
Governance, Conduct & Transparency
- Personal liability & watchlisting: Agents implicated in misconduct or fraud face personal liability, potential watchlisting, and termination.
- Public agent registers: Principals must publish and regularly update agent lists on their websites and display them in-branch.
- On-site supervision: The CBN may request additional information, perform inspections, and exercise direct supervisory powers at any time.
- Signed returns: Monthly returns must be signed by the MD/CEO and Chief Compliance Officer and addressed to the Director, Payments System Supervision Department.
Market Structure & Timing
- National reach: Super agents must maintain ≥50 agents across all six geopolitical zones, reinforcing coverage and inclusion.
- Premises control: Agents cannot relocate/transfer/close premises without written approval from their principal/super agent; a 30-day relocation notice must be displayed.
- Effective dates: Most provisions apply now; rules on agent location and exclusivity take effect April 1, 2026—a transition window to redesign networks and contracts.
What Institutions Should Do Next
- Automate compliance: Build pipelines to compile and submit the 10th-day returns (transactions, fraud, complaints, training, device metadata, visit notes).
- Harden tech: Enforce geo-fencing, device integrity/MDM, and instant reversal capabilities; tighten uptime SLAs with switches/processors.
- Rebalance networks: Adjust footprints for caps, improve liquidity planning, and publish accurate, updated agent registers.
- Train & monitor: Scale AML/CFT, fraud detection, reconciliation, counterfeit checks, and customer service training; document thoroughly.
Bottom line: The new circular is the enforcement spine for August’s tech mandates—turning compliance into capability and pushing Nigeria’s POS ecosystem toward safer, real-time, data-driven growth.
Related: “Nigeria’s POS Market Faces Shake-Up as CBN Imposes ISO 20022 and Geo-Tagging Rules” (Aug 2025).
