No new rules. Just consequences.
Also, what are Nigerian fintechs doing with AI?
If you missed last week’s newsletters, catch up here and here. If this newsletter was forwarded to you, subscribe here for free:
TOGETHER WITH CREDIT DIRECT
When your money has direction, it works harder for you. Clear goals turn intentions into action and help you stay focused on what truly matters.
Start building toward what you want with a plan that rewards commitment andconsistency. Set your target, stay on track, and watch your goals move closer to reality.
Just Consequences
I like to think that if you were starting a fintech company in Nigeria fifteen years ago, it would have gone like this: have a product idea, then spend a minute or two squinting at the licence categories. If nothing fit neatly, you built anyway. You tested, you iterated, you grew until you became too successful to ignore.
It was the age of anarchy experimentation.
Back then, Nigeria didn’t offer a neat “digital bank” license. Instead, the industry grew within a patchwork of mobile money, switching, processing, PSSP, and payment solution licenses. This regulatory negative space was a feature, not a bug. Smaller players played fast and loose, onboarding millions with lighter KYC friction and avoiding the heavy compliance anchors that slowed down traditional banks.
But it is now 2026, and you cannot launch first and worry about regulations later because fintechs are no longer experiments.
Moniepoint reported processing 5.2 billion transactions worth ₦94 trillion in 2023. Paga says it processed ₦17 trillion across 169 million transactions in 2025. These are big companies and their velocity means there’s systemic risk in there.
At the 60th Annual Bankers’ Dinner on November 28, 2025, CBN Governor Olayemi Cardoso signaled that the era of “letting things slide” is officially over:
“By mid-2025, leading fintech apps had surpassed 10 million downloads each, with one surpassing 50 million downloads, reflecting deep consumer adoption.”
This scale necessitates a transition from a ‘wait-and-see’ approach to one of rigorous oversight, ensuring that these entities—which have become systemically important—operate with the same institutional gravity as traditional banks.
When Cardoso promised “more scrutiny,” many people assumed that meant a blizzard of fresh rules.
Instead, the message, made clearer in the CBN’s new policy paper, Shaping the Future of Fintech in Nigeria: Innovation, Inclusion and Integrity, is more pointed: we don’t need a new rulebook. We need to enforce the one we already have, and upgrade the infrastructure that makes enforcement possible at fintech scale.
Two takeaways matter (to me) most.
The first is that the CBN views payments as a problem that’s largely solved. If you live in urban Nigeria in 2026, you can buy pepper, akara, suya, or groceries assuming that someone, somewhere, will accept a transfer or shove a POS terminal in your direction. I haven’t carried a debit card in over a year. Most transactions are processed in under a second.
You wouldn’t exactly know this, given how some Nigerians fawn over Pix or any other country’s instant transfers. There’s rice at home, people of God.
Anyway, nothing is perfect, and peak periods still expose the seams: surges, timeouts, intermittent downtime, fraud spikes, dispute backlogs. So we need to shift from building capacity to maintaining trust through resilience, uptime standards, fraud controls, and consistent supervision.
But financial services transcend payments. Formal credit penetration is 6%, insurance is 3,% and pensions is 8%. Those are dreadful numbers.
Nigeria’s low transaction fees (call all the people who constantly complain about banking fees) make the “commercial viability” of pushing payments and credit into rural markets harder. Whatever happened to the Payment Service Banks and agent banks that were supposed to take payments and credits to the last mile?
PSBs can collect money and move money, but they cannot lend, so there’s one dead end. Agent banking, too, has stubbornly remained mostly a cash-in, cash-out business, largely because there’s weak demand for anything else.
These realities are forcing the CBN to consider a few structural shifts to fix its approach to inclusion. According to the report, the CBN is now coordinating a review of PSB lending restrictions, a sign that the ban on lending, the very thing that handicapped MoMo and others from the start, could be lifted.
To solve the cost problem of rural onboarding, the Bank is also collaborating with NIMC to provide affordable, developer-friendly NIN APIs, effectively turning identity verification into a low-cost utility. Most tellingly, the report hints at a move toward a dedicated Digital Bank authorisation framework, signaling that the CBN would rather empower new entrants with a full credit engine than continue to patch up the limited PSB mandate.
TOGETHER WITH BUSHA
Still waiting days for international settlements? Pay global partners in minutes with
Busha Business. Explore the smarter way to move money.
What are Nigerian fintechs doing with AI?
My top answer would have been credit decisioning, but it came in a close second. The biggest use case for AI by far is fraud detection (87.5% of respondents), according to the CBN report.
Credit scoring, risk modelling, and onboarding/KYC sit much lower. Fraud has been the headline since 2024, so maybe no big surprises there.
The report talks up shared utilities—Compliance-as-a-Service, fraud intelligence hubs, supervisory technology (SupTech), and real-time alerts. It even references strengthening the Central Industry Fraud Desk (HAWK) hosted at NIBSS.
That’s it. See you on Sunday!