Regulation has long shaped the trajectory of Nigeria’s fast-growing fintech industry. Over the years, the Central Bank of Nigeria (CBN) has introduced multiple guidelines and frameworks on payments, digital lending, open banking, mobile money, IMTOs, cybersecurity, and even e-Naira operations. The most recent addition is the Guidelines for Agent Banking which reflects the regulator’s ongoing efforts to keep pace with rapid digital transformation.
However, a new legislative initiative is now at the centre of national debate. The House of Representatives is currently reviewing a bill that would establish a Nigerian Fintech Regulatory Commission, a standalone agency empowered to license, supervise, and enforce compliance across all fintech activities in Nigeria.
Under the draft bill, the commission would issue activity-specific licenses covering payments, lending, investment platforms, crowdfunding, and other digital services. It would also set standards for consumer protection, dispute resolution, data governance, operational resilience, and technology requirements with authority to impose sanctions or revoke licenses for non-compliance. Supporters argue that a dedicated regulator would close loopholes exploited by bad actors and give legitimate operators clearer rules as they scale.
A Potential Industry Arbiter
Beyond licensing, the commission is envisioned as a powerful industry watchdog capable of compelling information, conducting investigations, and resolving disputes involving fintechs, banks, and telecom operators.
Lawmakers say it could intervene on issues around interoperability, pricing abuses in digital lending, access to shared infrastructure, and customer redress which is a key pain points that have intensified as Nigeria’s digital finance ecosystem expands.
Proponents insist the move is necessary because Nigeria’s adoption of mobile payments and online credit has outpaced the capacity of current regulators, heightening risks linked to fraud, financial instability, data misuse, and consumer exploitation.
But the Proposal Raises Tough Questions
Despite its ambition, the plan introduces issues around regulatory overlap, institutional coherence, and operational clarity. Nigeria’s fintechs already fall under a crowded regulatory landscape:
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CBN – payments, lending, digital banking
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SEC – investments, securities, crowdfunding
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NITDA – data protection
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FCCPC – consumer rights and fair competition
It is unclear how these overlapping compliance regimes would be streamlined under a new body or how fintech subsidiaries owned by banks would navigate requirements between the CBN and the proposed commission.
For instance, if a commercial bank establishes a digital lending subsidiary, would the parent company need multiple licenses from both regulators? Would the CBN continue supervising digital lending, or would that role shift entirely to the new fintech commission?
These uncertainties are amplified by the ongoing convergence of banking and fintech. As banks adopt fintech-style models and fintechs take on traditionally banking-centric roles, the line between “bank” and “fintech” continues to disappear. Any new regulator would therefore need a mandate flexible enough to remain relevant as the industry evolves.
An Alternative Approach: Strengthen What Exists
Rather than building an entirely new bureaucracy, Nigeria could take a more streamlined approach by enhancing the CBN’s dedicated fintech oversight capacity. Establishing a specialised digital finance directorate within the CBN could provide clarity, avoid duplication, and maintain direct accountability.
This is consistent with global practice.
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In the United States, fintech oversight is activity-based and distributed among existing agencies such as the CFPB, FTC, SEC, OCC, and FinCEN, each handling areas aligned with their expertise.
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In the United Kingdom, fintechs are regulated under the existing frameworks of the Financial Conduct Authority (FCA) and the Prudential Regulation Authority (PRA), with rules set through legislation such as the FSMA, PSRs, and EMRs. No separate fintech regulator exists.
These models demonstrate that effective oversight does not necessarily require a new agency but rather stronger coordination and clear regulatory boundaries.
The Way Forward
The proposed bill establishing the Nigerian Fintech Regulatory Commission (HB.2389) assumes that centralising oversight will automatically drive innovation, investor confidence, and consumer protection. But these same outcomes are achievable by improving collaboration among existing regulators, clarifying responsibilities, and modernising supervisory tools.
While the intent behind the proposed commission reflects genuine concern for financial stability, consumer welfare, and market integrity, Nigeria’s fintech future may be better served by smarter, integrated, and adaptive regulation not more regulators.
A coordinated, data-driven approach across existing institutions could provide the clarity and protection the ecosystem needs while preserving accountability and promoting sustainable innovation.
