By Geraldine C. Nzulumike Esq, MCIArb and Chantel Umar Esq
Introduction
The evolution of agent banking in Nigeria over the past decade has been nothing short of transformative. At its core, agent banking refers to the delivery of financial services to customers by authorised third parties acting on behalf of licensed deposit-taking financial institutions. Through this model, banks and other regulated financial institutions extend their reach beyond traditional branches, enabling customers to access services such as cash deposits and withdrawals, bill payments, transfers, and account services within their local communities.
By extending financial services beyond traditional brick-and-mortar branches, agent banking has reshaped retail finance, deepened financial inclusion, and positioned non-bank intermediaries at the centre of everyday transactions. However, this rapid expansion has also revealed significant structural vulnerabilities, including widespread fraud, regulatory arbitrage, inconsistent compliance practices, and operational opacity.
In response to these challenges, the Central Bank of Nigeria (CBN) issued the Guidelines for the Operations of Agent Banking in Nigeria on 6th October 2025, which supersedes all other CBN guidelines on agent banking and agent banking relationships.[1] The Guidelines represent a decisive recalibration of the regulatory framework, introducing stricter oversight, clear accountability structures, and enhanced technological controls. This signals a shift from fragmented supervision to a more centralised, risk-based, and governance-driven model of agent banking regulation.
Who the Guidelines Apply To and When They Take Effect
The Guidelines apply uniformly to Deposit Money Banks, Other Financial Institutions, Payment Service Providers, Super-Agents,[2] and Licensed Agents operating within Nigeria’s agent banking ecosystem. While the Guidelines took immediate effect upon issuance, the CBN designated 1st April 2026 as the commencement date for the implementation of agent location and agent exclusivity.[3]
This phased implementation reflects regulatory pragmatism, providing institutions with a defined compliance window to restructure agreements, deploy requisite technology, retrain agent networks, recalibrate internal controls, and realign their risk management frameworks.
Agent Exclusivity
One of the most consequential reforms introduced by the Guidelines is the Exclusivity Rule. Under this rule, all agents, including Point-of-Sale (POS) operators, are permitted to affiliate with only one Principal Institution or one super-agent network.[4] This marks a significant departure from prior practice, where agents routinely maintained relationships with multiple financial service providers, enabling them to serve customers of competing platforms such as Moniepoint, OPay, and PalmPay simultaneously.[5]
While commercially convenient, multi-affiliation created profound regulatory and enforcement challenges. Monitoring agent conduct, attributing liability, and tracing misconduct across multiple principals proved problematic, often frustrating fraud investigations and weakening consumer protection. The new exclusivity requirement eliminates this ambiguity by anchoring each agent to a single accountable institution.
From a legal perspective, the implications are far-reaching. Existing contracts that permit multi-affiliation must be amended or re-executed to reflect exclusive relationships, and liability for agent misconduct becomes clearly traceable to one principal. Exclusivity, therefore, serves as a mechanism to enforce accountability within the agent banking value chain.
Agent Location and Geo-Fencing
The Guidelines also introduce stringent controls over agent location and mobility. All devices deployed for agent banking operations must now be geo-fenced or technologically tagged to operate strictly within the agent’s registered business premises or approved location. Agents are consequently prohibited from operating outside their authorised locations.[6]
This reform directly addresses the proliferation of mobile and untraceable POS terminals, which have significantly complicated fraud investigations and undermined consumer protection efforts. By tethering transactions to fixed approved locations, the CBN enhances traceability, strengthens evidentiary trails, and reinforces the integrity of the agent network.
Transaction Limits and Financial Controls: Implications for Daily Operations
Equally significant are the enhanced financial and transactional controls introduced by the Guidelines. Customers are restricted to a maximum of ₦100,000 (One Hundred Thousand Naira) daily for both deposits and withdrawals, while the weekly limit is fixed at ₦500,000 (Five Hundred Thousand Naira).[7] Furthermore, customers are restricted to a maximum of ₦100,000 (One Hundred Thousand Naira) per day and per week for bill payments conducted through agents, while agents themselves are subject to a cumulative daily cash-out (withdrawal) limit of ₦1,200,000 (One Million Two Hundred Thousand Naira).[8]
These thresholds form part of a broader anti-money laundering (AML) and anti-fraud strategy aimed at curbing transaction structuring, liquidity abuse, and illicit financial flows. To reinforce these objectives, Principal Institutions are required to establish dedicated agent accounts or wallets for routing all agent transactions. This ensures full visibility, auditability, and regulatory oversight of agent activities. The CBN also reserves the right to review and adjust these limits periodically in line with its Guide to Charges for Banks and Other Financial Institutions in Nigeria.[9]
Board and Management Liability
A notable innovation under the Guidelines is the explicit imposition of liability on the board of directors and senior management. Compliance failures within an institution’s agent network now attract personal consequences for those charged with oversight and governance. Enforcement measures include:[10]
- AML/CFT/CPF Non-Compliance. A fine of ₦2,000,000 (Two Million Naira) imposed on each member of the board of the financial institution, in addition to a ₦10,000,000 (Ten Million Naira) fine on the institution itself.
- Major Administrative Defaults. Fines commencing at ₦20,000,000 (Twenty Million Naira) for the offence, coupled with an additional penalty of ₦500,000 (Five Hundred Thousand Naira) for each day the default persists, such as operating without requisite CBN approval.
- Zero Tolerance for Unauthorised Operations. The imposition of substantial daily fines serves as a powerful deterrent, making prolonged non-compliance economically unviable and requiring immediate remedial action.
- Corporate Identity Violations. A fine of not less than ₦5,000,000 (Five Million Naira), mandatory immediate reversion to the approved name or logo, and an additional ₦100,000 (One Hundred Thousand Naira) for each day the default continues.
This exposure extends to enforcing agent exclusivity, monitoring agent locations, and complying with Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) obligations. The approach aligns with global regulatory trends that increasingly place responsibility for compliance not only on institutions but also on the individuals who direct and control them. Agent banking is thus elevated from a peripheral operational function to a core governance issue requiring sustained board-level oversight, periodic audits, and document risk assessments.
Consumer Protection Obligations
Beyond risk management and compliance, the Guidelines significantly strengthen consumer protection standards. Agents are required to issue transaction receipts that display their names and location coordinates, and transaction records must be retained for a minimum of five (5) years.[11] Practices such as unauthorised charges, interchange abuses, and misleading branding now attract strict sanctions enforceable against both agents and their principals.
These measures are designed to create a consistent and transparent consumer experience nationwide, regardless of location or agent type, while reinforcing public trust in the agent banking model.
Reporting, Monitoring, and Regulatory Enforcement
The Guidelines impose rigorous reporting obligations on financial institutions. Monthly returns must be submitted to the CBN no later than the 10th day of each month, detailing transaction volumes and values, fraud incidents, the number of active agents, customer complaints, and agent training activities, among other metrics. Any failure or deviation attracts administrative and regulatory sanctions, including suspension, blacklisting, or referral for criminal prosecution.[12]
Fraud investigations now trigger the immediate suspension of implicated agents, and any resulting conviction leads to permanent blacklisting. These measures are intended to sanitise the increasingly complex agent ecosystem and deter repeat misconduct.
Conclusion
The 2025 Guidelines for the Operations of Agent Banking in Nigeria mark a decisive turning point in the regulation of agent banking in Nigeria. Rather than treating agent banking as a peripheral channel for financial inclusion, the CBN has repositioned it as a core component of the formal financial system, demanding the same levels of governance, accountability, and regulatory discipline as traditional banking operations.
These reforms require a holistic reassessment of contractual arrangements, technology infrastructure, internal controls, and board-level oversight. Institutions that fail to adapt face not only institutional sanctions but also personal liability for directors and senior executives.
At the same time, the Guidelines seek to preserve the objective of agent banking by restoring trust, enhancing transparency, and strengthening consumer protection. If effectively implemented, the new Guidelines has the potential to stabilise the agent banking ecosystem, reduce systemic risk, and support the sustainable growth of Nigeria’s increasingly digitised financial services landscape.
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[1] ‘Central Bank of Nigeria Guidelines for the Operations of Agent Banking in Nigeria October 2025’ <https://www.cbn.gov.ng/Out/2025/CCD/CIRCULAR%20AND%20GUIDELINES%20FOR%20THE%20OPERATIONS%20OF%20AGENT%20BANKING%20IN%20NIGERIA%20OCTOBER%206%202025.pdf> accessed 12 December 2025
[2] A Super-Agent is an agent that has been contracted by a financial institution and may thereafter subcontract other agents in a network while retaining overall responsibility for the agency relationship
[3] Ibid n1
[4] ‘The Regulatory Earthquake: CBN’s New Rules for Agent Banking,’ Law Pavilion 4 December 2025 <https://lawpavilion.com/blog/the-regulatory-earthquake-cbns-new-rules-for-agent-banking/> accessed 12 December 2025
[5] ‘Nigeria’s Central Bank Limits POS Agents to one principal in new rules,’ Dabafinance 9 October 2025 <https://www.dabafinance.com/en/news/cbn-agent-banking-guidelines-pos-monopoly-2025> accessed 12 December 2025
[6] Olawale Atanda and Franklin Eze, ‘The CBN Agent Banking Guidelines 2025: Key Innovations and Regulatory Implications,’ TNP 11 November 2025 <https://tnp.com.ng/the-cbn-agent-banking-guidelines-2025-key-innovations-and-regulatory-implications/> accessed 12 December 2025
[7] Hope Moses-Ashike, ‘CBN limits daily cash withdrawals via agent banking to N100,000,’ Business Day 6 October 2025 <https://businessday.ng/business-economy/article/cbn-limits-daily-cash-withdrawals-via-agent-banking-to-n100000/#google_vignette> accessed 12 December 2025
[8] Busola Aro, ‘CBN issues guidelines for agent banking, sets daily transaction limit at N1.2m,’ The Cable 6 October 2025 <https://www.thecable.ng/cbn-issues-guidelines-for-agent-banking-sets-daily-transaction-limit-at-n1-2m/> accessed 12 December 2025
[9] Ibid
[10] Ibid n4
[11] Azeez Kareem, ‘CBN issues new agent banking rules,’ The Guardian 6 October 2025 <https://guardian.ng/business-services/money/cbn-issues-new-agent-banking-rules/> accessed 12 December 2025
[12] Ibid n8