CBN Payment Service Provider Licence Application (Nigeria)

A CBN Payment Service Provider Licence Application in Nigeria submits the applicant's details to the relevant authority for the approval it seeks.

The legal basis for payment system regulation in Nigeria is the Banks and Other Financial Institutions Act 2020 (BOFIA 2020), the Central Bank of Nigeria Act 2007, and the CBN Payments Framework 2020. The CBN's Payment System Management Department (PSMD) is the primary CBN department responsible for licensing, supervising, and regulating payment service providers. Nigeria's payment industry is also supervised by the Nigeria Inter-Bank Settlement System (NIBSS), which operates the central payment infrastructure.

Nigeria has one of Africa's largest and most dynamic fintech and payments markets. The CBN has licenced over 100 payment service providers as of 2025, including major players such as Interswitch Group, Flutterwave, Paystack (a Stripe subsidiary), OPay, Moniepoint, and PalmPay. The Payments Framework 2020 replaced the earlier 2015 framework and introduced new licence categories including Payment Solution Service Providers (PSSP) and Super-Agents to reflect the growing diversity of payment business models.

The application support document helps promoters organise the extensive documentation required by the CBN — including the business plan, feasibility study, capital evidence, corporate documents, governance framework, and technology architecture — into a coherent submission that meets the CBN's requirements.

The legal framework governing the CBN Payment Service Provider Licence Application (Nigeria) centres on the Banks and Other Financial Institutions Act 2020 (BOFIA 2020), the Central Bank of Nigeria Act 2007, the CBN Regulatory Framework for the Payments System in Nigeria 2020 (Payments Framework 2020), and the Companies and Allied Matters Act 2020 (CAMA). The Corporate Affairs Commission (CAC) handles company incorporation. The Federal Inland Revenue Service (FIRS) administers corporate income tax under the Companies Income Tax Act (CITA) Cap C21 LFN 2004 and VAT under the Value Added Tax Act Cap V1 LFN 2004 (as amended by Finance Act 2020). The Nigerian Investment Promotion Commission (NIPC) Act Cap N117 LFN 2004 governs foreign-owned PSPs. The Nigeria Data Protection Act 2023 (NDPA), administered by the Nigeria Data Protection Commission (NDPC), governs data processing. The Money Laundering (Prevention and Prohibition) Act 2022 and the Nigerian Financial Intelligence Unit (NFIU) govern AML/CFT obligations. The National Industrial Court of Nigeria (NICN) has jurisdiction over employment disputes under the Labour Act Cap L1 LFN 2004. The Federal High Court has jurisdiction over CBN licensing disputes under Section 251 of the Constitution of the Federal Republic of Nigeria 1999. The Supreme Court of Nigeria is the apex court. Forms-legal.com provides this template as a starting point for Nigeria-compliant PSP licence documentation.

A CBN Payment Service Provider Licence Application in Nigeria is required in the following situations.

When a company wishes to operate a payment gateway enabling merchants to accept card payments, bank transfers, or mobile money payments from customers in Nigeria, a Payment Solution Service Provider (PSSP) licence under the CBN Regulatory Framework for the Payments System in Nigeria 2020 (Payments Framework 2020) is required, with minimum capital of NGN 100 million.

When a company plans to deploy and manage POS terminals at merchant locations in Nigeria on behalf of one or more acquiring banks, a Payment Terminal Service Provider (PTSP) licence is required, with minimum capital of NGN 100 million under the Payments Framework 2020.

When a company plans to operate a mobile money service — offering customers a stored-value wallet accessible via mobile phone — a Mobile Money Operator (MMO) licence under the CBN Guidelines for the Regulation of Agent Banking and Agent Banking Relationships in Nigeria 2013 is required, with minimum capital of NGN 2 billion.

When a telecommunications company or its financial services subsidiary wishes to operate as a Payment Service Bank (PSB) — providing savings, payments, and remittance services via digital channels to unbanked populations — a PSB licence under the CBN Framework for the Regulation and Supervision of Payment Service Banks in Nigeria 2020 is required, with minimum capital of NGN 5 billion, as held by MTN's MoMo PSB and Airtel's SmartCash PSB.

When a fintech startup that has been operating under a partnership or white-label arrangement with a licensed bank reaches the scale and compliance maturity to seek its own CBN payment licence under BOFIA 2020, enabling it to operate independently. Prior to application, the company must be incorporated under CAMA 2020 with the Corporate Affairs Commission (CAC), register with the Nigerian Investment Promotion Commission (NIPC) if foreign-owned under the NIPC Act Cap N117 LFN 2004, and obtain a Tax Identification Number (TIN) from the Federal Inland Revenue Service (FIRS). The National Industrial Court of Nigeria (NICN) has jurisdiction over employment disputes. The Nigeria Data Protection Act 2023 (NDPA) and Nigeria Data Protection Commission (NDPC) govern data processing. The Federal High Court has jurisdiction over CBN licensing matters under Section 251 of the Constitution of the Federal Republic of Nigeria 1999.

A complete CBN Payment Service Provider Licence Application must contain the following elements.

Application letter: A formal application letter to the Director of the Payment System Management Department, CBN, signed by the board, specifying the licence category sought and the proposed commencement date.

Business plan and feasibility study: A thorough document covering the proposed business model, target market, revenue projections for 5 years, competitive analysis, risk management framework, and technology infrastructure plan. The CBN assesses the viability and compliance of the business model.

Proof of minimum capital: Evidence that the required minimum paid-up share capital (ranging from NGN 50 million for a Super-Agent to NGN 5 billion for a PSB) has been raised and deposited, confirmed by the company's auditors and the receiving bank.

Corporate documents: CAC Certificate of Incorporation, Memorandum and Articles of Association (with appropriate payment services objects), board resolution authorising the application, and details of all shareholders holding 5% or more (with source of funds documentation for major shareholders).

Fit and proper persons forms: CBN Fit and Proper Persons assessment forms for all directors, senior management, and key control function holders, with supporting documentation.

Technology and security architecture: Technical documentation of the payment platform, including system architecture diagrams, data flow diagrams, security controls (PCI DSS compliance evidence where applicable), disaster recovery and business continuity plans, and NDPA 2023 data protection impact assessment.

Compliance framework: AML/CFT policy and procedures manual, KYC procedures, transaction monitoring framework, and sanctions screening policy compliant with the CBN's AML/CFT Regulations 2013.

CBN application fee: Payment of the non-refundable CBN application fee via Remita, at the rate published on the CBN website at cbn.gov.ng.

NIPC registration (for foreign-owned applicants): Certificate of Registration from the Nigerian Investment Promotion Commission (NIPC) under the NIPC Act Cap N117 LFN 2004, confirming the minimum capital importation of USD 100,000 for foreign investors.

AML/CFT policy: A detailed AML/CFT policy and procedures manual compliant with the CBN's AML/CFT Regulations 2013 and the Money Laundering (Prevention and Prohibition) Act 2022 Cap M18, including KYC procedures, transaction monitoring, and a sanctions screening policy covering OFAC, UN, and ONSA lists. Suspicious Transaction Reports (STRs) must be filed with the Nigerian Financial Intelligence Unit (NFIU) under Section 6 of the Money Laundering Act 2022.

Data protection documentation: A Data Protection Impact Assessment (DPIA) under Section 30 of the Nigeria Data Protection Act 2023 (NDPA), privacy policy, and notification to the Nigeria Data Protection Commission (NDPC). Payment platforms processing card data must also achieve PCI DSS certification.

Tax registration: TIN from the Federal Inland Revenue Service (FIRS) under the Tax Identification Number Decree Cap T1, VAT registration under the Value Added Tax Act Cap V1 LFN 2004 (as amended by Finance Act 2020), and PAYE registration for staff under the Personal Income Tax Act (PITA) Cap P8 LFN 2004 with the relevant State Internal Revenue Service (SIRS).

Governing law and disputes: Nigerian law governs. The Federal High Court has exclusive jurisdiction over CBN licensing disputes and BOFIA 2020 matters under Section 251 of the Constitution of the Federal Republic of Nigeria 1999. The National Industrial Court of Nigeria (NICN) handles employment disputes under the Labour Act Cap L1 LFN 2004. Forms-legal.com provides this template as a starting point for Nigeria-compliant PSP licence documentation. The Supreme Court of Nigeria is the apex court.