ADERONKE ALEX-ADEDIPE AND MARK IMONITIE
Introduction
The Central Bank of Nigeria (CBN) on Monday, October 6 2025, issued new operational guidelines for Agent Banking in Nigeria. The purpose of the Guidelines is to strengthen and secure the enabling environment for providing financial services to the underbanked regions in the country.
The Guidelines also aim to consolidate all existing policies related to Agent Banking and Agent Banking relationships into a single comprehensive set of rules that addresses emerging issues within the ecosystem. Accordingly, the Guidelines supersede all previous CBN guidelines on Agent Banking.
In this newsletter, we examine some of the key provisions introduced by the Guidelines which affect Agency Banking operations in Nigeria.
1. AGENT EXCLUSIVITY
The Guidelines significantly changes the Agent Banking framework in Nigeria. Previously, Agents could operate across multiple platforms managed by various Principals—such as banks, microfinance institutions, payment service banks, or mobile money operators—to serve customers. Under the new Guidelines, Agents must now be exclusively tied to a single Principal.
In essence, an Agent can no longer provide services for multiple licensed deposit-taking financial institutions authorized to engage Agents. Additionally, Agents may belong to only one Super Agent’s network at the same time.
To formalize Agency relationships, Principals are required to enter into an Agreement with their Agents, which must, at a minimum, include terms on: duration; authorized services; applicable fees and charges; use of dedicated Agent accounts for all transactions; Agent remuneration; breach instances and penalties; business hours and geographic location; obligations of both parties; AML/CFT/CPF and KYC compliance requirements; confidentiality and non-disclosure; limitation of liability; dispute resolution; amendments; opt-in/opt-out rights; termination; and force majeure provisions.
According to the CBN, implementation of agent exclusivity will take effect from April 1, 2026.
2. DEDICATED AGENT ACCOUNTS
As a measure for transaction oversight, the Guidelines mandate Agents to conduct all Agent Banking transactions exclusively through a dedicated account or wallet assigned by a Principal. Furthermore, Principals are responsible for ensuring that payment terminals used by Agents are connected solely to this dedicated Agent account or wallet.
Conducting any transaction outside the designated account will be deemed a violation of the Guidelines, with the Agent personally liable for any resulting fraud or illegal activity.
Principals are authorized to terminate the Agent Banking agreement with any Agent who breaches the provisions of the Guidelines and such Agents may also be blacklisted by the CBN or placed on a watchlist.
3. OPERATIONAL AND TRANSACTIONAL LIMITS
The Guidelines establish additional operational and transaction limits for Agent Banking services, requiring Principals to ensure that these limits comply with the maximum regulatory thresholds set forth in the Guidelines.
Specifically, the Guidelines set a daily cash-in deposit limit of N100,000 and a weekly limit of N500,000. For cash-out withdrawals, Agents are restricted to a maximum of N100,000 daily and N500,000 weekly. Additionally, the Guidelines impose daily and weekly limits of N100,000 for utility and service bill payments.
Prior to the Guidelines, transaction limits only applied to withdrawals, and Principals were allowed to determine the limits for cash-in deposits and utility bill payments.
4. LOCATION AND LIST OF AGENTS
Under the Guidelines, the physical address or location of an Agent’s business operations must be mutually agreed upon by the Principal and the Agent. Principals are required to publish an updated list of all their Agents and their respective locations on their websites.
Agents must provide their Principals with at least thirty (30) days’ prior notice, or any other period agreed upon in the Agent Banking Agreement, before relocating or shutting down operations. Furthermore, Agents are obliged to display a visible notice of their intention to relocate or shutdown at their business premises throughout the notice period to inform their customers and Principals before relocating. Principals are mandated to report to CBN the relocation or closure of Agent’s location.
As part of measures to prevent Agents from operating at multiple locations, the Guidelines require every PoS terminal to process real-time transactions and be geo-fenced to the Agent’s registered location. Devices used by Agents cannot be moved or shared without formal approval from Principals and the location of Agents is restricted.
The implementation of the provisions in the Guidelines on agent location shall be with effect from April 1, 2026.
5. MANDATORY TRAINING FOR AGENTS
The Guidelines require Principals and Super Agents to ensure that their Agents complete training before onboarding. This training must, at a minimum, cover (i) Agent responsibilities and obligations, (ii) KYC regulations and customer registration requirements, (iii) transaction processes, (iv) prohibition of transactions on behalf of customers, (v) consumer protection laws and consequences of non-compliance, (vi) diversity and inclusion principles and their application, as well as basic financial literacy for both customers and Agents, amongst others.
This training requirement is commendable, as it ensures Agents remain well-informed of their legal and compliance obligations. However, the mandate on Principals increases their compliance responsibilities, which may lead to higher operational costs.
6. ENHANCED ELIGIBILITY AND DUE DILIGENCE REQUIREMENTS
The Guidelines also enhance the appointment requirements for both individual and non-individual Agents, mandating the provision of detailed information to the Principal, including;
Name, residential address, sex, age, local government area (LGA), and state
Physical business address, postal address, and telephone numbers
Evidence of available funds to support Agency operations
Bank Verification Number (BVN) and National Identity Number (NIN) for individual Agents; and
Disclosure and evidence of termination of any previous Agent banking relationships for the prospective Agent and designated employees.
For non-individual Agents, additional documentation includes:
- Certificate of incorporation or business name registration with the Corporate Affairs Commission (CAC);
- Names of designated employees;
- Three (3) years of Tax Clearance Certificates and Tax Identification Number (TIN); and
- BVNs of promoters, directors, and signatories to the Agent’s bank accounts.
Principals or Super Agents must conduct thorough due diligence before appointing or onboarding Agents. This due diligence must, at minimum, comprehensively verify:
- The background and professional suitability of the Agent or business operations for non-individual Agents, including promoters, directors, partners, and management;
- Credit history from credit bureaus or other sources;
- Criminal records related to fraud or dishonesty;
- Sources of funds;
- Business address or location submitted by the Agent; and
- Any prior relationships with the Principal that may adversely affect the Agent Banking relationship.
Conclusion
The CBN Guidelines for Agent Banking Operations represents a significant step forward in strengthening the integrity, security, and efficiency of Agent Banking in Nigeria.
By introducing stricter eligibility criteria, enhanced due diligence, robust transaction limits, and comprehensive training requirements, these regulations seek to protect consumers, promote financial inclusion, and build trust in the Agent Banking ecosystem.
Financial Institutions and Agents alike must prioritize compliance to fully realize these benefits while mitigating against operational risks. As Nigeria’s Agent Banking sector evolves, adherence to the Guidelines will be essential for sustainable growth, transparency and confidence among all stakeholders in the digital financial services landscape.