BY ADERONKE ALEX-ADEDIPE AND HILLARY OKOROTIE
Introduction
On July 8th, 2025, the Nigerian Communications Commission (NCC) published a regulatory framework for licensing international Application to Person (A2P) messaging services in Nigeria. In this newsletter, we highlight some of the salient provisions of the Framework and their impact on the telecommunication sector including the eligibility criteria, application process, and compliance obligations for licence holders.
What is A2P Messaging?
A2P messaging is an internet based messaging service typically used by businesses and organisations in transmitting messages to individuals over mobile networks. It is commonly used to deliver promotional or transactional messages such as marketing campaigns, service announcements, product advertisements, and order updates. The Framework introduces the International Application to Person Messaging Aggregator Licence (“IA2P Aggregator Licence”) that will regulate the provision of these services.
What is the Scope of the IA2P Aggregator Licence?
Key players in the telecommunications industry who currently provide international A2P messaging services will now be required to register with the NCC in order to continue their operations.
According to the NCC, the IA2P Aggregator Licence permits the licencee to provide the following services:
- Aggregation of international A2P messages on behalf of licenced operators in Nigeria;
- Provision of transactional messaging services;
- Delivery of notifications and alerts;
- Sending of A2P messages; and
- Provision of subscriber protection mechanisms (opt-in and opt-out mechanisms).
- Upon initial approval, the IA2P Aggregator Licence will be valid for a period of five (5) years and may be renewed for an additional five-year term.
The licence fee has been set by the NCC at ₦10,000,000 (Ten Million Naira).
Eligibility Criteria and Technical Requirements for the IA2P Aggregator Licence
To be eligible for the IA2P Aggregator Licence, an applicant must fulfil the following requirements:
- Must be a corporate entity registered in Nigeria.
- The entity is required to submit a contract with at least one host network operator or national carrier for the provision of international A2P messaging services.
- The applicant must also demonstrate financial capacity to cover both capital and operational expenditure of its operations.
- In addition, applicants are expected to integrate with local Mobile Network Operators (MNOs) and implement robust systems for fraud detection, security monitoring, and data protection.
- All international A2P messaging traffic must be routed through a centralized Short Messaging Service (SMS) firewall or any other technology mandated by the NCC. These technical requirements are aimed at ensuring the integrity of message transmissions and protecting against fraud and other security risks.
What are the Limitations of Licence Holders?
Holders of the IA2P Aggregator Licence are restricted from offering services beyond the specific scope of the licence. They are prohibited from engaging in any activity or providing any service for which they do not hold a valid licence issued by the NCC.
Specifically, licence holders are not permitted to operate transmission networks, switches, external fibre links, or any other infrastructure or services that require separate licensing under existing NCC regulations or other government regulations.
Specific conditions to be observed by Licence Holders
The Framework also outlines specific operational conditions that IA2P Aggregator Licence holders must observe. These conditions are aimed at ensuring regulatory compliance and consumer protection. Licence holders are required to operate in full compliance with the provisions of the Nigerian Communications Act and all other relevant regulations and guidelines issued by the NCC. All messages transmitted must include sender identification, and any message not including a sender identification is to be rejected.
In addition, licence holders must implement appropriate data protection measures. They are also required to provide a functional opt-in and opt-out mechanism that allows individuals to manage their message preferences. The Framework also prohibits the distribution of unsolicited or spam messages to consumers.
Conclusion
Previously, with no framework regulating international A2P messaging services, MNOs independently monetized the service and determined the tariff rates, which resulted in non-uniform termination rates. With the introduction of the Framework, the NCC aims to standardize the delivery of International A2P messaging services in Nigeria and ensure the secure transmission of SMS.
In addition, the Framework provides for the regulation of SMS termination rates, to provide a transparent market for operators involved in international A2P messaging.