What licensing steps and ongoing obligations are required for a fintech to operate a payment service bank in Nigeria?

Hello, Our Law Firm can help you navigate the Fintech registration and AML compliance requirements. We operate from Lagos Nigeria, New York and Houston Texas. Our Attorneys in Lagos can help file all regulatory compliance requirements and complete your compliance and registration process. Thank you. Lakinberg LLP.

First you would need to register with the Corporate Affairs Commission with a share capital of between 50M - 2B depending on the kind of Fintech Services your company wants to offer. Then you get the requisite License from the Central Bank of Nigeria; requirements and documents will largely depend on the kind of services your Fintech company wants to offer. Your company will then register with the necessary anti-money laundering parastatals of the government, etc. The process cannot all be exhausted on this platform; we advise you to visit our office for a consult to educate you on your legal options. Note the 50M -2B share capital is determined on the kind of Fintech services you want to provide. I hope this helps.

1. Regulatory classification

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  A fintech offering wallets, transfers, bill payments, agent banking etc. typically falls under a Payment Service Bank (PSB) or Other CBN Payment Licences (e.g. MMO – PSSP, PTSP, Switching), depending on scope.

  
  


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  If you want deposit-like wallets and broad retail payments, the PSB licence is the closest fit (you cannot lend or take FX).

  
  

2. Licence & capital

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  Regulator: Central Bank of Nigeria (CBN) under BOFIA 2020 and CBN Guidelines.

  
  


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  PSB capital: ₦5 billion minimum paid-up share capital (plus escrow during approval-in-principle stage).

  
  


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  Two stages: Approval-in-Principle (AIP) → Final Licence (after infrastructure, governance, audits).

  
  

3. Key compliance obligations

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  AML/CFT: Full KYC (tiered wallets), transaction monitoring, STR/CTR filing with NFIU, sanctions screening, AML policies, MLRO appointment.

  
  


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  Consumer protection: Dispute resolution, transparency, safeguarding of customer funds (trust accounts with DMBs).

  
  


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  Prudential & reporting: Periodic CBN returns, audits, risk management, board governance.

  
  


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  Data protection: NDPR compliance—privacy policy, lawful processing, DPO, data security, breach reporting.

  
  


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  Operational limits: PSBs cannot grant loans, deal in FX, or underwrite insurance.

  
  

4. Do you need legal representation?

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  Practically, yes. The process is document-heavy and technical (licence selection, capital structuring, CBN engagement, policies, compliance manuals, audits). Proper counsel reduces rejection risk and helps with ongoing regulatory compliance.

  
  

1. Regulatory classification A fintech offering wallets, transfers, bill payments, agent banking etc. typically falls under a Payment Service Bank (PSB) or Other CBN Payment Licences (e.g. MMO – PSSP, PTSP, Switching), depending on scope. If you want deposit-like wallets and broad retail payments, the PSB licence is the closest fit (you cannot lend or take FX).
2. Licence & capital Regulator: Central Bank of Nigeria (CBN) under BOFIA 2020 and CBN Guidelines. PSB capital: ₦5 billion minimum paid-up share capital (plus escrow during approval-in-principle stage). Two stages: Approval-in-Principle (AIP) → Final Licence (after infrastructure, governance, audits).
3. Key compliance obligations AML/CFT: Full KYC (tiered wallets), transaction monitoring, STR/CTR filing with NFIU, sanctions screening, AML policies, MLRO appointment. Consumer protection: Dispute resolution, transparency, safeguarding of customer funds (trust accounts with DMBs). Prudential & reporting: Periodic CBN returns, audits, risk management, board governance. Data protection: NDPR compliance—privacy policy, lawful processing, DPO, data security, breach reporting. Operational limits: PSBs cannot grant loans, deal in FX, or underwrite insurance.
4. Do you need legal representation? Practically, yes. The process is document-heavy and technical (licence selection, capital structuring, CBN engagement, policies, compliance manuals, audits). Proper counsel reduces rejection risk and helps with ongoing regulatory compliance.