On the 11th of July 2021, the Central Bank of Nigeria (CBN) issued a Regulatory Framework on Mobile Money Services in Nigeria. Mobile Money Services (MMS) involve the use of mobile phones for the initiation, authorization, and confirmation of the transfer of value from a savings, current or stored value account.

The CBN recognizes the growth and expansion of mobile services in Nigeria and sees Mobile Money Services as a means of financial inclusion and as a veritable channel for facilitating the growth of e-commerce.

Objectives of the Framework

The framework identifies its objectives as:

  1. The provision of an enabling environment for the adoption of MMS thereby reducing cash dominance in the Nigerian Economy
  2. To ensure that mobile money services develop in a structured and orderly manner with a clear definition of the participants, their roles and responsibilities
  3. To specify the minimum technical and business requirements for the various participants in the industry
  4. To provide guidelines for the operation of MMS from implementation to completion
  5. To promote safety and effectiveness of mobile money services and enhance user confidence in the services

The Scope of the Framework and Model for Implementation

The framework identified two models for the operation of MMS in Nigeria which are:

  1. Bank Led – wherein a bank or a consortium of banks are the lead initiator with the goal to leverage on MMS to provide banking services.
  2. Non-Bank Led – wherein a corporate body duly licensed by the CBN shall act as the lead initiator.

The framework while recognizing the model wherein Mobile Network Operators (MNOs) act as initiators but it also states that model shall not be operational in Nigeria. This is to ensure the full control of the CBN over monetary policy operations, risk minimization, and to ensure that only organizations that have been licensed by the CBN are allowed to provide MMS.

The Participants in the Mobile Money System

The participants are grouped into 6 categories and each with their own definitions and responsibilities:

  1. Regulators
  2. Mobile Money Operators
  3. Infrastructure Providers
  4. Other Service Providers
  5. Consumers
  6. Mobile Money Agents.

We shall now look briefly at each category and where stipulated, their responsibilities.


The regulators for the purpose of the framework shall be the CBN and the Nigerian Communications Commission (NCC). The CBN shall be responsible for defining and monitoring the mobile money systems in Nigeria.

Mobile Money Operators

These are organizations licensed by the CBN to provide the system for the mobile money services as Mobile Money Operators. These organizations include Banks and Licensed Corporate Organizations.

They are required to provide infrastructure for mobile money services, business continuity and disaster recovery plans to ensure round the clock business availability and ensure that all signed-on participating institutions follow the same rule.
They shall also provide a detailed payments management process that covers the entire solution delivery from user registration and management, agent recruitment and management, consumer protection/dispute resolution procedures, Risk management process to transaction settlement.

They are required to connect to the National Central Switch (NCS) to ensure interoperability of all schemes in the system. A scheme operator may be a bank or a licensed corporate organization. As lead initiators of the mobile money scheme, they shall ensure that all solutions and services comply with regulatory requirements, and they shall be legally responsible and accountable to the CBN and the end user. All advertisements and public pronouncements shall emanate and be issued by the lead initiator only.


Banks as MMOs shall provide all financial services for the operation of mobile money services and verify, approve and be accountable to the CBN for the credibility and integrity of their partner organization and recommending same for the CBN approval.


Non-bank MMOs shall provide and manage the technology required to deliver mobile payment services to the subscriber and provide agent networks required to extend all the proposed services to the marketplace.

Infrastructure Providers

These are organizations providing infrastructure that enables switching, processing, and settlement facilities for mobile money services. They are:

Telecommunications: they provide the infrastructure to drive the exchange of messages for mobile money payments.

Inter-Scheme Settlement Provider: they provide net positions of transactions across schemes to inter-bank settlement system to affect the finality of payment for services consummated across two different schemes by various participants.

Other Service Providers

These are service providers who have developed specialized skills and resources to fill gaps created because of the evolution of mobile money services. MMOs may need to outsource certain aspect of their business to these service providers. The MMOs may employ the infrastructure of the service providers to provide services to the end users.


These are the end users of mobile money services.

Mobile Money Agents

Their activities are to be guided by the provisions of the Guidelines on Agent and Banking Relationship in Nigeria. 

Mobile Money Scenarios

The methods by which mobile money can be carried out in Nigeria are:

Bank Account Based

This is when the mobile money system drives transactions through bank accounts of customers. Bank Account Based scenario includes but is not limited to Pull-based account transactions (debits through a mobile money solution) and Push-based account transactions (credits through a mobile money solution). A pull-based transaction shall be authorized by the account holder via a verifiable mode before the transaction is consummated.

Card Account Based

This is when a payment card is linked to a mobile phone for the purpose of initiating and concluding payments. The types of card-driven payments recognized by this framework include Credit, Debit and Pre-Paid.

Stored Value Account Based

This is when a mobile money system drives transactions through a system-based account that shall comply with the standards within the framework. The types of Stored Value Account recognized by the framework include Re-loadable Stored Value Account, Pre-Paid Account

Other key areas which the Framework addresses are


The components of the core infrastructure for a National mobile payment system are transaction processing, clearing and settlement platforms and agent network. The provision and management of these platforms is to be shared among the various stakeholders and service providers.


The settlement finality for the mobile money system will use the already existing NIBSS Infrastructure and the CBN Real Time Gross Settlement (RTGS). Using the established infrastructure will ensure instant payment to the end users and settlement of the Scheme providers on a T+1 (a day from the date of the transaction) cycle for the mobile money system.

Scheme Dispute Resolution

The platform for inter scheme transaction disputes between participants shall be provided by NIBSS. The best global practices for arbitration are to be used for the dispute resolution process.

Risk Management

The framework specifies certain measure to mitigate risk arising from the activities of MMOs. They are required to ensure risk minimization techniques are in place to minimize operational, liquidity, technical, fraud, financial and money laundering risks. They are also not to be susceptible to prolonged operational failure due to system outages. MMOs must assign a risk compliance manager to provide internal risk management oversight. The risk management programme will be reviewed by the CBN on a periodic basis.


The technology deployed for Mobile money services is to comply with international best practices for the service. It is to be reliable, user friendly, safe and secure. All MMOs are required to interconnect through NIBSS to ensure interoperability.

User Interface

The user Interface shall at the minimum allow customers make selections from a menu, not provide access to confidential information and PINs shall be encrypted at the point of entry.

Know Your Customer (KYC) and Customer Due Diligence (CDD) Requirements

MMOs are to comply with the provisions of all existing laws.

Anti-Money Laundering (AML) Regulation

The provisions of the CBN AML document shall apply to mobile money services. The regulatory authorities also have the right to change the criteria for suspicious transactions reporting in terms of mobile money as it deems fit. When such changes are made, they are to be communicated to the MMOs and other stakeholders through the appropriate channels.

Consumer Protection and Dispute Resolution

A dispute resolution system is to be put in place to inspire customer confidence in the system.

Mobile Money Savings Wallets in Nigeria

MMOs may offer saving wallet services to meet the demands of the unbanked. This will be according to the modalities prescribed in the Guidelines.


The Framework issued by the CBN on mobile banking provides more structure and detail to the system while also introducing new services such as Mobile Money Savings wallets to cater to the needs of the unbanked population in Nigeria. This is expected to foster more economic growth as it improves the ease with which money can be transferred from one person to another.

Published by David

Head, Legal Team