CBN’s 2026 Rules Set to Reshape Nigeria’s Fintech and Banking Landscape
4 min read
If Nigerian fintech founders thought 2025 was a migraine, 2026 is shaping up to require something stronger. As the year closes, the Central Bank of Nigeria (CBN) has released a series of policy documents that significantly reshape how traditional banks, neobanks, payment service banks (PSBs), and large agency banking networks such as Moniepoint, OPay, and PalmPay operate.
The regulator’s approach can best be described as aggressively prudent. On one hand, cash is being made easier to bring into the banking system but harder and more expensive to take out. On the other, the cost of ignoring fraud, particularly digital payment fraud, is rising sharply.
The first major shift comes from the revised cash-related policies that take effect on January 1, 2026. The CBN has reversed its earlier posture toward cash deposits. Previously, agents and businesses feared penalties for depositing large volumes of cash. Under the new framework, cumulative deposit limits and the associated excess deposit fees have been removed. For agency banking networks that function as informal ATMs for millions of Nigerians, this offers relief. Agents can now deposit unlimited cash without penalty, removing the anxiety around being taxed on daily collections.
However, this relief is counterbalanced by a far tighter regime on withdrawals. The special authorisation that once allowed individuals and corporates to withdraw up to N5 million and N10 million respectively on a monthly basis has been abolished. Individuals are now limited to N500,000 in cash withdrawals per week across all channels, while corporates are capped at N5 million weekly. ATM withdrawals are restricted to N100,000 per day, with a maximum of N500,000 per week.
Exceeding these limits attracts significant penalties. Individuals will pay a 3 percent fee on excess withdrawals, while corporates will pay 5 percent. Notably, these charges are split between the regulator and the banks, with 40 percent going to the CBN and 60 percent retained by the financial institution. This effectively turns excess cash withdrawals into a revenue stream and reinforces the push toward digital transactions.
Even long-standing exemptions have been removed. Embassies, diplomatic missions, and donor agencies, which previously enjoyed special treatment, are now subject to the same weekly withdrawal caps as small and medium-sized enterprises. The message is clear: exceptions are no longer part of the policy landscape.
Alongside the cash reforms, the CBN has introduced draft guidelines on handling Authorised Push Payment (APP) fraud, marking a major shift in fraud liability. Traditionally, when customers were tricked into sending money to fraudsters through social engineering, banks could deny responsibility on the grounds that the transaction was authorised. The new guidelines dismantle that defence.
Under the proposed rules, banks may be required to reimburse customers even when the customer authorised the transaction, provided the customer was not grossly negligent. In cases where neither the sending nor receiving bank is clearly at fault, the cost of reimbursement must be shared equally between them. This introduces a new and potentially volatile risk for banks and fintechs.
The guidelines also impose a higher duty of care toward vulnerable users, a term that remains loosely defined in a market with wide variations in digital literacy. This ambiguity is expected to create significant compliance and legal challenges.
Timelines for action are tight. Customers must report fraud within 72 hours to qualify for guaranteed reimbursement. Banks are required to complete investigations within 14 working days and, where the customer’s claim is upheld, issue reimbursement within 48 hours. If another bank is involved, the originating institution has just 30 minutes to notify its counterpart.
Perhaps the most far-reaching requirement is the mandate for banks to implement early warning systems to identify potentially fraudulent or mule accounts. Institutions must flag suspicious behaviour such as unusual inflows, repeated complaints, or abnormal transaction patterns. Failure to identify and act on such accounts could make a bank fully liable for resulting losses. This effectively ends the era of minimal onboarding checks and places greater emphasis on continuous monitoring.
The combined effect of these policies is likely to make 2026 an edgy and expensive year for the financial sector. Removing deposit fees may encourage agents to collect more cash, but strict withdrawal caps and penalties could make it difficult to restock cash for customer withdrawals without incurring costs. This may discourage cash-out services and keep money circulating digitally, aligning with the CBN’s objectives but posing challenges for cash-dependent segments of the economy. There is also the risk that agents revert to informal cash storage practices, undermining transaction volumes and agent liquidity.
These changes arrive at a time when Nigerian banks are under pressure to meet recapitalisation requirements ahead of the 2026 deadline. By limiting withdrawals and monetising excess cash transactions, the CBN strengthens liquidity ratios and supports bank balance sheets. However, in a system where public trust is still fragile, such measures risk being interpreted as signals of underlying stress rather than stability.
For fintechs built on low-fee, high-volume models, the profitability impact could be significant. Potential reimbursement of fraud losses, combined with shared liability in no-fault cases, introduces an unpredictable cost line. To manage this risk, fintechs are likely to reintroduce friction through longer onboarding processes, cooling-off periods for new beneficiaries, and more aggressive transaction monitoring.
Ultimately, the CBN’s new rules underscore a clear shift in priorities: retaining cash within the formal system, reducing fraud, and stabilising banks as recapitalisation pressures mount. While the regulator believes stricter controls will produce a safer and more resilient financial system, the critical question heading into 2026 is whether the industry can absorb the rising cost of compliance without stifling the innovation and financial inclusion that defined Nigeria’s fintech boom.
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