{"id":5269,"date":"2022-07-17T12:05:47","date_gmt":"2022-07-17T12:05:47","guid":{"rendered":"https:\/\/koriatlaw.com\/?p=5269"},"modified":"2022-07-17T12:05:47","modified_gmt":"2022-07-17T12:05:47","slug":"agency-banking-licence-requirements-costs-timeline-for-processing","status":"publish","type":"post","link":"https:\/\/koriatlaw.com\/2026\/2022\/07\/17\/agency-banking-licence-requirements-costs-timeline-for-processing\/","title":{"rendered":"AGENCY BANKING LICENCE: REQUIREMENTS, COSTS & TIMELINE FOR PROCESSING"},"content":{"rendered":"\n
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1.\nWhat is a Super-Agent Company?<\/em><\/strong><\/p>\n\n\n\n

Super-Agents are Fintech companies with the lowest capital requirement threshold (being N50 Million) in the payment ecosystem in Nigeria. A super-agent company is a business incorporated in Nigeria and licensed by the Central Bank of Nigeria (\u201cCBN\u201d) to undertake agency banking. Agency banking is a type of financial service on behalf of banks to unbanked communities or population in order to increase financial inclusion to those who would have been otherwise unable to benefit such financial services under formal banking system.<\/p>\n\n\n\n

A Super-Agent company is required to be registered with the Corporate Affairs Commission (\u201cCAC\u201d), however, such registration cannot be completed unless with the approval of the CBN and subject to deposit of N50 Million in an escrow account with the CBN and submission of several other documentary requirements. <\/p>\n\n\n\n

2. What is the difference between Super-Agent Licence and other Fintech Licences?<\/em><\/strong><\/p>\n\n\n\n

Super-Agent licence is a type of Fintech licence that is different from the Payment Solution Service Providers (PSSP) licence, the Payment Terminal Service Provider (\u201cPTSP\u201d) licence and the Mobile Mobile Money Operator (MMO) licence in terms of the scope of financial services which it affords its holder to render. All the foregoing Fintech licences are granted by the CBN subject to different share capital and other requirements.<\/p>\n\n\n\n

Please note that a company may hold any of PSSP, PTSP and Super Agents license or a combination of all the licenses (except the MMO Licence). However, companies seeking to combine activities under the switching and MMO categories may be permitted by the CBN if such company seeks to do so under a holding company structure with the subsidiary entities (separately holding switching licence and MMO licence respectively) clearly delineated to prevent commingling.<\/p>\n\n\n\n

MMO licence allows its holder to operate a wide spectrum of mobile money services beyond the activities that are permissible for Super Agent licencee. Such other services include issuing e-money, creating and management of e-wallet, pool account creation and wallet management services, etc. Please note that only MMO licencees are permitted to hold customer funds. Companies with other payments system licences are not permitted to hold customer funds. You can read more about MMO Licence here.<\/a><\/p>\n\n\n\n

The PSSP license falls under the Payment Solution Services (\u201cPSSs\u201d), which permits holder to engage in payment processing gateway and portals, payment solution\/application development, merchant services aggregation and collections. A PSSP cannot take deposits or savings of customers’ funds. You can read more about Payment Solution Service Providers (PSSP) Licence here.<\/a><\/p>\n\n\n\n

The PTSP license permits Pont of Sale (\u201cPoS\u201d) Terminal deployment and services, PoS Terminal ownership, PTAD, Merchant\/agent training and support. <\/p>\n\n\n\n

The Super Agent license allows holders to undertake agent recruitment, training and other activities as specified in the Regulatory Framework for Licensing Super Agents in Nigeria. Super-Agents cannot hold customer funds, cannot take deposits and cannot render wallet services.<\/p>\n\n\n\n

Below are the lists of permissible and Non-permissible activities of a super agent company:<\/p>\n\n\n\n

Permissible<\/strong> Activities<\/strong><\/p>\n\n\n\n

\u2013 Doing business without CBN licence.<\/p>\n\n\n\n

\u2013 Acceptance of Monetary deposits and withdrawals from customers.<\/p>\n\n\n\n

\u2013 Processing of Utility Bills payment.<\/p>\n\n\n\n

\u2013 Processing of Salary payment.<\/p>\n\n\n\n

\u2013 Processing Local money value transfer.<\/p>\n\n\n\n

\u2013 Processing of Balance Enquiries.<\/p>\n\n\n\n

\u2013 Mini-statement generation & issuance services.<\/p>\n\n\n\n

\u2013 Collection and submission of account opening & other related documentations.<\/p>\n\n\n\n

\u2013 Agent Mobile payments \/ Banking services.<\/p>\n\n\n\n

\u2013 Cash disbursement & Cash repayment of loans<\/p>\n\n\n\n

\u2013 Collection of Bank mail\/Correspondence for customers.<\/p>\n\n\n\n

\u2013 Any other activity as the Central Bank of Nigeria may from time to time prescribe.<\/p>\n\n\n\n

Non-Permissible<\/strong> Activities<\/strong><\/p>\n\n\n\n

\u2013 Charging the customer any fee.<\/p>\n\n\n\n

\u2013 Provision of any guarantees.<\/p>\n\n\n\n

\u2013 Carrying out transactions without a generated receipt or acknowledgement.<\/p>\n\n\n\n

\u2013 Offering Banking services of its own accord without affiliation to any licensed bank as its principal.<\/p>\n\n\n\n

\u2013 Carrying out a transaction when there\u2019s communication failure with the Financial Institution ( The Principal).<\/p>\n\n\n\n

\u2013 Continuing with the agency business when it has a proven criminal record involving fraud, dishonesty, integrity or any Financial impropriety.<\/p>\n\n\n\n

\u2013 Providing banking services not specifically mentioned in its Agency Banking contract.<\/p>\n\n\n\n

\u2013 Undertaking or processing cheque deposits & encashment of cheques.<\/p>\n\n\n\n

\u2013 Providing cash advances.<\/p>\n\n\n\n

\u2013 Being run or managed by a Financial Institution\u2019s employee or associate.<\/p>\n\n\n\n

\u2013 Transacting in Foreign currency.<\/p>\n\n\n\n

\u2013 Subcontracting another agent to operate on its behalf without being a licensed Super Agent.<\/p>\n\n\n\n

3. What is the procedure for licensing a Super-Agent Company in Nigeria?<\/em><\/strong><\/p>\n\n\n\n

Existing Company:<\/span> <\/em><\/strong>Usually, the procedure to adopt will depend on if the applicant company has been fully registered or seeking to be newly registered with CAC. For an existing company, there is a number of house-keeping issues to tidy up (depending on the state of the company, the nature of its business and amount of its share capital):<\/p>\n\n\n\n

i. It may be necessary to first file an application to CAC to increase the share capital to N50 Million if the amount of its share capital is less than N50 Million;<\/p>\n\n\n\n

ii. It may also be important to amend the Memorandum and Articles of Association (“MEMART”) of the existing company to reflect only permissible business activities relating to agency banking (the Draft Amended MEMART is acceptable for Super Agent Application purposes);<\/p>\n\n\n\n

iii. It may also be necessary to appoint new directors on the board, where the number of directors is less than five (5) and file the application for the new appointments with the CAC together with all the necessary resolution and other post incorporation filings at the CAC. <\/p>\n\n\n\n

The above and other Super Agent requirements are necessary before submission of Application for Super Agent licence to the CBN.<\/p>\n\n\n\n

New Company<\/strong><\/span><\/em>: <\/strong>The process for a new company begins with the reservation of the proposed name with the CAC and thereafter the application for Approval In Principle (\u201cAIP\u201d) to CBN is processed in the reserved name subject to payment of application fee and shareholders\u2019 fund as well as presentation of documentary requirements. An AIP has a lifespan of 6 months, though may be extended by the CBN.<\/p>\n\n\n\n

Upon\nthe grant of the AIP, the promoters are required to return to the CAC to\ncomplete the registration of the Super-Agent company (within 6 months of the\ngrant of the AIP) following which the CAC will issue a certificate of\nincorporation, a memorandum and articles of association and a status report of\napplication for registration showing details of the company including share\ncapital, registered address, directors, shareholders, company secretary and\nother relevant information of the company.<\/p>\n\n\n\n

Upon\ncompletion of the company\u2019s incorporation, the company is required to apply to\nthe CBN and make payment of the licensing fee before the Final Licence issued. The\noperating licence of a super-agent is renewable every two (2) years, subject to\nsatisfactory performance of the licensed company.<\/p>\n\n\n\n

You can read more about Payment Solution Service Providers (PSSP) Licence here.<\/a><\/p>\n\n\n\n

4. What are the documentary requirements for Super-Agent licence in Nigeria?<\/em><\/strong><\/p>\n\n\n\n

Application for super-agent licence must be\naddressed to the Director, Payments System Management Department (\u201cPSMD\u201d), CBN\nand accompanied by evidence of payment of Application Fee and other documentary\nrequirements. The other documentary requirements for AIP are as follows:<\/p>\n\n\n\n