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HOW TO SET UP A FINTECH PAYMENT COMPANY IN NIGERIA

The data on fintech payment released by the Nigeria Inter-Bank Settlement Systems (“NIBSS”) has revealed that payment transactions worth N33.2 trillion were performed electronically in August through the NIBSS Instant Payment platform (NIP). This brings the total value of e-payment deals in the last 8 months to N238.7 trillion!

This surge in electronic transactions shows a steady increase in e-payments in the country and a proof that more Nigerians are embracing cashless policy as more innovations are welcome to the payment ecosystem.

The above record is a clear indicator for a huge potential for more technological innovations and business investment in the country’s payment sub-sector. More payment fintechs are needed to drive more financial inclusion in Nigeria!

The regulatory framework for the e-payment sub-sector in Nigeria is still at a developing stage. Currently, there are about six (6) categories of payment company licences that are grantable in Nigeria, namely:

1. Super-Agent Licence permits its holders to undertake agency banking. Agency banking is a financial service rendered 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 a formal banking system SEE BELOW:

2. Payment Solution Services Provider (“PSSP”) Licence permits holder to engage in payment processing gateway and portals, payment solution/application development, merchant services aggregation and collections. SEE BELOW:

3. Payment Terminal Service Provider (PTSP) Licence for PoS Terminal deployment and services, PoS terminal ownership, PTAD, Merchant/agent training and support.

4. Switching and Processing Licence for Switching, Card Processing, Transaction clearing and Settlement Agents Services, non-bank acquiring services and other activities permissible under Super Agents, PTSP and PSSP licences.

5. Mobile Money Operation Licence for e-money issuing, e-wallet creation and management, pool account management and other activities permissible under Super Agent licence. SEE BELOW:

6. Payment Service Bank licence is a deposit-taking licensed fintech bank that primarily focuses on the rural areas and unbanked locations, targeting financially excluded persons providing the following services:

i.   Acceptance of deposits from individuals and small businesses, which shall be covered by the deposit insurance scheme;

ii. Carry out payments and remittances (including inbound cross-border personal remittances) services through various channels within Nigeria;

iii. Sale of foreign currencies realized from inbound cross-border personal remittances to authorized foreign exchange dealers;

iv. Without prejudice to (i) and (ii) above, a Payment Service Bank must comply with provisions of the extant Foreign Exchange Regulations of the Central Bank of Nigeria;

v. Issuance of debit and pre-paid cards on its name and Enter into direct partnership with card scheme operators. Please note that such cards shall not be eligible for foreign currency transactions;

vi. Operate electronic wallet services for its customers;

vii. Deploy Automated Teller Machines (ATMs) in some rural areas;

viii. Deploy Point of Sale (PoS) devices;

ix. Be at liberty to operate through banking agents (in line with the CBN’s Guidelines for the Regulation of Agent Banking and Agent Banking Relationships in Nigeria);

x. Roll out agent networks with the prior approval of the CBN;

xi. Use other channels including electronic platforms to reach-out to its customers;

xii. Establish coordinating centres in clusters of outlets to superintend and control the activities of the various financial service touch points and banking agents;

xiii. Render financial advisory services;

xiv. Invest in Federal Government of Nigeria and Central Bank of Nigeria securities; and

xv. Carry out such other activities as may be prescribed by the Central Bank of Nigeria from time to time. (See https://koriatlaw.com/how-to-set-up-a-payment-service-bank-in-nigeria/). SEE BELOW:

7. Regulatory Sandbox Licence granted on a case by case basis (after CBN’s review of the products and services of a proposed fintech business) to drive any fintech innovation that is not suitable under any of the existing licensing categories. (See https://koriatlaw.com/how-to-obtain-regulatory-sandbox-approval-in-nigeria/).


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