An Analysis Of The Guidelines For Operations Of Agent Banking In Nigeria

1.0. INTRODUCTION

On 6th October 2025, the Central Bank of Nigeria (CBN) issued the Guidelines for the Operations of Agent Banking in Nigeria ("the Guidelines"), set to take effect from 1st April 2026. This marks a major step in strengthening Nigeria's financial inclusion framework and updating the rules that govern how financial services reach the unbanked population.

Agent banking simply refers to the delivery of financial services by a third party to customers on behalf of a licensed deposit-taking financial institution.³ It allows banks and other financial institutions to extend their services to people in rural or underserved areas without having to set up physical branches.

The CBN first introduced agent banking regulations in 2013, and followed up with a framework for licensing super agents in 2015. Over the years, these initiatives have expanded access to financial services and encouraged digital finance adoption. However, with rapid technological advancements and the evolving financial sector, the earlier frameworks became outdated and it became necessary for the CBN to update the existing regulatory framework.

In line with its mandate under the CBN Act and the Banks and Other Financial Institutions Act (BOFIA) to promote a sound, safe, and stable financial system, the CBN developed the new Guidelines, which supersede all other CBN Guidelines on agent banking and agent banking relationship.' Further, it represents the most comprehensive regulatory overhaul since the introduction of agent banking in 2013.⁵

The new Guidelines aim to set minimum standards for agent banking operations, strengthen consumer protection, promote responsible market conduct, and enhance the efficiency of financial service delivery. They apply to all financial institutions licensed by the CBN to carry out agent banking and identify the participants in the ecosystem: the Principal (licensed financial institution); (ii) the Super-Agent (a company licensed to recruit, aggregate and manage agents)⁷; and the Agent (an individual or organization providing approved financial services) etc.

This paper analyses the key provisions of the Guidelines and their implications for financial institutions and agents.

ANALYSIS OF KEY PROVISIONS OF THE GUIDELINES

1.Mode and Conditions for Appointment of Agents⁸

Under the Guidelines, agents may be appointed either directly or indirectly. A direct appointment occurs when a licensed financial institution, referred to as the Principal, engages the agent itself. An indirect appointment, on the other hand, takes place when a Super-Agent duly licensed by the Central Bank of Nigeria ("CBN") appoints agents on behalf of the Principal. The Guidelines place no limit on the number of agents a Principal may appoint, provided that all appointments meet the regulatory requirements and the prescribed due diligence processes of the CBN.

Before anyone can act as an agent, certain eligibility conditions must be satisfied. An individual agent must be at least 18 years old and of sound mind, while a non-individual agent must demonstrate the capacity to perform the permitted activities and provide all mandatory information required under Section 8 of the Guidelines. Such information includes:

a. Name and particulars of the proposed agent;

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b. Certificate of incorporation or business name registration with the Corporate Affairs Commission (CAC);

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c. Physical address of the agent's location;

d. Evidence of funds available for agent operations;

e. Tax clearance certificate for the past three years; and

f. Particulars and BVN of directors (for non-individual agents), as well as disclosure of any prior agent banking relationships.

The Guidelines also specify persons who are disqualified from acting as agents. These include individuals with non-performing loans in any financial institution, persons declared bankrupt, those convicted of offences involving fraud, dishonesty, or felony, and anyone whose BVN is blacklisted or listed on a watchlist.⁹

2.Classification and Responsibilities of Agents

The Guidelines divided agents into two categories that is individual and non -individual agent. An individual agent refers to a person who is contracted by a principal to perform permissible agent banking activities. A non-individual agent, on the other hand, is an incorporated entity or business enterprise that engages in commercial activities and has been appointed to provide agent banking services on behalf of a Principal.¹⁰

Agents, regardless of their classification, have key responsibilities under the Guidelines and are required to safeguard all data and information obtained in the course of their operations and to submit such information promptly to the Principal at agreed intervals. Agents must also ensure the safety and proper use of platforms or devices provided by the Principal, maintain accurate records of all transactions, and uphold strict confidentiality and data privacy standards. These obligations are designed to promote trust, security, and accountability in the agent banking system.¹¹

3.Classification of Agent Banking Relationship

The Guidelines define an agent banking relationship as a formal arrangement between a Principal and an Agent, established through a duly executed agent banking agreement, under which the Agent is authorized to provide specified banking services on behalf of the Principal.¹² The Guidelines further outline the structure and conditions governing such relationships. Notably, each Agent is required to maintain an exclusive relationship with only one Principal and one Super-Agent at any given time. This means an Agent cannot simultaneously serve multiple Principals or Super-Agents.

However, a Super-Agent may be contracted by more than one Principal. In such cases, the Super-Agent must execute a separate agency agreement with each Principal to clearly define the scope of engagement and responsibilities.¹³

Additionally, before entering any agent banking relationship, every Principal or Super-Agent must obtain the approval of its Board of Directors. This ensures proper governance oversight and compliance with the regulatory framework set out by the Central Bank of Nigeria (CBN).¹⁴

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