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8 April 2026

Highlights Of The Guidelines Letters Circulars And Notifications Issued In March 2026

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Advocaat Law Practice

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The Securities and Exchange Commission (‘SEC’), Nigerian Communications Commission (‘NCC’), the National Pension Commission (‘PenCom’), the Nigeria Revenue Service...
Nigeria Finance and Banking
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Dear Esteemed Client,

The Securities and Exchange Commission (‘SEC’), Nigerian Communications Commission (‘NCC’), the National Pension Commission (‘PenCom’), the Nigeria Revenue Service (‘NRS’), Lagos State Internal Revenue Service (‘LIRS’), the Financial Reporting Council of Nigeria (‘FRCN’), the Central Bank of Nigeria (‘CBN’), the Nigerian Exchange Group (‘NGX’), the Nigeria Data Protection Commission (‘NDPC’), the Federal Competition and Consumer Protection Commission (‘FCCPC’), National Agency for Food and Drug Administration and Control (‘NAFDAC’) and the Federal Government of Nigeria (‘FGN’) issued a series of Press Releases, Circulars, Directives, and Guidelines in March 2026 containing information and directives for various sectors and the general public. We hope that you find the information useful in your operations.

NDPC COLLABORTAES WITH SIXTY DATA AUTHORITIES TO TACKLE PRIVACY RISKS IN AI-GENERATED IMAGES.

On 3rd March 2026, the NDPC, joined over sixty Data Protection Authorities (‘DPAs’), in endorsing the “Joint Statement on AI-generated Imagery and the Protection of Privacy”, a document coordinated by the International Enforcement Cooperation Working Group of the Global Privacy Assembly. The Joint Statement highlights growing global concern about the risks posed by artificial intelligence tools capable of generating highly realistic images and videos of identifiable individuals. Regulators warn that such tools are increasingly being misused to create non-consensual imagery, defamatory content, and other harmful materials, thereby posing significant risks to individuals and society.

In response, organisations are urged to implement appropriate safeguards before deploying Artificial Intelligence (‘AI’) systems, ensure transparency in how these tools operate, establish accessible and effective content removal mechanisms, and comply with applicable data protection laws. The NDPC also indicated that compliance audit returns under the Nigeria Data Protection Act will be used to assess how major data controllers and processors utilise AI in their operations. According to the NDPC, this audit process will serve as a benchmark for monitoring responsible data processing practices, particularly where AI technologies are involved.

For more information, please refer here

PENCOM ISSUES CIRCULAR ON FEES FOR FUND V, FUND VII AND ACCREDITED PENSION AGENTS

On 5th March 2026, the PenCom issued a circular approving the asset-based fees chargeable on the Foreign Currency Pension Contributions (Fund VII), Personal Pension Plan (Fund V), and a compensation framework for Accredited Pension Agents (‘APAs’).

The Circular prescribes a total fee cap of 1.70% for Fund VII and 3.00% for Fund V, alongside provisions on applicable conditions and safeguards for contributors’ funds. It also establishes a structured compensation regime for APAs, including onboarding fees, transaction charges and performance bonus, aimed at enhancing transparency and efficiency within the pension system. The framework will be subject to periodic review based on market conditions, service performance and strategic objectives of the Personal Pension Plan Fund. The circular takes immediate effect.

For more information, please refer here

LIRS EXTENDS DEADLINE FOR FILING OF INDIVIDUAL ANNUAL INCOME TAX RETURNS TO 14TH APRIL 2026

The LIRS has extended the deadline for filing individual annual income tax returns from 31st March 2026 to 14th April 2026, providing taxpayers with additional time to ensure accurate submissions. LIRS stated that the statutory deadline remains 31st March, however, the extension is aimed at improving compliance and encouraging timely filing as a routine obligation.

LIRS reiterated that all filings must be completed electronically via its eTax platform, https://etax.lirs.net/ as manual submissions have been fully discontinued.

For more information, please refer here

NAICOM AND BPP SIGN A MEMORANDUM OF UNDERSTANDING TO STRENGTHEN INSURANCE COMPLIANCE IN PUBLIC PROCUREMENT

On 10th March 2026, the NAICOM and the Bureau of Public Procurement (‘BPP’) signed a Memorandum of Understanding (‘MoU’) to enhance the enforcement of insurance requirements within Nigeria’s public procurement framework. The collaboration is aimed at ensuring that all insurance obligations associated with government contracts are duly complied with in accordance with applicable laws and regulatory standards.

The MoU establishes a framework for inter-agency cooperation in areas including data sharing, compliance monitoring, and enforcement, with a view to addressing longstanding gaps in the implementation of compulsory insurance policies in the public sector. The initiative is expected to strengthen risk management in public projects, improve regulatory oversight, and support the growth and penetration of the insurance sector through increased compliance by contractors and procuring entities.

For more information, please refer here

CBN ISSUES BASELINE STANDARDS FOR AUTOMATED ANTI-MONEY LAUNDERING SOLUTION FOR FINANCIAL INSTITUTIONS IN NIGERIA

On 10th March 2026 the CBN issued Baseline Standards for Automated Anti Money Laundering (‘AML’), Combating the Financing of Terrorism (‘CFT’), and Countering Proliferation Financing (‘CPF’) solutions for financial institutions. The framework is aimed at strengthening real-time detection and reporting of suspicious transactions, enhancing regulatory compliance, and promoting the adoption of emerging technologies in financial crime risk management.

compliance required within 18 months for Deposit Money Banks and 24 months for Other Financial Institutions. All institutions are required to submit implementation roadmaps to CBN’s Compliance Department within three months of issuance of the Baseline Standards. The CBN emphasised that all stakeholders must ensure strict adherence to the standards, noting that it will continue to monitor developments and provide further regulatory guidance where necessary

For more information, please refer here

CBN ISSUES ADDENDUM TO BVN REGULATORY FRAMEWORK AND WATCHLIST REGIME

On 12th March 2026, the CBN issued a circular introducing amendments to the Revised Regulatory Framework for Bank Verification Number (‘BVN’) operations and the watchlist regime in the Nigerian banking industry. Notably, the amendments introduce a temporary watchlist, requiring financial institutions to flag BVNs linked to suspected fraudulent transactions for up to 24 hours, during which affected individuals must be contacted for clarification.

The circular further provides that access to BVN databases is restricted to CBN-licensed financial institutions, subject to the CBN’s discretion to grant access in extenuating circumstances in line with applicable laws. The CBN also restricts BVN enrolment to individuals aged 18 years and above, and permits only one amendment to phone numbers linked to a BVN.

The addendum takes effect from 1st May 2026, and all financial institutions are required to comply accordingly.

For more information, please refer here

CBN ISSUES CIRCULAR ON ADDITIONAL FUNCTIONALITIES FOR INSTANT PAYMENTS

On 12th March 2026, the CBN issued a circular introducing additional functionalities requirements for Instant Payments (IP) services across banks, other financial institutions and payment service providers. The measures are aimed at strengthening customer control, authentication, and fraud prevention. Financial institutions are now required to provide customers with voluntary opt-in/opt-out functionality for instant payments, with opt-out disabling online transfers while allowing in-branch transactions. Customers must also be able to adjust and set their transaction limits (within existing regulatory thresholds), and any adjustments made will be subject to enhanced due diligence and appropriate risk assessment by the financial institution. The new transaction limit will take effect upon successful completion of multi-factor authentication.

To enhance fraud risk management, institutions must implement enterprise-wide fraud monitoring systems covering both inflows and outflows, and deploy stronger authentication controls, including liveliness checks for online account opening and reactivation, with real-time validation against BVN/NIN databases.

Additional requirements apply to mobile financial services, including mandatory device binding (one device per app session), re-authentication when migrating devices, and transaction limits of up to NGN 20,000 within the first 24 hours of activating mobile apps for both new and existing accounts. First t ime logins on new devices for internet banking must also be subject to enhanced multi-factor authentication. The CBN emphasised that these measures represent baseline standards to improve the security, integrity, and resilience of Nigeria’s instant payment ecosystem.

The provisions take effect from 1st July 2026, and all banks, other financial institutions and payment service providers are required to comply accordingly.

For more information, please refer here

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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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