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Arm’s Length Policy of Payment Service Banks in Nigeria: The need for Clarity

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Emmanuel Okoegwale

In furtherance to enhance access to basic financial services for underserved  and unbanked segments of the society, the Central Bank of Nigeria created a new license category, called the Payment services Bank(PSB).

The key objective of setting up the PSB category, is to enhance financial inclusion by increasing access to deposit products, payment and remittance services to small businesses, low-income households and other financially excluded entities.

To achieve the purpose, PSBs are expected to leverage mobile and digital channels of mobile network operators which will be provided on commercial market rates, to licensed providers irrespective of relationship as a subsidiary, partner or competitor.

Diverse promoters are eligible to promote a PSB such as mobile network operators through their subsidiary, Banking agents, Retail chains, mobile money operators and many other entities that the regulator may deemed meritous of the license.

Relationship between the Mobile network operators, subsidiary and market operators

In order not to give extra advantage, appropriate risk  and prevent commingling, where the PSB is affiliated to a mobile network operator, they are not permitted to include any word that links it, to its parent company.

A parent company or any other related entity of a PSB, which renders services to its PSB shall extend similar services to other entities that so desire on the same terms and conditions therefore on arm’s length basis without preferential treatment to its subsidiary, not offering lower quality of service to subsidiary’s competitors or offering differential pricing etc.

Scope of the Arm’s length

The framework is upfront with access channels and infrastructure’s use and pricing but vague in other areas such as agent and distribution networks which is a compelling component for the design and delivery of basic financial services products.

To avoid the pitfall of current mobile money sector where interoperability is mandated by regulation but market operators shy away from its implementation therefore denying the entire ecosystem, a key driver for growth since wallet holders of diverse mobilemoney operators cant transact with agents outside their network, seamlessly in some cases.

The uncertainty

Without a clear definition, market operators can make poor judgement where they are unsure of what they can access or not access such as subscribers database, CRM, Agency and distribution network etc of the mobile network operators.

To improve operational effectiveness and  resource allotment, organizations need to create certainty and appropriate risk but where arm’s length is not properly defined, market operators  thread with extreme caution to avoid regulatory landmines which can stifle innovation, increase cost, delay product developments  which ultimately  impacts negatively on the market robustness to meet the compelling needs of the underserved population and the nation, missing the financial inclusion targets.

There is need for clarity at inception, what services are classified under the arm’s length for the benefit of potential entrants that might be constrained  by such policies while planning to apply for license or business implementation, post licensing.

Conclusion

A PSB is a combination of a Bank, mobilemoney, remittance and payment provider  without the ability to give credit which is  a major revenue driver, in low value and high volume business financial segment.

With such restriction which reduces the  scope for sufficient earning already hence the need to reduce cost by leveraging as much resources from the mobile network operator’s assets by their subsidiary and other market operators.

From a mobile network operator’s point of view, financial services can be  leveraged as a cost saving platform to reduce churn, lock-in customers which in turn will reduce marketing cost and cost of acquiring new subscribers which will lead to overall  reduction in operating cost. It can also be for income generation, in addition to existing primary products.

A very restrictive arm’s length policy will have negative impact on service delivery and impair the ability of the licensees to leverage some assets, goodwill of either party to deliver financial services that meets the compelling needs of the underserved.

Emmanuel Okoegwale can be reached on [email protected]


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E-Financial

BVN Enrollment Up 6.87 Percent to 67.84m in 2025 – NIBSS

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Bank Verification Number (BVN) enrollments in the country rose by 6.87 per cent , or 4.36 million, to 67.84 million as at the end of December 2025 from 63.48 million in the corresponding period of the preceding year, according to latest data released by the Nigeria Interbank Settlement System (NIBSS).

BVN Enrollment Up 6.87 Percent to 67.84m in 2025 - NIBSS

This means that a total number of 4.36 million BVN enrolments were recorded between the end of December 2024 and the end of last year.

The BVN scheme was launched on February 14, 2014 by the Central Bank of Nigeria (CBN) in collaboration with the Bankers’ Committee, NIBSS and the German firm, Dermalog, with the aim of capturing biometrics of all bank customers and giving each bank customer a unique 11-digit identity number (BVN) that can be verified across the Nigerian banking industry.

Lamido Sanusi, governor of the CBN, at the time, said at the event that the BVN scheme would enable the apex bank to significantly reduce incidents of fraud and money laundering in the banking industry and also help accelerate financial inclusion by opening up opportunities for credit to millions of Nigerians who do not have a standard means of identification.

In October 2017, the CBN released a regulatory framework for BVN operations and Watchlist for the financial system. It stated that the Watchlist comprises a database of bank customers identified by their BVNs, who have been involved in confirmed fraudulent activities in the Nigerian banking industry.

An analysis of the latest NIBSS data shows that BVN enrollment maintained an upward trend in the last five years, rising from 51.90 million in 2021 to 56.90 million and 60.12 million in 2022 and 2023 respectively, before hitting 63.48 million in 2024 and 67.84 in 2025.

Analysts attribute the rise in BVN enrolments in recent years to policy measures introduced by the CBN as part of its efforts to tackle fraud.

For instance, on December 1, 2023, the apex bank issued a circular directing Deposit money banks (DMBs) Non-interest banks, Payment Service Banks, other financial institutions and mobile operators, to ensure that all funded bank accounts or wallets, without BVN or National Identification Number (NIN) are placed on “Post No Debit or Credit,” by April 1, 2024.


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Fidelity Bank Completes N500Bn Capital Raise ahead of Deadline

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Fidelity Bank Plc said it has raised the required minimum share capital for lenders with international authorisation, boosting its capital base as Nigerian lenders race to comply with tougher regulatory requirements scheduled to end by March 2026.

Fidelity Bank Completes N500Bn Capital Raise ahead of Deadline

Nneka Onyeali-Ikpe, GMD, Fidelity Bank

The push-up in its eligible capital, raised through a private placement, effectively placed Fidelity Bank among lenders that have successfully scaled through the regulatory mandate.

The Lagos-based bank, in a disclosure on the Nigerian Exchange on Tuesday, said the offer, which opened and closed on December 31, 2025, was approved by the Central Bank of Nigeria and the Securities and Exchange Commission. Proceeds from the transaction lift Fidelity’s eligible capital to about N564.5 billion from N305.5 billion, subject to final regulatory approvals.

The private placement was carried out under a mandate granted by shareholders at an extraordinary general meeting on February 6, 2025, authorising the bank to issue up to 20 billion ordinary shares.

Fidelity did not disclose the pricing or investor mix for the transaction.

The fundraising caps an aggressive capital-raising drive by Fidelity over the past two years. In 2024, the lender raised N175.85 billion through a public offer and rights issue, which brought its eligible capital to N305.5 billion. That left a shortfall of about N194.5 billion relative to the new minimum capital threshold.

Nigeria’s central bank in 2024 announced a sweeping recapitalisation programme aimed at strengthening the banking system, raising the minimum capital for commercial banks with international authorisation to N500 billion.

The apex bank mandated an increment in capital for national banks, pushing it to N200 billion and N50 billion for regional banks. The 24‑month compliance window ends on March 31, 2026, a regulation that’s triggering a wave of equity issuances, merger talks, and balance-sheet restructuring across the sector.

Fidelity’s latest capital raise places it above the regulatory floor, potentially easing pressure on the bank as peers continue to tap markets. The additional capital is also expected to support balance-sheet expansion, larger ticket lending, and resilience against macroeconomic shocks in Africa’s fourth-largest economy, which has been grappling with currency volatility, double-digit inflation, and elevated interest rates.

Analysts stated the scale and speed of this transaction validate Fidelity Bank’s standing among tier‑one lenders. Recently, Fitch Ratings affirmed the bank’s Long‑Term Issuer Default Rating at ‘B’ and upgraded its National Long‑Term Rating to ‘A+(nga)’, citing stronger capital buffers and improved profitability.

Fitch also recognised the bank’s expanding franchise, sound fundamentals, and healthy foreign‑currency liquidity, noting it was Nigeria’s sixth‑largest lender by assets at the end of 2024.


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Kuda Microfinance Bank Releases ‘My Year on Kuda’ 2025 Financial Recap

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Kuda Microfinance Bank has unveiled the 2025 edition of “My Year on Kuda,” its annual recap providing customers with personalised insights into their spending, saving, and money management habits from the previous year.

Kuda Microfinance Bank Releases 'My Year on Kuda' 2025 Financial Recap

Kuda Microfinance Bank

The tool analyses transaction data across categories like transfers, card payments, online purchases, and bills, revealing patterns such as highest-spending months, biggest payments, saving frequency, and savings from Kuda’s 25 free monthly transfers. Customers can compare 2025 activity against 2024, including income versus expenditure.

In an era of inflation and economic uncertainty, the recap promotes financial literacy by highlighting responsible borrowing via Kuda Overdraft usage, including access frequency, amounts borrowed, and repayment patterns.

Customer-shared screenshots on X reflect national trends: Nigeria recorded over 2.2 billion electronic transactions worth ₦285 trillion in Q1 2025, up 20 percent year-on-year, with POS terminals driving the shift to cashless commerce.

Kuda Group CEO Babs Ogundeyi, in the recap’s opening video, urged users: “Before you carry on with January, this is the perfect time to see everything you did with your money on Kuda last year and learn something.”

The feature underscores Kuda’s focus on actionable insights to help Nigerians navigate evolving personal finance amid shifting earning and spending behaviours.


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