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Mobile Money Agency Propositions & Operations in Nigeria

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Emmanuel  Okoegwale, Mobile Money Africa
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As mobile financial services industry in Nigeria takes shape with limited agency network to serve as touch points to meet the needs of the subscribers, we will examine the value adding roles of the agents in the emerging mobile financial ecosystem in Nigeria.

Mobile Money is the use of mobile devices as a means of authentication to access basic financial services. Currently about 16 providers are licensed by the Central Bank of Nigeria.

An agent is an intermediary that represents the provider that could be a Bank or a non Bank to offer the service to the last mile, the subscribers.

They are very critical to the success of the mobile money scheme because they serve as the touch points for cash in, cash out, bill processes and other services that the subscribers will want to conduct without the need for a physical visit to a Bank Branch which are limited by spread and mostly concentrated in urban areas.

Mobile Money successes depend greatly on the availability of these service points as we have seen with MPESA in Kenya and G-cash in Philippines.
 
Simple Products/ Simple Service
First time agents are always curious about the Banks taking their services outside the secure branch network and place their trust in them as agents to serve their communities through the use of mobile phones, POS and other devices for financial services.

While the agents are willing most times, ability to understand the service is important to signing up and long-term relationships.

In many Instances, store owners that are already positioned and actively selling similar low value / high volume products, will turn down an opportunity to become an agent due to poor product knowledge from the agent recruiter, inadequate marketing information or in some instances, absence of agent marketing materials.

It is crucial for the recruiter to be properly trained while resisting the lame attempt to push down commission earnable as the only value proposition to potential agents.

 Understanding the primary business of the agent will help to unlock the best approach as we have seen that many potential agents are actually best fit as merchants and not agents. Resist the attempt to instantly sign up agents. Develop a relationship and you have a deal.
 
 
Avoid Round Robin Visits to Agents
Best practices for agent sign-up, entails first caller visits to explain the products and if progress was made, the requirements are made available for review, observation and comments by potential agents.

There is need to resist round robin and unproductive visits to the agents. Agents have primary businesses and do manage their time to attend to the demands of their businesses.

Where the recruiter keeps checking on a potential agent without new information, marketing materials or updates but rather making passing visits which are of no value, the agents might become disinterested over time.

Every single agent trip must add value in terms of record keeping checking, new features advice, branding placement, capacity building, mentoring and monitoring.
 
Agent Commissions
Potential agent’s main interest in becoming an agent is to earn decent commissions from the transactions.

There are non transactional earnings like registrations and transactional revenues from transactions conducted at agent locations.

Where transaction commissions earnable are vague and unclear, agents are not encouraged to sign up to the scheme.

Transparent and sustainable commissions are the core driver of agency sign-up drive.
Agent payout circle must also be clear, transparent and easy to understand.
 
Know-Your-Agents
Agent requirements are necessary to enable providers know who the agents are, what they do and how they are positioned to add value to the scheme.

It is very important to have clear cut requirements that are commensurate with agent categories and threshold as stipulated by the regulator and practically, implementable.

While it is desirous to have a universal set of requirements for standardization purposes, it is also critical to have non mandatory requirements depending on community size, agent location and peculiarities of targeted market.

Some documentation like Utility bill may be farfetched in some semi rural and rural communities.

After thoughts and additional agency documentation requirements, places additional burden on the agents to seek for these documentation.

Demanding Ambiguous, Conflicting and sometimes unnecessary agency documentation requirements are some of the major barriers of agency sign ups that is currently faced in the industry.
 
Agent ratio
Aggressive agency sign up could be seen as early day’s activities but understanding and measuring the customer to agent ratio is critical to position the network sustainably.

If agents sign ups quickly outstrip the customer coverage per community, demands will be highly fragmented across large numbers of agent which will earn very little for the given numbers of customers.

Signing up agents aggressively should be adequately balanced with plans to place some in reserve or waiting list for possible replacement where are agents dropped for non performance, fraud or non compliance with scheme provider’s provisions.

Agent /customer ratio might be a small projection in the early days but should increase over time as agents build capacity, trust and knowledge, over time.
 
Branding
Selling a mass driven, low value and high volume product, require lots of street visibility.

While above the line marketing via Television, bill boards, event sponsorships and newspaper adverts may have their advantages, agent location branding is extremely useful to promote product, build trust and location visibility.

It is not enough to have agent id, service availability posters at agent locations.

 These are only educational and promotional materials while inside the agent’s outlet.

They do not announce the service to the passerby from a little distance away. For a traffic driven service, how will the customers know agent locations to transact?

Strong color schemes and branding are strongly linked to the successes of selling airtime tops-upsat least in developing world and should also be adopted for such services as mobile money.

Customers should be able to identify agent locations from a distance with a color code that is unique to the brand.

While not all agents will agree to paint their outlets but most will do if they perceive that it will improve traffic to their outlets for purpose of transacting mobile money which may also benefit their primary businesses.
 
Record keeping
Most businesses that will ever sign up to become agents did that because they are willing and they have ability to offer the service.

While willingness is a major factor to watch out for, ability is very important.
Agents might be able to provide all the necessary documentation requirements, fund their e-float account but not literate enough to records transactions or patient enough to update their record even if they are literate.

No matter how useful an agent is, if record keeping is poor, such agents must be re-trained, monitored and might be dropped if He/She, cannot consistently keep records which might be a regulatory requirement or required to manage customer / agent disputes or  for back end reconciliation purposes.
 
Support
An efficient back-end support system is the life blood of an active agency network. In situations where things do not work as planned due to platform, people and process failures, agents should be able to reach out via telephony, email, sms or visit to resolve issues. Back end support will enable the agent build capacity, confidence and trust which are necessary for the uptake of the service and enable them function at optimal level.
 
e-float Management
Exchanging cash for e-money is the most critical aspect of agent functions. Where this is inefficient, re-balancing cost of the agents might increase significantly and it may also impact services which could lead to liquidity challenges and poor performance of agents.

 E-float rebalancing should be efficient, easy and timely. Where agents travel long distances or wait for hours on end after funding their e-wallets account to receive notification of e-float, can be discouraging.

Ability to fund accounts through multiple channels like ATM, online, agent-to-agent, account-to-agents should be available to ensure that agents are able to funds their accounts anytime and anywhere without a physical visit to a Bank branch which can also be used for e-float funding.
 
Set up Demo Centers
Setting up strategic touch points in well traffic environments for potential agents to seek information, demo, support and set – up procedures will improve understanding, interaction and the knowledge of the agents.

These demo centers might be embedded inside Bank premises, gas stations, bus tops and other major interactions points to serve the needs of the agents.

 In the early days, it might be owned by the scheme provider with plans to replicate such structures nationwide and eventually, transfer to third-party agent network providers.
 
Emmanuel  Okoegwale is the principal Associate at MobileMoneyAfrica.He will be a Judge in the mobilemoney category at the Global GSMA event in Barcelona in Feb 2013.


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E-Financial

Wema Bank Upgrades ALAT Banking App

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Wema Bank Plc has launched the upgraded version of its flagship digital banking platform, ALAT by Wema. Designed as the next phase in digital banking, the upgraded version of ALAT delivers a smarter, faster, and more intuitive experience, reinforcing Wema Bank’s leadership in technology-driven financial services.

Tagged ALAT: The Evolution, the upgraded version represents a significant advancement in how customers interact with their bank.

It enables seamless banking through intelligent features such as voice banking (called SAW), which allows customers to carry out banking activities using natural voice commands, reducing friction and improving accessibility.

It also introduces Tap and Pay for quick, secure, and convenient contactless transactions, alongside uptime prediction that enhances transparency, reliability, and confidence around service availability.

Together, these innovations are designed to simplify everyday banking while anticipating customer needs in real time, reinforcing Wema Bank’s commitment to trust, efficiency, and customer-centric digital experiences.

While announcing the upgraded version of the ALAT Banking app, Moruf Oseni, Managing Director and Chief Executive Officer of Wema Bank, said, “ALAT: The Evolution is more than an upgrade. It is a clear demonstration of our commitment to redefining digital banking in Africa.

“By understanding the future of banking and listening closely to our customers, we have upgraded ALAT by Wema to a digital banking platform that is smart, intelligent and dependable. This evolution reinforces our promise to deliver innovation that genuinely enhances how people live, work, and transact everyday.”

He added that migrating to the upgraded app is seamless. “Existing customers can simply visit the Google Play Store or Apple App Store to update their existing ALAT app and sign-in with their existing login details (All their account information and transaction history remain intact on their profile and they will also gain access to new features that make banking faster, more intuitive, and more reliable).

For new customers, all they have to do is visit the Google Play Store or Apple App Store to download ALAT by Wema app and click the Get Started icon to onboard seamlessly.

Speaking on the technology in the upgraded ALAT by Wema, Olusegun Adeniyi, Chief Digital Officer at Wema Bank, explained, “With ALAT: The Evolution, we set out to enhance not just functionality but the overall banking experience.

“By integrating voice banking, contactless payments, and predictive reliability, we are delivering a platform that is built on powerful technology and responds intelligently to customer needs. This upgrade reflects our long-term digital vision to create a digital bank that is adaptive, intuitive, and consistently available.”

Built on speed, intelligence, and user-centric design, ALAT: The Evolution redefines everyday banking through intuitive features such as voice-enabled transactions, contactless payments, and predictive service reliability. Designed to anticipate customer needs in real time, the platform delivers a smarter, more seamless, and dependable digital banking experience that reflects Wema Bank’s vision for the future of finance.

With the upgraded version of ALAT, Wema Bank continues to strengthen its position as a digital-first institution, delivering innovative solutions that empower individuals and businesses to bank with confidence in an increasingly digital economy.


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NDIC Declares Second Liquidation Dividend for Heritage Bank Depositors

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Nigeria Deposit Insurance Corporation (NDIC) has declared a second liquidation dividend of ₦24.3 billion for depositors of Heritage Bank Limited (in liquidation) whose account balances exceeded the statutory insured limit of ₦5 million at the time of the bank’s closure.

NDIC Declares Second Liquidation Dividend for Heritage Bank Depositors

Heritage Bank’s operating licence was revoked by the Central Bank of Nigeria (CBN) on June 3, 2024, after which the NDIC was appointed liquidator in line with the Banks and Other Financial Institutions Act (BOFIA) 2020 and the NDIC Act 2023.

In a statement signed by Hawwau Gambo, head of the Communication and Public Affairs Department,  the Corporation said the second liquidation dividend would be paid at a rate of 5.2 kobo per ₦1.00 on outstanding uninsured balances. This brings the total liquidation dividend paid so far to 14.4 kobo per ₦1.00.

“The NDIC has now declared a second liquidation dividend of ₦24.3 billion. This amount, derived from debt recovery, sale of physical assets, and realisation of investments, will be applied to the payment of uninsured balances for depositors with funds exceeding the ₦5 million insured limit. The second liquidation dividend is payable at a rate of 5.2 kobo per ₦1.00 on outstanding balances, in accordance with Section 72 of the NDIC Act 2023. This brings the cumulative liquidation dividend declared to date to 14.4 kobo per ₦1.00”.

The NDIC recalled that it had earlier paid a first liquidation dividend of ₦46.6 billion in April 2025, representing 9.2 kobo per ₦1.00, following the reimbursement of insured deposits of up to ₦5 million per depositor from its Deposit Insurance Fund.

According to the Corporation, the second tranche was made possible through sustained recovery of debts and continued asset disposal.

This payment is in furtherance of our statutory responsibility to ensure that depositors of closed banks are reimbursed promptly as assets are realised,” the NDIC said.

The Corporation explained that payments would be made automatically to eligible depositors using existing records. Depositors who have already received their insured deposits and the first liquidation dividend will have their alternative bank accounts credited automatically through their Bank Verification Numbers (BVN).

However, depositors without alternative bank accounts or BVNs, as well as those who have not claimed their insured deposits or the first liquidation dividend, were advised to visit the nearest NDIC office nationwide or complete the e-claim form on the Corporation’s website for verification and processing.

The NDIC noted that liquidation dividends are paid only to depositors with balances above the insured limit and are sourced from asset sales and recoveries. Other creditors and shareholders will be considered only after all depositors have been fully reimbursed and subject to the availability of funds.

The Corporation assured the public that the ₦24.3 billion payment represents only the second liquidation dividend, adding that further payments would be made as additional assets are realised and outstanding debts recovered.

Depositors were advised to contact the NDIC Claims Resolution Department at any of its offices nationwide or through the Corporation’s official email addresses and helplines for further enquiries.


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KPMG Identifies ‘Flaws, Inconsistencies, and Omission’ in New Tax Law

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KPMG Nigeria has identified what’s described as “errors, inconsistencies, gaps and omissions” in Nigeria’s tax laws that came into force at the beginning of this year.

The professional services company warns that these issues could undermine the attainment of the tax reforms’ stated objectives if left unaddressed.

The reforms, anchored on the Nigeria Tax Act (NTA) and the Nigeria Tax Administration Act (NTAA), alongside the Nigeria Revenue Service (NRS)  Establishment Act and the Joint Revenue Board (JRB) Establishment Act, are aimed at improving revenue generation, simplifying tax administration, and enhancing competitiveness.

Authorities have repeatedly described the overhaul as critical to strengthening Nigeria’s weak tax-to-GDP ratio and adapting the tax system to changing economic realities.

Capital gains, inflation, and market behaviour

One of the most far-reaching concerns relates to the computation of chargeable gains under Sections 39 and 40 of the Nigeria Tax Act, which require capital gains to be calculated as the difference between sale proceeds and the tax-written-down value of assets, without any adjustment for inflation, analysis by KPMG revealed.

This approach has attracted attention largely because of Nigeria’s inflation environment. Headline inflation has remained in double digits for eight consecutive years, averaging above 18 percent between 2022 and 2025, according to data from the National Bureau of Statistics. Over the same period, asset price movements have been heavily influenced by currency depreciation and general price increases.

Actual market behaviour shows a mixed reaction to tax policy expectations, despite a strong full‑year rally, with the NGX All‑Share Index up more than 50  percent and market capitalisation near N99.4 trillion, the equities market saw significant sell‑offs in late 2025, including a N6.5 trillion drop in market value in November amid uncertainty over the new capital gains tax rules, underscoring investor sensitivity to tax policy shifts.

In its review of the law, KPMG Nigeria noted that taxing nominal gains in a high-inflation environment could result in taxpayers being assessed on inflationary gains rather than real economic value. The firm recommended the introduction of a cost indexation allowance to adjust asset values for inflation when computing chargeable gains.

According to the analysis, such an adjustment would reduce distortions in effective tax rates while still allowing the government to generate additional revenue from genuine capital appreciation.

Indirect transfer rules and foreign investment risks

Another provision drawing scrutiny is Section 47 of the Nigeria Tax Act, which subjects gains from indirect transfers of shares or assets by non-residents to Nigerian tax where such transfers result in changes in ownership of Nigerian companies or assets located in Nigeria.

The provision is being introduced amid weak foreign investment inflows. Data from the United Nations Conference on Trade and Development shows that foreign direct investment into Nigeria remains below pre-2019 levels, reflecting broader investor caution.

While similar indirect transfer rules exist in other jurisdictions, analysts note that such regimes are typically supported by detailed guidance and clear thresholds to reduce uncertainty.

KPMG’s analysis recommended that Nigerian tax authorities issue clear administrative guidance defining the scope, thresholds, and reporting obligations associated with indirect transfers. The firm noted that clarity would reduce the risk of disputes, improve compliance, and mitigate potential negative effects on foreign investment flows.

FX deductions clash with economic realities

Section 24 of the Nigeria Tax Act limits businesses from deducting foreign-currency expenses beyond their naira equivalent at the official CBN rate.

In practice, this means a company importing goods, paying foreign software subscriptions, or settling overseas vendor invoices cannot claim as tax-deductible any amount they spent above the official exchange rate.

For many companies, this is a real problem. Access to official foreign exchange is limited, forcing businesses to pay higher rates on the parallel market. Under the law, the extra cost becomes non-deductible, effectively increasing taxable profits and raising their tax bills.

KPMG warns that while the rule aims to curb speculative foreign exchange activity, it fails to account for supply shortages. The firm recommends that deductibility should reflect the actual cost incurred, provided proper documentation, so businesses aren’t penalized for circumstances beyond their control.

VAT-linked expense disallowances

Section 21(p) of the Nigeria Tax Act disallows deductions for expenses on which value-added tax has not been charged, even where such expenses were incurred wholly for business purposes.

This intersects with Nigeria’s VAT compliance challenges. The informal sector accounts for a significant share of economic activity, and VAT compliance gaps remain wide, according to assessments by tax authorities and development institutions.

Analysts note that the provision effectively transfers part of the VAT enforcement burden to compliant taxpayers, who may be penalised for supplier non-compliance.

KPMG recommended that Section 21(p) be deleted or substantially modified, arguing that deductibility should depend solely on whether an expense was wholly, exclusively, and necessarily incurred for business purposes. The firm noted that VAT compliance should instead be enforced directly through audits and penalties on defaulting suppliers.

Non-resident taxation and compliance ambiguity

Uncertainty also surrounds the compliance obligations of non-resident companies. While Section 17 of the Nigeria Tax Act provides that withholding tax constitutes final tax for certain non-resident payments where there is no permanent establishment or significant economic presence, the Nigeria Tax Administration Act does not clearly exempt such entities from registration or filing requirements.

Nigeria has signed over a dozen double taxation treaties (DTTs), including the UK, South Africa, Canada, and France, which align with the principle that final WHT extinguishes further tax obligations in the absence of a taxable presence. Experts say harmonizing the NTA and NTAA with these treaties is critical to avoid conflicts and deter foreign investors.

KPMG recommended that the relevant provisions of the Nigeria Tax Act and the Nigeria Tax Administration Act be harmonised, with explicit exemptions for non-resident companies whose Nigerian tax obligations have been fully discharged through withholding tax. According to the firm, such alignment would reduce compliance friction and improve Nigeria’s attractiveness for cross-border transactions.

As Nigeria enacts its most comprehensive tax overhaul in decades, the path to success will depend on clarity, alignment with international best practices, and swift adoption of recommended amendments. Without these measures, businesses may face higher costs, non-residents could be discouraged from investing, and capital markets may remain volatile. For policymakers, the challenge is not just raising revenue but ensuring that the reforms strengthen competitiveness and sustainable economic growth.


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