Quick Reads:

• CBN’s new market structure circular caps consumer issuing at 25% and merchant acquiring at 15% for any single fintech, with compliance due by end of 2026.
• Draft ring-fencing guidelines will force each subsidiary in a fintech group, such as Paystack’s The Stack Group or Flutterwave’s MFB arm, to hold its own capital and governance.
• A new AML framework demands fintechs prove explainability and accountability, not just software, in flagging suspicious activity.

Nigeria’s electronic payments industry processed a staggering ₦1.2 quadrillion (about $880.51 billion) in transactions in 2025, according to CBN figures cited in the report. But the era of near-frictionless expansion for fintechs may be ending. Between March and June, the Central Bank of Nigeria issued or opened for consultation a cluster of policy documents that, together, amount to a sweeping rewrite of the sector’s rulebook, and the new CBN fintech rules are already reshaping strategy across the industry.

For years, the growth formula was simple: build a payments product, sign up merchants, scale volumes, grab a microfinance banking licence, then push into lending and savings. Flutterwave followed that path in April, securing an MFB licence after acquiring open banking startup Mono. Paystack did the same in January by acquiring Ladder Microfinance Bank, before restructuring in a holding company called The Stack Group, which now houses Paystack, its Zap consumer app, Paystack MFB and a venture studio.

That model let fintechs share data, technology and management across units cheaply. The CBN’s draft ring-fencing framework wants to end that efficiency. It requires each regulated entity within a group to meet its own capital, liquidity and governance standards “regardless of group-level resources,” according to the guideline. Growth by acquisition remains possible, but running acquired businesses as one seamless group will now cost significantly more.

The regulator is also going after market dominance directly. Under a June circular, any institution controlling more than 25% of consumer issuing cannot simultaneously hold more than 15% of merchant acquiring, or vice versa, a direct response to fintechs like Moniepoint, which processed over ₦412 trillion in transactions in 2025 while expanding across merchant services and retail banking. Firms must now file monthly market-share reports and fall in line by the end of 2026.

Nigeria isn’t inventing this approach from scratch. India’s Reserve Bank capped market share on UPI apps after PhonePe and Google Pay came to dominate, while Europe’s PSD2 forced banks to open up payment infrastructure to third parties. The CBN’s latest moves mirror that global push toward reining in concentrated payment power.

Rounding out the reforms is a new anti-money laundering framework that raises the bar beyond simply buying compliance software. Fintechs must now show they can explain how suspicious activity is flagged and prove risk management is embedded across the business, not bolted on. Together, these CBN fintech rules signal that Nigeria’s payments industry is moving from a growth-at-all-costs phase into one where governance, not just scale, determines who wins.