A CBN rule designed to curb fraud is exposing small operators to outages, income shocks, and a market tilted toward dominant fintechs, ITPulse’s Epiphanus Obia writes
On 1 April 2026, the Central Bank of Nigeria activated the most consequential clause in its October 2025 agent banking guidelines: every PoS agent in the country must now operate exclusively with a single financial institution. No more backup terminals and no more switching when networks fail. No diversifying income across providers. The decision is final, the deadline has passed, and the consequences are only beginning to unfold.
The CBN’s stated rationale is coherent enough. Nigeria had 8.36 million registered PoS terminals and 5.90 million active ones as of March 2025, generating a record ₦10.51 trillion in transactions in Q1 2025 alone — a 301.67 per cent increase over the same period in 2024. That extraordinary growth outpaced regulatory oversight. Multi-terminal operations made fraud difficult to trace, accountability impossible to assign, and suspicious transaction patterns easy to obscure across multiple provider platforms. The solution the CBN has opted for is straightforward: one agent, one institution, one dedicated account. Violation means a three-year BVN suspension for the agent and fines of up to ₦10 million for the principal.
The reform, on paper, is rational, but in practice, particularly across the South-East, its consequences are considerably more complicated.
The South-East exposure
Nigeria’s South-East geopolitical zone (comprising Anambra, Enugu, Imo, Abia, and Ebonyi states) is commercially dense in ways that made it an early and enthusiastic adopter of agent banking. The region’s economy runs on trade, and trade in Nigeria runs on cash. From the wholesale markets of Onitsha, Enugu and Aba to the industrial clusters of Nnewi, transactions that would be handled by bank branches in other economies have long been mediated by PoS agents.
Based on national figures, the South-East is home to an estimated 270,000 of Nigeria’s approximately two million banking agents — roughly 13 per cent of the national network distributed across five of the country’s 37 territorial units. The region also records some of the country’s lowest rates of financial exclusion. EFInA survey data places formal financial exclusion in the South-East among the lowest in Nigeria, meaning a higher share of everyday transactions flows through the PoS network than in more excluded regions. That density is now a source of vulnerability rather than strength.
The reason is infrastructure. The South-East has one of the most unreliable electricity supplies in the country. Under the old multi-terminal model, agents managed the risk of network failures by switching providers when one went down. That option no longer exists. An agent who has committed to a single provider is now entirely exposed to that provider’s uptime in a region where uptime cannot be guaranteed. The new geo-fencing requirement makes the problem worse: agents cannot operate outside their registered premises, removing whatever geographic flexibility once allowed them to adapt to shifting market conditions.
The small agent squeeze
The reform’s most acute pressure falls on the agents that the CBN’s financial inclusion mandate was originally designed to empower. Many of Nigeria’s two million banking agents are micro-operators: women running kiosks in markets, young men at roadside stalls, shop owners who added a terminal to supplement their primary income. For these agents, multi-terminal operations were not an abuse of the system. They were the system’s de facto safety net.
Meanwhile, the uniform transaction caps introduced alongside the exclusivity rule compound the problem. A daily agent cash-out limit of ₦1.2 million sounds substantial until it is tested against the transaction volumes of a busy market agent in Onitsha or Ariaria on a peak trading day. Combined with a ₦100,000 daily ceiling on individual customer cash-out transactions, there is a real risk that high-traffic agents in the South-East’s commercial corridors will exhaust their limits before the working day ends, pushing customers toward whichever providers still have capacity, rather than the agent’s registered institution.
Legal analysts at Mondaq have raised a related concern: the new requirement that agents operate from a formal kiosk or fixed registered premises adds structural costs that favour urban operators. In smaller South-East communities, agents frequently operate from tables or makeshift arrangements. Rigid formalisation requirements, excluding risk from the network, the very operators closest to the financially underserved communities, the CBN sought to bring into the formal system.
The consolidation play
The structural beneficiary of this regulatory reset is not the small agent. It is the fintech platform with the most reliable infrastructure at the precise moment agents are forced to choose.
Among Nigeria’s agent banking providers, OPay and Moniepoint are the most likely winners. OPay operates more than two million PoS and merchant service points nationally, backed by substantial infrastructure investment and a brand that is already synonymous with everyday transactions for millions of Nigerians. Moniepoint, meanwhile, processes an estimated $17 billion in monthly transactions, driven by deep penetration into SME and merchant payments. When agents must choose once and cannot easily reverse that choice, they will gravitate toward whoever fails the least.
However, framing this consolidation as a natural market outcome obscures the regulatory role in engineering it. The guidelines have not simply improved the agent banking market; they have structurally disadvantaged every provider that does not already command a dominant share of agent trust. Smaller fintechs and payment service banks that have been steadily building agent networks face a fundamentally altered competitive landscape: one where the only viable pitch is unimpeachable reliability, and where the incumbents’ head start may now be institutionally entrenched.
It is worth noting that a lengthy article published in Vanguard days after the April 1 deadline, authored in OPay’s own voice, explicitly promoted OPay as the obvious choice for agents navigating the new rules. Whether that reflects confidence or urgency is a matter of interpretation. What it confirms is that the race for agent loyalty is already underway, and the largest players arrived at the starting line with a significant advantage.
The accountability gap
The CBN’s reform addresses one accountability problem, fraudulent multi-terminal activity, by creating another: single-point dependency in a market where infrastructure failure is routine. What makes the omission difficult to excuse is that the regulatory precedent for addressing it already exists.
In May 2025, the Nigerian Communications Commission directed telecommunications operators to notify users of major network outages and provide proportional compensation, including extended service validity, when disruptions exceed 24 hours. The NCC’s logic was straightforward: when a consumer or business depends on a single network for a critical service, the provider bears formal accountability for the cost of that service failing. The CBN, publishing its agent banking guidelines just months later, did not apply the same logic to principals whose agents are now, by regulatory mandate, equally single-dependent.
The guidelines needed to be paired with mandatory service-level commitments from principals, with clear compensation mechanisms when downtime affects agent income. No such provision appears in the current framework. What the regulation has produced, in effect, is a system where the risk of provider failure has been transferred entirely from fintech companies to individual agents. The institution that wins an agent’s loyalty through the exclusivity mandate faces no formal penalty if network failure costs that agent a day’s income. And in the South-East, where power instability and fibre vulnerability make outages a near-daily reality, it is the agents least equipped to absorb the loss who will bear it most often.
The CBN has addressed a genuine problem through a blunt instrument that concentrates market power, reduces operational resilience for the South-East’s most vulnerable agents, and does not yet require the entities that benefit most from the consolidation to guarantee the service quality that the reform’s logic demands. The regulation may well stabilise the sector over time. In the South-East, the short-term cost will be borne disproportionately by small-scale operators for whom agent banking was never simply a business, it was their version of a bank. The question the CBN has not yet answered is who compensates them when the single provider they were forced to choose goes down.