CBN's Open Banking Guidelines: Implications For Non-Bank Entities

It is often assumed that the Central Bank of Nigeria's (the "CBN") Open Banking Framework and related guidelines ( the "Open Banking Guidelines") are relevant only to banks and licensed fintech companies. However, a closer reading of the Open Banking Guidelines suggests that its application is significantly broader, extending to any company that shares or consumes financial data through APIs, regardless of sector.

The Legal Basis for Broad Applicability

First, section 6.1 of the CBN Operational Guidelines for Open Banking (2023) states unambiguously that only entities that are registered on the Open Banking Registry are eligible to participate in the open banking ecosystem, either as API Providers or API Consumers.