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ARTICLE · 06 JULY 2026

CBN’S Data Localisation Directive – Compliance Considerations For Payment System Participants

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Nigeria's Central Bank has introduced sweeping data localisation requirements that will fundamentally reshape how payment service providers, banks, and financial institutions handle transaction data. With a January 2027 compliance deadline, these new rules mandate that all payment transaction data generated within Nigeria must be stored and managed locally, raising critical questions about cloud infrastructure, vendor relationships, and operational readiness. This analysis examines the scope of the requirem

NigeriaFinance and Banking

Introduction

On June 15, 2026, the Central Bank of Nigeria (“CBN“) issued a Circular on Introduction of Market Structure Requirements, Data Localisation, Ultimate Beneficial Ownership Disclosure, and Systemic Oversight Measures in the Nigeria Payments System (the “Circular“). Among other regulatory reforms, the Circular introduces a significant data localisation requirement directing all financial institutions and participants facilitating payments within Nigeria—including banks, payment service providers, mobile money operators and other payment participants— (collectively “Payment System Participants”) to ensure that data generated in relation to payment transactions in Nigeria is stored and managed in Nigeria by January 1, 2027.

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