Nigeria's Open Banking: Data Access Considerations

As Nigeria transitions to an open banking regime, we anticipate a wave of fintech innovation driven by secure and regulated access to customer data. While this access presents significant opportunities for product development, it is governed by strict regulatory safeguards. In this update, we outline key considerations for fintechs seeking to responsibly and lawfully leverage open banking APIs to access customer data.

1.Understanding Customer Data Categories

The categories of information that a fintech (as an API Consumer) can access from a bank depend on the data tier and the scope of customer consent. The CBN groups data into four broad categories, each with increasing sensitivity and regulatory requirements. The first category is Product Information and Service Touchpoints (PIST). This includes non-sensitive, public information such as a bank's branch locations, ATM networks, interest rates, account types, loan offerings, and applicable charges. Because this