In a significant development, largely unprecedented in Nigeria, the Central Bank of Nigeria ("CBN") issued a Circular titled Introduction of Market Structure Requirements, Data Localisation, Ultimate Beneficial Ownership Disclosure, and Systemic Oversight Measures in the Nigerian Payments System on 15 June 2026 ("Circular"). Through the Circular, the CBN directed that all financial institutions and participants facilitating payment transactions within Nigeria must ensure that payment transaction data generated within the country is stored and managed in Nigeria in accordance with applicable Nigerian data protection laws and regulations. Compliance with this requirement becomes mandatory from 1 January 2027. The discourse below centres around the impact of the requirement on Nigeria’s data protection regulatory landscape.
