Legal Question in Banking Law in Nigeria

The question is not clear in regard to the capacity in which you want to operate, for example, as a payment systems provider, or a switch, or some value added service or even a merchant.

The Central Bank of Nigeria can only license banks and other financial institutions, not providers of payment systems. Consequently, CBN gives a "No Objection" instead of a license.

CBN also issued some guidelines and regulations, but none is backed by any law and it is debatable if CBN has such powers. There are no laws in Nigeria yet governing payment systems and service providers or governing electronic transactions.

I suggest discussions with switches/processors and your bank since whatever capacity you will be operating will still require integration. Ask about their requirements. My preliminary view is that they will suggest you get a no objection status from CBN