The story of Nigeria’s fintech rise is usually told through the infrastructure the CBN built: instant payment rails, a biometric identity layer, and a real-time settlement system that processed close to 11 billion transactions in 2024. The first instalment of this series made that case. But infrastructure alone does not explain everything. Two of the most consequential things the CBN has done involve not building, but enabling a network of human intermediaries to bring banking to street corners, and redesigning the rules of remittance corridors so that billions of dollars changed direction. This second instalment covers both.
Case study 3: How agent banking turned a kiosk into a bank branch
In 2013, the CBN introduced its Guidelines for the Regulation of Agent Banking in Nigeria, allowing licensed financial institutions to appoint third parties, such as local shops, market traders, and petrol station kiosks, as banking agents. The regulation was modest in ambition, serving as a mechanism to extend cash-in and cash-out services into communities underserved by formal bank branches. What it set in motion was more significant.
A decade later, Nigeria has 5.9 million active POS terminals. For context, that figure is several orders of magnitude higher than the country’s 16,714 ATMs (per 2024 estimates) and nearly 1,000 times the number of bank branches. The International Monetary Fund (IMF) estimates there are 1,600 POS operators per square kilometre in Nigeria.
In 2024, POS terminals processed ₦18 trillion across 1.5 billion transactions, up 69% from ₦10.7 trillion the year before. By Q1 2025 alone, POS transactions had hit ₦10.51 trillion, a 209 per cent increase compared to the ₦3.62 trillion recorded during the same period in 2024. ATM transaction values, meanwhile, fell 19.87% year-on-year in the first half of 2024. Nigerians did not gradually shift to agents; they replaced ATMs with them.
The inclusion numbers tell the same story. Non-banking channel usage, which includes mobile money, agent banking, and digital platforms, grew from 5% to 12% of adults between 2020 and 2023. Enhancing Financial Innovation and Access (EFInA) identified the agent network as the primary driver behind Nigeria’s overall formal inclusion rate rising to 64% in 2023 from 56% in 2020.
The framework created a business model. It gave fintechs like Moniepoint, OPay, and PalmPay a licensed, scalable way to deploy hardware through human networks rather than building branches. Moniepoint alone now handles roughly 42% of Nigeria’s POS transaction volume through more than 400,000 active agents across all 36 states. That coverage was made possible by a regulatory decision in 2013 that defined who could serve as a ‘bank’, and where.
The CBN has continued to update the framework as it scales: October 2025 guidelines introduced geo-fencing, exclusivity requirements, and Know Your Agent standards, just as the regulator is tightening governance on an infrastructure it helped create.
Case Study 4: How the CBN redesigned the remittance corridor
Nigeria receives an estimated $20 billion in diaspora remittances annually. For years, a significant portion of that flowed through informal channels. The money reached households, but it bypassed the formal FX market, denying the CBN visibility and limiting naira liquidity at critical moments.
The problem was not simply an informal preference; it was pricing. Under the old rules, International Money Transfer Operators (IMTOs) were required to quote exchange rates within a ±2.5% band of the previous day’s official rate. In a market where the gap between official and parallel rates had grown wide, the restriction made formal channels structurally uncompetitive. Remitters went elsewhere.
In January 2024, the CBN abolished the rate cap entirely, allowing IMTOs to price at market rates. In the same package of reforms, the bank issued 14 new Approvals-in-Principle to prospective IMTOs, expanding competition in a corridor that had been dominated by a small number of incumbents, and established a Collaborative Task Force, reporting directly to Governor Cardoso, to drive inflow growth. It also raised IMTO licence fees and minimum operating capital requirements, filtering for serious, well-capitalised operators rather than a broad field of thinly funded ones.
The result? IMTO inflows rose to $4.76 billion in 2024, a 44.5% increase from $3.30 billion in 2023. July 2024 alone recorded $553 million. At the time, it was the highest monthly inflow on record, a 130% increase year-on-year. Total remittance inflows across all channels reached $20.93 billion in 2024, up 8.9% year-on-year, reversing declines in both 2022 and 2023.
The mechanism was straightforward: once formal channels were priced competitively, volume followed. What the IMTO reforms demonstrate is that the CBN’s most effective interventions are not always the ones that build something new. Sometimes, the more consequential act is identifying what the market already wants to do and removing the rule that was stopping it.
This article was written by the TechCabal Insights team.
