-1323.png){kind=logo}
Introduction
This November 2025 Regulatory Digest highlights key regulatory developments across Nigeria’s financial, telecommunications, and digital sectors, reflecting ongoing efforts to strengthen governance, foster innovation, and enhance cyber and consumer protections. From Central Bank of Nigeria (CBN) exposure draft Guideline strategic partnerships by the Federal Ministry of Communications, Innovation and Digital Economy (FMCIDE) and the National Information Technology Development Agency (NITDA). This is geared towards advancing digital infrastructure, cybersecurity, and digital skills development, enhancing telecommunications security and competitiveness. This digest also covers important regional regulatory movements impacting Africa’s digital economy landscape.
A quick summary...
CBN Draft Guideline on the Treatment of Dud Cheques by Banks and Other Financial Institutions in Nigeria
In November 24, 2025, the Central Bank of Nigeria (CBN) released an Exposure Draft of the Guidelines on the Treatment of Dud Cheques by Banks and Other Financial Institutions in Nigeria (the “Draft Guidelines”) The Draft Guidelines is intended to supersedes all previous circulars and regulations on dud cheque management and introduce a more consistent framework for handling such incidents across the financial system.
The revised framework is designed to enhance public confidence in the banking sector by clarifying how dud cheques are to be reported, processed, and sanctioned. Under the Draft Guidelines, Participating Financial Institutions are required to follow a clearly defined process for reporting dud cheque occurrences, while the Credit Risk Management System (CRMS) must notify all PFIs when a customer is classified as a serial dud cheque issuer and barred. The Draft Guidelines further provide that any individual who, after being unbarred upon expiration of the initial five-year barring period, issues another dud cheque will be subject to a fresh five-year bar each time the offence is repeated.
The document also outlines the conditions under which an individual may be removed from the dud cheque database which includes the expiration of the barring period, correction of erroneous reporting by a PFI, or any additional grounds that may be stipulated by the CBN. It sets out the procedures for updating records thereby ensuring accuracy in the CRMS. Finally, the Draft Guidelines introduce a structured sanctions regime that prescribes penalties for non-compliance by both customers and financial institutions, reinforcing the CBN’s objective of promoting stronger risk management and accountability within the industry.
The exposure draft is open for comments and contribution until December 15, 2025.
CBN Publishes Draft on Authorisation Push Payment (APP) Fraud
In November 2025, the CBN published a draft Authorisation Push Payment (APP) Fraud Guideline. A Guideline that represents a regulatory intervention that fundamentally shifts liability from victims to financial institutions through mandatory reimbursement within 48 hours post-investigation, strict 14-day investigation timelines, and board-level governance requirements. The framework mandates Early Warning Systems for fraud detection, 24/7 reporting channels, and holds institutions fully liable when they fail to detect suspicious activities or freeze fraudulent proceeds, while recognising vulnerable customers and establishing clear eligibility criteria tied to 72-hour reporting windows. The strength of the Guideline lies in making fraud prevention a collective responsibility across the ecosystem rather than externalising costs to consumers.
The exposure draft is open for comments and contributions until December 17, 2025.
CBN Issues Circular on Compliance with Regulatory Provisions on Advertisement
CBN issued a circular directing all banks, payment service banks, and financial institutions to immediately withdraw advertisements violating consumer protection and fair-marketing standards, following a thematic industry review that revealed widespread inconsistencies in disclosure, transparency, and fair-marketing practices under the Consumer Protection Regulations 2019 and the 2000 Guidelines on Advertisements by Deposit-Taking Financial Institutions. Financial institutions must withdraw advertisements that are not compliant with the existing Regulations and submit a compliance attestation within 30 days jointly signed by the CEO, Executive Compliance Officer, and Chief Compliance Officer. Financial institutions in non-compliance will face sanctions under BOFIA 2020 and Consumer Protection Regulations during a follow-up review commencing in January 2026.
FMICDE Partners with Sierra Leone to Advance Regional Digital Integration and Innovation
The Federal Ministry of Communications, Innovation and Digital Economy (FMICDE), in collaboration with Sierra Leone, concluded a bilateral Digital Economy Mission in Freetown aimed at strengthening West Africa’s digital corridor through expanded cross-border interoperability, enhanced digital infrastructure, advanced talent development and deeper innovation ecosystems. The mission focused on shared priorities including cross-border payments, AI localisation, Digital Public Infrastructure and startup expansion, and both countries signed three major cooperation frameworks aimed at accelerating regional digital integration and strengthening West Africa’s emerging technology ecosystem. These agreements, supported by direct company-to-company partnerships, underscore FMICDE’s commitment to building a secure, connected and innovation-driven regional digital landscape that empowers young people, supports competitive businesses and drives sustainable economic prosperity.
FMCIDE Participates in the Adoption of the Cotonou Declaration 2025 to Advance Regional Digital Transformation
The Federal Ministry of Communications, Innovation and Digital Economy FMICDE participated in the Regional Summit on Digital Transformation, where West and Central African states formally adopted the Cotonou Declaration 2025. The Declaration outlines shared priorities, including expanding affordable high-speed broadband, deploying secure and interoperable digital public services, equipping young people, women and persons with disabilities with digital skills, strengthening regional capacities in data, cloud and artificial intelligence, supporting Africa-founded innovation and digital job creation, mobilising capital for digital growth, and harmonising cybersecurity, governance and data protection frameworks.
The adoption of this Declaration aligns closely with FMCIDE’s national priorities to expand resilient fibre infrastructure, deepen Digital Public Infrastructure and strengthen talent development, marking a significant step toward building a Single African Digital Market grounded in connectivity, trust, innovation and ethical AI.
NITDA Partners with the UK to Strengthen Cybersecurity and Digital Infrastructure
The National Information Technology Development Agency (NITDA), in collaboration with Galaxy Backbone and the Nigeria Data Protection Commission (NDPC), engaged with the United Kingdom’s Digital Access Programme in London to strengthen Nigeria’s digital transformation agenda. The partnership focused on enhancing cybersecurity through improved supply chain security, robust threat intelligence, and comprehensive risk assessments, while also drawing on UK expertise to advance secure and cost-efficient IT procurement frameworks. These joint efforts reflect NITDA’s continued commitment to driving secure digital infrastructure and supporting sustainable economic growth.
NITDA Issues Advisory to Enhance Service Resilience After Global Cloudflare Outage
NITDA issued a security advisory following the global Cloudflare service outage that disrupted access to several government and organisational websites. The advisory urges all institutions to strengthen service resilience by adopting backup (Domain Name Servers (DNS) resolvers, using multiple Content Delivery Network (CDN) or failover configurations, ensuring direct server access where possible, maintaining alternative access channels for staff, and keeping updated local records of critical server and DNS information. These measures aim to minimise downtime and ensure continuity of essential digital services during future disruptions.
NITDA Announces National Initiative to Train 50 Million Nigerians in Digital Skills by 2027
NITDA announced a major national initiative to boost Nigeria’s digital economy by training 50 million citizens and raising digital literacy to 70% by 2027. This was announced during the closing session of the Digital Nigeria Conference 2025; the programme targets the education sector, public service, and informal economy through measures such as curriculum development, nationwide teacher training, civil service capacity building, and community-based outreach. Partnerships with NYSC and state governments are expected to drive large-scale adoption, with digital champions projected to train over 10 million Nigerians annually.
NITDA Launches Platform for Registration of Indigenous IT Service Providers
NITDA has launched its digital platform for the registration of indigenous IT contractors and service providers, a mandatory requirement for firms seeking to deliver IT services to Federal Government Ministries, Departments, and Agencies. Through the IICP portal, companies can submit applications and required documents, including CAC registration, tax clearance, and evidence of technical competence, to obtain a provisional six-month certificate, followed by a substantive two-year certification upon verification. The initiative strengthens compliance, enhances service quality, and supports the development of a national database of credible indigenous IT firms.
Senate Confirms New NCC Board
The Senate has confirmed the new board of the Nigerian Communications Commission (NCC) following a successful screening by its Committee on Communications. The newly confirmed board is expected to provide strategic leadership and oversight to advance the development and regulation of Nigeria’s telecommunications sector.
NCC Issues Draft Cybersecurity Resilience Framework for Stakeholder Review
NCC has issued a draft Cybersecurity Resilience Framework (CRF-NCS) to guide licensees and operators in strengthening security measures across Nigeria’s communications sector. The document has been shared with stakeholders via email, and they are expected to review it and provide feedback through the same channel to support the development of robust, sector-wide cybersecurity practices.
NCC Begins Review of 3 Key Regulatory Instruments to Strengthen Sector
NCC commenced the review of three of its regulatory instruments, the Licensing Regulation, Enforcement Processes Regulation, and the Internet Code of Practice, to enhance efficiency, accessibility, and competitiveness in the communications sector.
The review aims to align the regulations with evolving global best practices, safeguard user rights, promote cybersecurity, support the responsible use of AI, and streamline licensing and enforcement processes.
NCC Partners with Swedfund to Strengthen 5G Security and Reliability
NCC has partnered with Sweden’s development finance institution (Swedfund) to enhance the security and reliability of 5G network in Nigeria. This partnership is to develop a risk-based framework ensuring that 5G infrastructure is deployed and operated securely, strengthening trust in the network. The initiative is expected to support key sectors such as power, healthcare, transport, and education, boost public confidence, and advance the country’s digital economy while mitigating emerging security risks associated with 5G technology.
NCC Launches Nigeria’s First Mobile Virtual Network Operator (MVNO)
NCC has marked a key milestone in the country’s telecommunications sector with the launch of Nigeria’s first Mobile Virtual Network Operator (MVNO), Vitel Wireless. Licensed under the NCC’s MVNO framework, Vitel operates under the brand name Blue, leasing network capacity from MTN and achieving full interconnection with all major operators.
FEC Approves Reform from the Federal Ministry of Industry, Trade, and Investment
Nigeria's Federal Executive Council (FEC) approved the reforms presented by the Minister of Industry, Trade and Investment (MITI) which includes the National Intellectual Property Policy and Strategy (NIPSS), and ratification of the AfCFTA Protocol on Digital Trade. The Ministry is spearheading efforts to modernise Nigeria's outdated IP laws through plans to merge the Trademarks, Patents, and Designs registries into a single commission, automate digital filing systems in collaboration with WIPO, and enable IP assets to serve as collateral for loans.
Additionally, the Ministry is driving innovation commercialisation by providing funding through TETFund, incentivising universities to develop and register patents, and integrating IP education into tertiary institution curricula. Through the AfCFTA Protocol ratification, the Ministry aims to harmonise digital commerce rules across Africa, covering cybersecurity standards, electronic transactions, digital payments, and consumer rights, positioning Nigeria as a continental leader in digital trade governance.
These reforms provide critical legal infrastructure for Nigeria's tech ecosystem, particularly benefiting fintech, eCommerce, and creative industry startups seeking global scalability.
FMITI Launches Trade Intelligence Tools
The FMITI launched two trade intelligence tools, the Nigeria Trade Intelligence Report 2025 and Trade Insights Nigeria, alongside a National Action Framework to accelerate AfCFTA implementation and position Nigeria as Africa's leading trade hub. These tools aim to provide businesses with actionable market data, deepen understanding of regional value chains, and support exporters scaling across African markets, building on Nigeria's 2024 progress including updated tariff concessions and designation as co-champion of the AfCFTA Protocol on Digital Trade. The launch underscores the need for sustained collaboration among government, private sector, media, and development partners to translate AfCFTA reforms into real economic gains for Nigerians.
Gabon to Revise its Media Law
The Minister of Communication and Media in Gabon and the High Authority for Communication (HAC) have initiated the comprehensive review of the Gabon's media laws. Key areas under consideration include defining the legal framework for media practitioners, establishing transparent procedures for licensing and establishing media outlets, and enhancing regulatory mechanisms for broadcast content. The Minister emphasised that enacting a revised Media Code is a top governmental priority, with the reform expected to elevate professional standards, strengthen accountability measures, and establish a unified regulatory framework that promotes information credibility and transparency.
South Sudan Moves to Enact its Cybersecurity Law
South Sudan's National Legislative Assembly (NLA) has passed the Cybercrime and Computer Misuse Bill, 2025, which it has forwarded to the President for assent. The bill seeks to establish comprehensive digital security regulations by creating a specialised cybercrime unit under the Ministry of Justice and Constitutional Affairs. Key provisions include mandatory obligations for service providers, criminalisation of unauthorised data access, online harassment, disinformation, and fraudulent digital identities. The bill confers extensive investigative authority on law enforcement and empowers regulators to mandate cybersecurity compliance, backed by penalties for violations.
The November 2025 regulatory updates demonstrate a resolute push towards regulatory modernisation and integration in Nigeria and across Africa’s digital and financial ecosystems. With measures such as the CBN’s phased crackdown on dud cheque issuance, expanded digital skills initiatives by NITDA, and new cybersecurity and telecommunications frameworks by NCC, regulators are prioritising accountability, innovation, and resilience. These developments lay a solid foundation for sustainable digital transformation, regional cooperation, and economic growth, ultimately fostering increased trust and participation in the evolving digital economy.
.png)
