An Examination of the Regulation of Financial Technology Companies Under Nigerian Law

Financial technology companies have transformed the delivery of payments, credit, insurance, and investment services in Nigeria, yet the regulatory framework governing these entities is fragmented across Central Bank of Nigeria licensing regimes, SEC rules, NAICOM guidelines, and the draft Financial Services Regulatory Bill. This study examines the legal framework applicable to fintech companies in Nigeria, focusing on payment service banks, digital lenders, robo-advisory platforms, and insurance technology operators. A doctrinal methodology was combined with interviews of 20 fintech founders and legal advisers in Lagos and Abuja. Regulatory sandbox policy documents and CBN, SEC, and NAICOM circulars from 2020 to 2023 were also analysed. Results indicate that regulatory arbitrage is common because similar activities attract different licensing requirements and consumer protection obligations depending on the regulatory agency involved. The CBN regulatory sandbox has admitted a limited number of participants, restricting innovation at scale. Digital lender predatory practices including unconscionable interest rates and data privacy violations remain inadequately regulated. The study concludes that a consolidated Financial Services and Fintech Regulatory Act is necessary to harmonise requirements across agencies and establish technology-neutral regulatory principles. Recommendations include a joint CBN-SEC-NAICOM fintech coordination committee, mandatory digital lender code of conduct, and NDPC-enforced consumer data protection obligations for fintech platforms.

Keywords: fintech regulation, CBN, digital lending, payment services, Nigeria