CBN’s UBO directive signals deeper regulatory shift for fintechs

The Central Bank of Nigeria has ordered fintechs and other regulated financial institutions to identify, verify, and disclose their Ultimate Beneficial Owners. The directive, issued in June 2026, applies to banks, payment service providers, mobile money operators, switching companies, and all players in the payments ecosystem.

At first glance, it looks like another compliance burden. But the circular points to a bigger change. The CBN wants to know who really owns, controls, or influences the institutions now central to Nigeria’s financial system.

“All Deposit Money Banks, Payment Service Providers and Other Financial Institutions with digital payments footprints shall disclose the Ultimate Beneficial Ownership of significant shareholders in accordance with applicable extant laws and regulations including Anti-Money Laundering, Combating the Financing of Terrorism and Counter Proliferation Financing regulations,” the circular states. “Institutions shall maintain accurate and up-to-date UBO records and make such information available to the CBN upon request.”

The regulator is not just looking at company registration documents. It wants the natural persons who ultimately own or control these firms, even if ownership runs through multiple companies, investment funds, trusts, or offshore structures.

For traditional banks, this is straightforward. For high-growth fintechs, it is more complex. Many leading Nigerian fintech firms have raised billions of dollars from international investors over the past decade. To accommodate those investments, they set up offshore holding companies in various jurisdictions.

This directive could force those firms to untangle complex ownership webs and reveal who is really pulling the strings. It signals that as fintechs become critical to Nigeria’s payment infrastructure, the CBN will demand full transparency, no matter how complicated the corporate structure.