CBN UBO Rule Targets Ownership Disclosure in Fintech

In Short

• The Central Bank of Nigeria (CBN) has issued a new directive on ownership transparency across banks and payment firms.
• Regulated fintechs must identify and disclose their ultimate beneficial owners, meaning the real people who control the business.
• The CBN says the move supports anti-money laundering and counter-terrorism financing enforcement.

What Happened

The CBN has introduced an Ultimate Beneficial Owners (UBO) disclosure requirement for Nigerian fintech solutions and other regulated financial institutions.

A UBO is the natural person, meaning a real human, who ultimately owns or controls a company, even if the holding structure uses other companies in between. Under the directive, Deposit Money Banks, Payment Service Providers (PSPs), and digital finance institutions must verify, identify, and disclose all people who own, control, or influence the business.

The circular also points to broader payment system oversight topics, including market structure requirements and data localisation. Data localisation means certain payment data should be stored in Nigeria, instead of being hosted fully abroad.

The new UBO rule requires firms to keep a public record of this ownership information and have it ready for checks by the regulator.

Why It Matters

Nigeria’s payments and fintech sector is large and heavily funded. Industry research cited by the source estimates Nigeria had over 430 fintech companies as of February 2025, and the country has attracted a major share of Africa’s fintech equity funding in recent years.

For the CBN, UBO disclosure is a compliance tool. It helps regulators trace responsibility when there is fraud, sanctions exposure, or money laundering risk.

For startups and investors, the rule may be harder to implement. Many Nigerian fintechs operate with offshore holding companies to raise foreign capital, simplify shareholding, and access other jurisdictions. This can make it harder to show who controls what, especially when ownership is spread across funds, special purpose vehicles, or nominee structures.

The next question is enforcement. If the CBN conducts routine audits and ties compliance to licensing, approvals, or transaction limits, fintech operators will need stronger legal and governance processes to stay compliant.