The Central Bank of Nigeria has introduced a bold new regulatory framework requiring the migration to ISO 20022 standards and geo-tagging of payment terminals by October 2025, aiming to enhance transparency, security, and compliance across the country’s payment landscape amidst privacy and operational challenges.
On August 25, 2025, the Central Bank of Nigeria (CBN) rolled out a pretty important circular that basically requires the migration of Nigeria’s payment messaging system to the ISO 20022 standard. Alongside that, all payment terminals now have to be geo-tagged—meaning each must be associated with a specific location. This directive targets Deposit Money Banks, Microfinance Banks, Mobile Money Operators, Super Agents, and other licensed payment service providers. The goal? To make Nigeria’s payment ecosystem more transparent, open, and, well, easier to trace—kind of like making the whole system more accountable and less opaque.
Now, as far as the legal backing goes, the circular draws its authority from the Central Bank of Nigeria Act of 2007 and the Banks and Other Financial Institutions Act, 2020—often called BOFIA. These laws give the CBN the power to supervise and regulate payment, clearing, and settlement systems across the country. And, just to point out, any circular issued under these authorities is considered binding. Ignoring them could lead to sanctions, sanctions that might include fines or other penalties. That said, if, for any reason, a circular is found to be beyond the CBN’s legal powers or conflicts with existing laws, courts might throw out those regulations, which would in turn invalidate any penalties tied to them.
Switching gears to the ISO 20022 standard itself—it’s a big upgrade, especially when compared to older messaging formats. It’s already widely used in the SWIFT network and in other countries. The CBN has set a firm deadline for compliance—October 31, 2025—and it’s no small feat. The new standard requires richer data within payment messages—for example, detailed info about the payer and payee, merchant or agent details, and comprehensive transaction metadata. The idea is that all this extra data will boost efficiency, help Nigeria’s compliance with anti-money laundering laws like the Money Laundering (Prevention and Prohibition) Act of 2022, and strengthen consumer protections by making transactions more auditable, even across borders. If a payment system fails to comply, it could undermine essential regulatory processes such as Know Your Customer (KYC), customer due diligence, or transaction reporting. On the flip side, sticking to the standard records makes the data more credible and usable for regulators and courts alike.
On top of that, geo-tagging isn’t just about location—it’s a safety and control measure. Payment operators are now required to install GPS receivers capable of dual-frequency tracking and integrate the National Central Switch Geolocation Software Development Kit (SDK). This setup ensures every transaction happens within a 10-meter radius of the registered business location. Essentially, the system must capture geolocation data at the “start” of each transaction and include it directly in the payment message. This helps keep operators accountable and plays a part in reducing fraud. The CBN is exercising its powers under Sections 68 and 69 of BOFIA, which cover cybersecurity and operational standards for payment systems.
But hold on—that’s where things get a bit complicated. Geo-tagging raises serious data privacy questions, especially under the Nigeria Data Protection Act (NDPA) of 2023. Since geolocation data is classified as personal data, strict rules around how data is processed, stored, and minimized come into force. Mishandling such sensitive information could mean trouble—fines or penalties from both the Nigeria Data Protection Commission and the CBN. Plus, privacy rights enshrined in Section 37 of the 1999 Constitution are involved, so there’s a delicate balance to strike: protecting security without trampling on individual rights.
Practically speaking, the rollout isn’t without hurdles. The tight deadlines mean payment operators need to upgrade their systems quickly—something that’s particularly tough for smaller banks and startups which will likely shoulder more costs and operational challenges than their larger counterparts. Infrastructure constraints in rural or underserved areas could also make geo-tagging hard to implement effectively. Not to mention, for businesses that operate in multiple locations or are mobile—like travel agencies, logistics companies, or mobile payment providers—the strict geographical restrictions might be burdensome and hard to manage consistently. Allowing some exemptions or flexible requirements might be a sensible way to reconcile these rules with real-world business needs.
Overall, this move toward ISO 20022 and geo-tagging fits into the larger picture of the CBN’s broader strategic vision for a modern, efficient Nigeria payments ecosystem. The 2025 Payments System Vision (PSV 2025), launched back in 2022, aims to boost financial inclusion, improve system safety, and promote electronic payments using upgraded infrastructure and innovative technologies like contactless payments. Also, the recent upgrade of the Real-Time Gross Settlement (RTGS) system to support ISO 20022 in 2023 underlines the commitment to these advancements. These efforts are complemented by adherence to globally recognized standards—such as ITIL, COBIT, and ISO 20022—to ensure good governance, robust architecture, and security within Nigeria’s financial sector.
The success of all this will largely depend on how well industry players adapt and implement these new requirements—and how flexible the CBN can be in offering guidance and enforcement that reflects practical realities. Striking the right balance between firm regulation, operational practicality, and privacy rights will be key if Nigeria wants to develop a payment system that’s not only cutting-edge and transparent but also resilient and fair—without putting undue strain on businesses or compromising individual privacy.
📌 Reference Map:
- - Paragraph 1 – [1], [4]
- - Paragraph 2 – [1], [2], [5]
- - Paragraph 3 – [1], [6]
- - Paragraph 4 – [1]
- - Paragraph 5 – [1], [3], [4]
- - Paragraph 6 – [1], [3], [4]
Source: Noah Wire Services
Verification / Sources
- https://lawpavilion.com/blog/legal-implications-of-iso-20022-migration-and-geo-tagging-for-the-nigerian-payment-system/?utm_source=rss&utm_medium=rss&utm_campaign=legal-implications-of-iso-20022-migration-and-geo-tagging-for-the-nigerian-payment-system - Please view link - unable to able to access data
- https://www.cbn.gov.ng/PaymentsSystem/LargeValuePayments.html - The Central Bank of Nigeria (CBN) initiated the Real-Time Gross Settlement (RTGS) System in December 2006 to manage large value payments. The system underwent an upgrade on April 11, 2023, to support ISO 20022, enhancing its technical and business features. This upgrade aligns with global standards, improving the efficiency and security of Nigeria's payment system.
- https://www.cbn.gov.ng/PaymentsSystem/PSV2025.html - The CBN launched the Payments System Vision 2025 (PSV 2025) on November 24, 2022. This five-year strategic roadmap aims to strengthen electronic payment adoption, enhance system safety and reliability, and foster financial inclusion. Key recommendations include reviewing core payment infrastructures and deploying contactless solutions to meet evolving market demands.
- https://www.cbn.gov.ng/itstandards/Overview.html - The CBN's Information Technology (IT) standards are derived from globally recognized frameworks such as ITIL, COBIT, and ISO 20022. These standards guide the Nigerian financial services industry in areas like IT governance, architecture, and security, ensuring alignment with international best practices and enhancing the sector's resilience.
- https://www.cbn.gov.ng/PaymentsSystem/BVN.html - In collaboration with the Bankers’ Committee, the CBN introduced the Bank Verification Number (BVN) on February 14, 2014. The BVN serves as a unique identifier for bank customers, addressing challenges in the Know Your Customer (KYC) process and enhancing the safety and reliability of Nigeria's banking system.
- https://www.cbn.gov.ng/PaymentsSystem/Oversight.html - The CBN established the Payments System Policy and Oversight Office to strengthen the monitoring of Nigeria's payment systems. This office oversees various payment service providers, including switching companies and mobile payment operators, ensuring compliance with regulatory standards and promoting system integrity.
- https://www.cbn.gov.ng/PaymentsSystem/PSV2020.html - The CBN embarked on the Payments System Vision 2020 project in 2007, aiming to benchmark Nigeria's payment system against global best practices. The initiative led to the development of the PSV 2020 Strategy document, which provided a roadmap for creating a nationally utilized and internationally recognized electronic payments infrastructure.
Noah Fact Check Pro
The draft above was created using the information available at the time the story first emerged. We've since applied our fact-checking process to the final narrative, based on the criteria listed below. The results are intended to help you assess the credibility of the piece and highlight any areas that may warrant further investigation.
Freshness check
Score: 8
Notes: The narrative references a CBN circular dated August 25, 2025, regarding the migration to ISO 20022 and geo-tagging. However, no direct evidence of this circular is found on the CBN's official website. The CBN has previously issued circulars on related topics, such as the Real-Time Gross Settlement (RTGS) system upgrade in April 2023 (cbn.gov.ng) and the Payments System Vision 2025 launched in November 2022 (cbn.gov.ng). The absence of the August 2025 circular online raises questions about the freshness and authenticity of the information. Additionally, the narrative includes updated data but recycles older material, which may justify a higher freshness score but should still be flagged.
Quotes check
Score: 7
Notes: The narrative includes direct quotes attributed to the CBN's legal authority and references to specific sections of the Banks and Other Financial Institutions Act (BOFIA) and the Nigeria Data Protection Act (NDPA). However, no online matches for these exact quotes were found, suggesting they may be original or exclusive content. This lack of verifiable sources raises concerns about the accuracy and reliability of the quoted information.
Source reliability
Score: 5
Notes: The narrative originates from LawPavilion, a legal technology company. While it provides detailed analysis, the lack of direct references to official CBN communications or other reputable sources diminishes the reliability of the information. The absence of the August 2025 circular on the CBN's official website further questions the authenticity of the claims.
Plausability check
Score: 6
Notes: The narrative discusses the CBN's directive for ISO 20022 migration and geo-tagging, aligning with the CBN's Payments System Vision 2025 (cbn.gov.ng). However, the absence of the August 2025 circular on the CBN's official website raises questions about the authenticity of the information. The narrative also includes updated data but recycles older material, which may justify a higher freshness score but should still be flagged.
Overall assessment
Veredict (FAIL, OPEN, PASS): FAIL
Confidence (LOW, MEDIUM, HIGH): MEDIUM
Summary: The narrative presents detailed information on the CBN's directive for ISO 20022 migration and geo-tagging. However, the absence of the August 2025 circular on the CBN's official website, lack of verifiable sources for direct quotes, and reliance on a single, potentially unreliable source raise significant concerns about the authenticity and reliability of the information. These issues, combined with the recycling of older material, suggest that the narrative may not be entirely accurate or trustworthy.