If Nigerian fintech founders thought 2025 was a migraine, they might want to stock up on something stronger for 2026. The Central Bank of Nigeria (CBN) is closing out the year by issuing policy documents that effectively reshape the operational landscape for traditional banks, neobanks, payment service banks (PSBs), and agency banking giants like Moniepoint, OPay, and PalmPay.

In a move that can be described as “aggressively prudent,” the regulator is squeezing the sector from two sides: making cash easier to trap but expensive to release, and making fraud significantly more expensive to ignore.

Part 1: The War on Cash

The Circular: Revised Cash-Related Policies (Effective Jan 1, 2026)

The CBN has pivoted its strategy. Previously, the regulator threatened to punish people for bringing too much cash into the banking system.

Effective January 1, 2026, the cost of handling physical naira changes drastically. For the agency banking networks that serve as the de facto ATMs for millions of Nigerians, the new math is a mixed bag of relief and restriction.

The Reverse Logic on Deposits

In a surprising twist, the CBN has removed the cumulative deposit limit and, crucially, scrapped the associated fees on excess deposits.

• The Old Fear: Agents used to worry about being taxed for depositing their daily collections.
• The New Reality: Agents can now dump as much cash as they like into the system without penalty. 

The Withdrawal Squeeze

Here is where it gets tricky. The “special authorisation” that previously allowed individuals and corporates to withdraw N5m and N10m once a month? Abolished. 

The New Limits:

• Individuals: Capped at N500,000 weekly withdrawals across all channels.
• Corporates: Capped at N5,000,000 weekly.
• ATMs: The daily limit is a modest N100,000 (capped at N500k weekly).

The “Penalty” for Liquidity: If you insist on withdrawing more than the limit, you will pay for the privilege.

• Individuals: 3% fee on the excess amount.
• Corporates: 5% fee on the excess amount.
• The Kicker: The fee is shared 40% to the CBN and 60% to the bank. Essentially, the regulator has created a revenue stream out of your stubborn refusal to use an app.

Even diplomatic immunity has its limits. In a move that suggests the CBN is in no mood for exceptions, the exemption previously enjoyed by embassies, diplomatic missions, and aid-donor agencies has been revoked. The diplomatic pouch may be inviolable, but the diplomatic wallet is now subject to the same weekly withdrawal caps as a standard SME

Part 2: A New Fraud Policy

The Document: Draft Guidelines for Handling Authorised Push Payment (APP) Fraud

If the cash policy is a strategic pivot, the new guidelines on Authorised Push Payment (APP) fraud are a blunt instrument aimed at compliance departments. Historically, if a customer was tricked into sending money to a fraudster (social engineering), the bank’s defense was simple: “You entered your PIN. You authorized it. Tough luck.”

The CBN’s new stance suggests: “Not anymore.”

The Liability Shift

The guidelines introduce a concept terrifying to risk officers: the bank is liable for reimbursement even if the customer authorized the transaction, provided the customer wasn’t “grossly negligent.”

• The 50/50 Split: If the money is gone and neither the sending bank nor the receiving bank is technically “at fault” (i.e., they followed protocol but the fraud happened anyway), they must split the reimbursement cost equally.
• The “Vulnerable” User: Financial institutions must apply a “higher duty of care” to vulnerable customers. In a market where digital literacy varies wildly, defining who is “vulnerable” is a potential minefield for legal teams.

The Sprint Protocol

The CBN has set deadlines that suggest they believe bank investigators do not require sleep:

1. Reporting: Customers have 72 hours to report fraud to be eligible for guaranteed reimbursement.
2. Investigation: Banks have 14 working days to conclude investigations.
3. The Payday: If the bank finds in favor of the customer, they must reimburse within 48 hours.
4. Inter-bank Communication: If fraud involves another bank, the originating bank has 30 minutes to notify them.

The “Pre-Crime” Division

Banks are now required to implement an Early Warning System (EWS). They must “red flag” accounts that look suspicious — unusual inflows, repeated complaints, or behavioral anomalies. The CBN is effectively asking fintechs to develop a “Minority Report” division. If a bank fails to flag an account that turns out to be a mule, they are fully liable for the losses. The days of onboarding users with just a phone number and a smile are definitively over.

The Impact: An Edgy (and Expensive) 2026

1. The “Cash Vacuum” Model With deposit fees gone, agents will likely become aggressive cash collectors. However, with withdrawal fees kicking in at just N500k for individuals, agents will struggle to re-stock cash for withdrawals without incurring costs. This naturally disincentivizes cash-out services. The result? Money goes digital and stays digital. Great for the CBN’s metrics; a headache for the market woman who needs cash to buy yams from a farmer with no smartphone. Essentially, the strict withdrawal caps and punitive excess-cash charges could unintentionally push Nigeria’s ubiquitous agents to the old habit of storing money under the mattress. For fintechs, this undermines transaction volumes and agent float — the very fuel of their business models. This situation is even worsened by recent rules from the CBN on agency banking.
2. An Edgy Recapitalisation Year These policies land at a moment when Nigeria’s banks are under strict orders to bulk up their balance sheets, and fast. With the 2026 recapitalisation deadline looming, the CBN is keen to ensure deposits remain sticky — or better yet, trapped — inside the system. Limiting withdrawals and monetising excess cash transactions conveniently boosts liquidity ratios and cushions banks’ capital positions ahead of regulatory audits. But in a country where trust in the banking sector still wobbles, this strategy walks a fine line: what the regulator calls financial stability, the public might interpret as a silent admission of fragility. By making cash expensive to touch, the CBN is effectively signalling that every naira inside the banking sector now counts — arguably a sign of strength on paper, but one that risks jittery customers reading between the lines.
3.  The Profitability Hit Fintechs like Kuda, FairMoney, and OPay have built models on low fees. The requirement to potentially reimburse social engineering victims — combined with the 50/50 liability split for “no-fault” fraud — creates a massive, unpredictable line item on the balance sheet.
4. The Friction Returns To avoid liability, fintechs will likely tighten the screws on transactions. Expect more “cooling off” periods for new beneficiaries, aggressive blocking of “suspicious” transfers, and perhaps the end of instant, friction-free onboarding.

The Bottom Line

The CBN’s latest rules reflect a decisive shift in Nigeria’s financial priorities: keep cash in, keep fraud out, and keep the banks upright as recapitalisation pressure builds. For fintechs, this means the very engine that drove their explosive growth — cheap cash-in, easy cash-out — is being redesigned into a high-maintenance machine. The regulator believes tougher medicine will produce a safer, more resilient financial system. But as 2026 approaches, the unanswered question is whether the industry can absorb the cost of compliance without draining the innovation and inclusion it was meant to deliver.

Editor’s Note:
 This article was updated to reflect the CBN’s latest 2026 cash-handling circular, including revised withdrawal limits, the removal of cumulative deposit caps, and updated excess-withdrawal fee structures. Clarifications were also added to distinguish the new 2026 rules from earlier policy drafts.