If you look at the slide deck of any bullish emerging market VC, Lagos is the promised land. The stats are intoxicating: 11 billion real-time transactions a year, four unicorns, and a permanent seat at the “Big Three” table of African tech.

But if you look at the operations dashboard of an actual Lagos-based founder, the story is less “hockey stick growth” and more “administrative endurance test.”

A new, surprisingly candid 34-page report from the Central Bank of Nigeria (CBN) — titled “Shaping the Future of Fintech in Nigeria” — pulls the curtain back on this disconnect. Based on closed-door workshops and surveys with fintech executives, the document reads less like a victory lap and more like a therapy session.

It paints a picture of an ecosystem that has mastered the art of the launch announcement but is still struggling with the unsexy machinery of execution. Here are the unspoken realities of running a fintech in Africa’s largest economy.

The “hurry up and wait” product cycle

In Silicon Valley, the mantra is “move fast and break things.” In Lagos, it appears to be “move fast and wait 12 months for a letter.”

The most bruising stat from the CBN’s report is this: 37.5% of fintech companies say it takes over a year to bring a new product to market. To be clear, that isn’t the time spent coding or beta testing — that is the time spent waiting for regulatory approval to launch.

Another 25% of founders report timelines of six to twelve months. Only a fortunate 12.5% can ship in under a quarter.

For a sector predicated on speed, this is a distinct competitive disadvantage. While a Nigerian startup sits in a regulatory queue, competitors in more agile jurisdictions can iterate a product three times over. Investors, who are already twitchy about African risk, find their patience tested not by market dynamics, but by inbox silence.

The survey reveals a telling split in sentiment: exactly 50% of respondents find the regulatory environment “supportive,” while the other 50% find it “restrictive.” In a rules-based system, that split shouldn’t exist. It suggests that success in Nigeria often depends less on the clarity of the guidelines and more on which officer picks up your file.

Policy rich, implementation poor

To be fair to the Nigerian regulators, they are prolific writers. The country is drowning in frameworks.

There is a Payments System Vision 2025, comprehensive AML regulations, a Cybersecurity Framework, Open Banking Guidelines, and a Regulatory Sandbox. The problem, as the CBN admits with rare benignity, is that these documents often live better on PDF than in practice.

Take the Global Standing Instruction (GSI). Launched in 2020, this policy was supposed to be a lender’s dream, allowing them to claw back loan repayments from a defaulter’s accounts at any bank. Five years later, the report describes the rollout as “incomplete,” with full implementation pushed to 2026.

Or look at Open Banking. The operational guidelines arrived with fanfare in 2023. Yet, the report notes that the API landscape remains fragmented, data-sharing protocols are inconsistent, and universal service standards are effectively non-existent.

It’s a recurring theme: Nigeria has world-class rules, but third-world enforcement. The Start-up Act was meant to fix multi-agency coordination; the report admits it has “struggled.” The result is a sophisticated legal framework that often feels purely theoretical to the engineers trying to build against it.

The AI is for the fraudsters, not the chatbots

While the rest of the world debates whether AI will write our poetry, Nigerian fintechs have a more pragmatic use for it: stopping thieves.

An overwhelming 87.5% of surveyed companies use AI primarily for fraud detection. Customer service chatbots (62.5%) and credit scoring (37.5%) are distant seconds.

This isn’t a choice; it’s a tax on innovation. The report bluntly notes that a “significant share” of digital financial crimes are orchestrated by cross-border actors using Nigeria as a proxy. This fraud burden forces startups to divert massive resources — talent, compute power, and capital — away from product development and into digital policing.

The reputational cost is just as high. Nigeria’s recent stint on the FATF “grey list” strangled cross-border partnerships. While the country was removed from the list in 2023 — a milestone the CBN celebrates — it was largely a remediation of failures rather than a new achievement. For Nigerian founders, “compliance” isn’t a department; it’s the biggest line item on the budget.

The regulatory alphabet soup

If you want to run a fintech in Nigeria, you need to be a diplomat as much as a CEO.

The regulatory landscape is a turf war. The CBN watches the money. The Nigerian Communications Commission (NCC) watches the telcos (who own the Payment Service Banks). The National Information Technology Development Agency (NITDA) watches the data.

The friction is palpable. 62.5% of companies are crying out for a “Compliance-as-a-Service” utility — essentially a plea to stop making them report the same data to three different agencies in three different formats.

The report invites stakeholders to share examples of “egregious regulatory overlap.” It is a polite way of asking, “Who exactly is making your life miserable today?” — an admission that the coordinating bodies currently in place don’t actually know where the friction lies.

The capital drought hit hard

The era of easy money is over, and Nigeria is feeling the chill.

In 2019, Nigerian startups hoovered up 37% of all African funding ($747m). By 2024, despite the global ecosystem growing, Nigeria’s haul dropped to $520m.

The issue is structural. There is almost no domestic venture capital base. The ecosystem relies on foreign USD, meaning every investment is a gamble on both the startup’s execution and the Naira’s stability. That is a double-risk exposure that scares off all but the bravest capital.

The industry’s proposed solution? A government-backed fund. nearly 90% of respondents want a fintech-specific growth fund or credit guarantee scheme. The CBN says it can’t launch a VC fund (wisely), but might “convene stakeholders.” In corporate speak, that means a lot of meetings are coming, but the chequebook remains closed for now.

The financial inclusion paradox

Nigeria’s fintech narrative is built on “banking the unbanked.” The reality is slightly more awkward.

Despite a decade of mobile money and agent banking, 26% of Nigerian adults remain financially excluded. In the North, that figure hits 47% — nearly half the population.

The report highlights a brutal economic truth: serving the poor is expensive. The “cost of last-mile delivery” combined with ultra-low transaction fees makes rural expansion commercially unviable. Founders know this, which is why they stay in Lagos.

Furthermore, the infrastructure for inclusion — digital identity — is a mess. 37.5% of fintechs cite the lack of credit history or ID as their biggest barrier. The data exists (in the BVN and NIN systems), but accessing it is plagued by downtime, fragmentation, and high API costs. One executive complained about paying a global consultant huge fees just to access Nigerian data that should be a public utility.

The “Detty December” stress test

Every December, the Nigerian diaspora returns home, spending surges, and the banking rails melt down.

The report treats these “Detty December” failures as a case study in resilience. Users face unexplained transaction failures during critical moments, eroding trust. The survey on resilience was split 50/50, but the anecdotes were telling. Settlement limits haven’t been adjusted for inflation in nearly a decade, and stress testing is virtually non-existent.

The industry’s suggestion? Scheduled maintenance blackouts and real-time dashboards. Basic operational hygiene, in other words, that seems to have been overlooked in the rush to scale.

The Launch Base Africa take: A moment of clarity?

The Central Bank of Nigeria deserves credit for this report. It is rare for a regulator to publish a document that essentially lists its own implementation failures alongside industry complaints. It offers validation to every founder who has ever screamed into a pillow after a meeting in Abuja.

But validation doesn’t pay the payroll.

The report proposes ten priority policies — sandboxes, single-window regulation, engagement forums. They are the right ideas. But in Nigeria, the gap between a “priority policy” and a working system is often measured in years.

For investors and founders, the message is clear: The “unspoken” sides of Nigerian fintech are finally being spoken. The question now is whether anyone has the political will to actually fix them.

Key Takeaways for Investors

• Patience Premium: Factor in a 12-month delay for any new product launch requiring regulatory approval.
• Fraud Tech is Key: Due diligence should focus heavily on a startup’s fraud detection stack; it’s mission-critical, not a nice-to-have.
• The pivot to B2B: With consumer inclusion proving expensive and difficult, expect more pivots toward “Compliance-as-a-Service” and infrastructure plays that solve the regulatory mess for others.
• Currency Exposure: The lack of domestic capital means reliance on foreign funds will continue, keeping currency risk front and center.