CENTRAL BANK OF NIGERIA (CBN) ISSUES NEW DAILY CASH WITHDRAWAL LIMITS AND UPDATED AGENT BANKING GUIDELINES.

The Central Bank of Nigeria (CBN) has issued a new directive regulating cash-based transactions and the operation of agent banking nationwide. The new directive, Guidelines for the Operations of Agent Banking in Nigeria, was released on the 6^th day of October 2025 via a Circular to All Deposit Money Banks, Other Financial Institutions, and Payment Service Providers, Ref: PSP/DIR/CON/CWO/001/049. It replaces aspects of the 2013 Guidelines for the Regulation of Agent Banking and Agent Banking Relationships in Nigeria, introducing new operational limits, exclusivity rules, and compliance obligations.

Definition of Key Stakeholders

Paragraph 2.0 of the guidelines provides the official definition of stakeholders as recognized under the document:

1. Principal: A duly licensed deposit-taking Financial Institution (FI), authorized to carry out Agent banking activities
2. Super-Agent: An Incorporated Entity Licensed by the CBN to carry out the sole permissible activity of Recruiting, aggregating, and managing agents.
3. Agent: An individual or eligible non-individual or through a Super-Agent, to provide part or all the services listed in Section 3.0 on behalf of a Principal.
4. A non-individual is an entity that operates businesses such as the sale of confectionery and Fast-Moving Consumer Goods (FMCG), petrol stations, restaurants/bars, parks and recreation centres, fashion and beauty outlets with a registered place of business, and any other venture which the CBN may authorise from time to time.

The New Legal Framework

Agent banking remains an essential instrument of financial inclusion in Nigeria. However, rapid expansion has raised concerns about fraud, poor supervision, and inconsistent operational standards.The Guidelines outline the minimum regulatory standards for agent banking operations to:

1. Strengthen financial inclusion by expanding agent-based financial services.
2. Promote market discipline and consumer confidence; and
3. Ensure compliance with prudential and anti-money laundering and relevant extant AML/CFT/CPF regulations.

Agent Banking Relationships: Agent Exclusivity and Super Agents:Paragraph 4.0 introduces exclusivity; each agent may now serve only one principal financial institution, formalized through a written Agent Banking Agreement. This represents a major departure from the 2013 Guidelines, which permitted multi-principal arrangements subject to the CBN’s no-objection. Furthermore, while the circular takes effect from the date of release, implementation and agent exclusivity must be implemented with effect from 1^st of April, 2026.

Paragraph 4.4 provides that while Agents can only belong to the network of one Super-Agent at any given time, a Super-Agent, however, may be contracted by more than one Principal and in each case shall be required to execute an agency contract with each Principal.

Non-Permissible Activities: Under paragraph 3.2 of the guidelines, the following activities are classified as non-permissible activities:

1. Super Agents undertaking Agent banking activities;
2. Agents carrying out banking services, including but not limited to customer  account opening, loan underwriting, investment, and forex services;
3. Delegation of permissible activities of an Agent to another entity or individual
4. Use of non-human/automated machines as Agents;
5. Any other activity that the CBN may deem as non-permissible from time to time.

Training and Operational Requirements: Paragraph 8.4.2 requires every principal to provide mandatory training programs for their appointed agents covering: responsibilities, KYC regulations and customer registration requirements, transaction processes, prohibition of transacting on behalf of customers, reporting fraudulent transactions (AML & CFT guidelines), consumer protection laws and implications for non-compliance, amongst others. The frequency of such training by the principal/super-agent shall be at least biyearly.

Designated Account or Wallet: Pursuant to Paragraph 10, all agent banking transactions must be conducted through a designated account or wallet assigned by the Principal. PoS terminals must be linked solely to that account/wallet, and transactions conducted outside the approved channel will constitute a violation of the Guidelines. Agents that violate these provisions shall be considered personally liable for any issue that arises from such transaction, and may be blacklisted or barred from further participation.

Adequate Notification of Relocation and Closure of Agent Premises:Paragraph 10.2 requires Principals to publish lists of their registered agents and branches across all geopolitical zones for transparency. A Super-Agent shall have fifty (50) or more Agents spread across the geo-political zones of the country. Paragraph 10.3 (iii) further provides that no Agent shall relocate from, transfer, or close its Agent banking premises without prior notice and approval of the Principal. Also, agents must notify their principals at least 30 days prior to relocation and display a notice of relocation prominently throughout the notice period. This measure ensures that agents remain easily traceable and that customers are adequately informed of any change in the agent’s business location.

Under paragraph 10.10(iii), agents are required to conspicuously display at their premises the name and logo of the principal, the letter of appointment, applicable fees, agent banking services offered, and the principal’s dedicated telephone number for complaints.

Technology and Transparency:Paragraph 10.5 requires the technology implemented by the Principal for agent banking operations to comply with relevant industry ICT standards. The technology must allow seamless transactions, and each transaction that the agent does with a customer must generate a receipt for successful transactions, as well as alerts on the customer’s device showing the agent’s name and the geo-coordinates place of transaction. In the event of failure of technology during a transaction, immediate reversal is mandatory. These measures are designed to promote transparency, strengthen consumer protection, and improve traceability within Nigeria’s agent banking ecosystem.

Transaction Limits and Scope

Paragraph 11 of the Guidelines provides that:

1. Individual customers are limited to ₦100,000 daily and ₦500,000 weekly for both cash deposits and withdrawals.
2. Individual customers are limited to ₦100,000 daily and ₦100,000 weekly for bill payment.
3. Each has an overall ₦1,200,000.00 daily transaction ceiling, and every principal to the agent must ensure that the agent does not exceed this limit.

Implications of the New Guidelines

Compliance and Enforcement: Agents now operate directly within the CBN’s supervisory scope. Any breach of exclusivity, limit thresholds, or record-keeping obligations exposes both the agent and its principal to enforcement action. Sanctions may include suspension, monetary penalties, or revocation of agency rights

Contractual Obligations; Agent Banking Agreements must now explicitly incorporate CBN-mandated clauses, exclusivity, training obligations, operational limits, and termination procedures. Failure to align contracts could create non-compliance exposure for principals

Impact on Small Businesses and PoS Operators: Most operators are small-scale entrepreneurs functioning as micro-agents. The exclusivity clause and transaction cap may reduce profitability or compel re-registration under a single principal, affecting market competition.

Consumer Protection: Customers now benefit from enhanced traceability and mandatory receipts. However, the reduced transaction limits may inconvenience customers who rely on agents for large transactions, leading to longer queues and reduced convenience, especially in rural areas where agent banking has driven financial inclusion.

Reduced Income Potential: The ₦1.2 million daily transaction cap limits how much agents can earn. Since agents depend solely on transaction commissions for income, these limits could significantly reduce profitability, discourage participation, and possibly increase unemployment among operators.

Network Reliability for Transactions; Most PoS operators rely on multiple banking platformsto ensure transaction stability by switching between networks. Limiting agents to only one principal may therefore lead to service disruptions, longer transaction delays, and reduced customer satisfaction, especially in rural or low-network areas where connectivity is inconsistent. This exclusive principal rule could thus pose a significant operational challenge for agents who depend on flexibility to keep transactions running smoothly.

In conclusion, the CBN’s new Agent Banking Guidelines represent a decisive move toward regulatory accountability and fraud prevention within Nigeria’s expanding digital finance sector. While these reforms are necessary for a safer, more transparent financial system, implementation must be balanced and inclusive to avoid stifling innovation or discouraging small-scale operators. A phased adoption strategy, combined with regulator-operator consultations, will be crucial to ensure that the CBN’s objectives are achieved without undermining financial inclusion, the very goal agent banking was designed to serve.