The Nigeria Inter-bank Settlement Systems PLC (NIBSS) just launched the NQR Payment Solution, interoperable across the Nigerian finance system and affords the quickest payment solution. We are delighted to have been a part of this innovative development and deployment of the Universal QR Code payment solutions to the Nigerian financial infrastructure.

The central bank of Nigeria (CBN) in January of 2021 released the framework for Quick response code (QR code) payments in Nigeria. This comes as a continued effort by the CBN to ensure the stability of the financial system and adopt modern technology in facilitating electronic payments and digital payment systems.

The Universal QR code payment systems have become more prominent and acceptable globally, especially in the wake of the ravaging Covid 19 pandemic which further underscores the need to adopt innovative payment methods aimed at significantly reducing human contact in payment processes. We provide a cursory overview of the NQR and the QR code framework and its key provisions.


The Nigeria QR code (NQR) with local and global interoperability standards and powered by NIBSS for and on-behalf of the Financial Services industry in Nigeria, is a secure QR code based payments and collections platform engineered for merchants and customers to receive and make payments for goods and services.


The CBN defines QR codes as a kind of matrix barcode representing information presented as square grids, made up of black squares against a contrasting background that can be scanned by imaging device, processed and transmitted by appropriate technology.

These codes can be used to present, capture and transmit payments information across payments infrastructure.

Basically, QR code payment technology adopts the use of barcodes that when scanned by imaging devices with such capabilities eg. Apple, Microsoft and Android phones, will be able transmit to payment information of any variety as programmed into the code. Think of it this way, using the QRCODE payment system, you could easily go to a supermarket with products outfitted with the requisite barcodes, scan with your phone camera and it immediately directs you to a link containing the payment information of the product and providing a payment gateway, this is just one instance of the use of the technology. The technology itself enables mobile channels to facilitate payments and presents another veritable avenue for promoting electronic payments for micro and small enterprises, as it provides an easy alternative to the use of POS machines or ATM cards.


The CBN’s framework provides for the implementation of QRCODE payments in Nigeria, participants and their duties, interoperability, risk management and sanctions and also dispute resolution. The principal aim of the framework being not only to regulate the usage of this payment system but also to ensure that only safe and efficient standards are adopted in its usage. The CBN framework mandates that all participants should ensure that QR code schemes are fully interoperable in Nigeria

The Implementation of QR Code for payments in Nigeria will fall under any of 4 different specifications:

  1. QR Code Payments in Nigeria shall be based on the Europay, Mastercard and Visa QR Code Specification for Payment Systems;
  2. The Bank may also approve the implementation of any other QR Code Standard, provided it meets the prescribed security requirements within the framework, demonstrates interoperability with other existing implementation in the industry and/or cost benefits to end-users (merchants and customers);
  3. QR Code Payments implementation in Nigeria shall support account, wallet, card and token based QR Code Operations;
  4. Implementation of QR Code for payments in Nigeria shall be based on the Merchant-presented mode (where merchants present the QR Code for buyers to accept in order to conclude payment transactions) specification;


Parties who opt to use the QR code payment systems are referred to as participants and are each granted a series of responsibilities under the framework to regulate their use of the payment system.

Participants in QR Code Payment in Nigeria include;

  1. Merchants
  2. Customers
  • Issuers (Banks, MMOs and Other Financial Institutions)
  1. Acquirers (Banks, MMOs and Other Financial Institutions)
  2. Payments Service Providers

Merchants; Are individuals or corporate organizations who trade goods or provide services to customers. their use of QR code payments systems are guided by extant CBN provisions and their responsibilities under the framework are thus;

  1. Use and display only approved QR Codes in Nigeria;
  2. Comply with service agreements executed with the acquirer;
  3. Cooperate with acquirer to investigate any reported fraudulent transaction;
  4. Report suspicious use of QR Codes for payments to the acquirer;
  5. Conform to the rules and regulation of the acquirer;

Customers; these are consumers of goods and services, they may either be individuals or corporate bodies, under the framework, they shall;

  1. Use QR Code payments applications availed by the issuer and for intended purpose without modifications, at merchant locations/websites/applications;
  2. Consumer shall adhere to all minimum security guidelines as stipulated by the issuer;
  3. Report inappropriate/unauthorized QR Code Payment transaction on their accounts/wallets.

Issuers; examples of issuers are Banks, MMOs and Other Financial Institutions, they are mandated tol:

  1. Provide QR Code Payment application to customers upon request and activation by customer;
  2. Execute service agreement with their customers;
  3. Comply with Card Scheme Rules (where applicable);
  4. Determine and agree appropriate transaction limits with customers for QR Code Payments based on their customers’ risk profile assessment;
  5. Ensure appropriate configurations on QR Code Payment application that use QR codes for payments in conformity and compliance with requirements of QR Code regulations;
  6. Deploy necessary updates and patches on its QR Code Payment application and ensure the customer is unable to initiate transaction through the older version of the application where the customer fails to apply the update within 14 days of the availability of the update or patch;
  7. Without prejudice to (f) above, issuers may induce an automatic update of the customer’s application where applicable;
  8. Provide adequate training, support and security guidelines to customers on the use of QR code for payments;
  9. Ensure security of QR Code payment application for QR Code payments;
  10. Resolve customers dispute in accordance with the CBN Consumer Protection Regulation.
  11. Be guided by the extant CBN Guidelines on Electronic Payments Channels in Nigeria, Guide to charges by banks, other financial and nonbank financial institutions, and other applicable regulation as may be issued by the Bank.

Acquirers; are the financial institution engaged by merchants to receive payments on its behalf, their responsibilities are to;

  1. Execute service agreement with merchants;
  2. Determine and agree appropriate transaction limits with merchants for accepting QR Code Payments based on its risk profile assessment of the merchant;
  3. Ensure appropriate configurations and use of QR codes at Merchant location/website/applications in conformity and compliance with requirements of QR Scheme(s) and QR Code regulations;
  4. Ensure that appropriate security protocols are applied.
  5. Provide adequate training, support and security guidelines to merchants on the use of QR code for payments;
  6. Ensure that hardware, software, protocols used for QR Code for payments are in conformity with the requirements of operations of QR Code payments regulations;
  7. Give merchants value for QR Code transaction within T+1 or as may be agreed with the merchant;
  8. Be guided by the extant CBN Guidelines on Electronic Payments Channels in Nigeria, Guide to charges by banks, other financial and non-bank financial institutions, and other applicable regulation as may be issued by the Bank.

Other Payments Service Providers (Switches & PSSPs) these are institutions that are engaged to interface and facilitate smooth/ seamless payment systems, the framework requires them to;

  1. Support processing and settlement for all issuers and acquirers;
  2. Facilitate interoperability of QR Code Payments for all issuers and acquirers;
  3. Ensure full compliance with this Framework and other extant guidelines on electronic payments and transaction processing.


All consumer disputes arising from the framework and implementation of QR code payment systems shall be resolved in accordance with the CBN consumer protection regulation. Participants and Parties are expected to wholly comply with the provisions of the framework and other extant provisional guidelines issued by CBN any infringements will be sanctioned by the CBN at its discretion.

In conclusion, financial technology is rapidly increasing in the world, payment solutions are expected to be unique and hassle free. The advent of the pandemic has made e-payment solutions such as this a necessity rather than a luxury and with Nigeria aiming to compete in a global market, it is extremely pertinent that businesses have access to unique payment solutions.

Within, the e-commerce space, stores like Amazon has employed automatic barcode scanning systems which enable customers to be able to shop and are automatically billed once they lift an item at their store. This is a foremost example of the numerous adaptations of the QR code payment system. We expect that the CBN will continue to regulate and provide guidelines that foster advancement of the application of this new technology.

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Mani Ojeah
Managing Partner,
Manifield Solicitors.