Nigeria’s Fintech Regulatory Commission Bill: A Fourth Body Nobody Asked For

Nigeria’s House of Representatives held a public hearing on March 2, 2026 on HB.2389 — the Nigerian Fintech Regulatory Commission Bill. The bill proposes…
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Nigeria's Fintech Regulatory Commission Bill: A Fourth Body Nobody Asked For
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Nigeria’s House of Representatives held a public hearing on March 2, 2026 on HB.2389 — the Nigerian Fintech Regulatory Commission Bill. The bill proposes a new specialised body, the NFRC, with authority to license, supervise, and regulate every fintech operating in Africa’s largest financial market. The Central Bank of Nigeria did not send a representative. The fintech sector split on whether the commission would solve their problems or multiply them. Both reactions point to the same underlying issue: Nigeria already has a framework for this, and it is three months old.

In December 2025, Nigeria launched the VARA coordination framework — a deliberate decision to regulate virtual assets and fintech infrastructure through existing institutions rather than new legislation. The Virtual Asset Regulatory Council, co-chaired by the CBN and the Nigeria Revenue Service, was designed precisely to end the problem of fragmented, overlapping supervision. The Fintech Regulatory Commission Bill would introduce a fourth institutional layer on top of CBN, SEC, and FIRS — the three bodies VARA was built to align.

What the Bill Proposes

HB.2389 was sponsored by Hon. Fuad Kayode Laguda of Lagos and passed its second reading in October 2025. The bill would establish the Nigerian Fintech Regulatory Commission, governed by a 14-member board: a chairman, a director-general, six executive commissioners, and six non-executive commissioners — one from each of Nigeria’s six geopolitical zones. The NFRC’s mandate would cover licensing, supervision, and regulation of fintech service providers, and the bill includes provisions for sandboxes, innovation support, and cross-border operations.

The House committee convening the March 2 public hearing brought together the panels on Digital and Electronic Banking, Banking Regulations, Science and Technology, Communications, and Capital Market and Other Financial Institutions — a roster that signals how broad the NFRC’s intended reach is. It would not be a niche regulator for a niche sector. It would be a horizontal body with authority across every fintech product category, from payments to lending to digital assets.

The CBN’s Silence

The CBN did not respond to requests for comment before the public hearing, and did not send a representative to the session. That silence should be read as a position. The VARA framework was the CBN’s preferred institutional architecture: coordination between existing regulators, with the CBN retaining authority over payment-function virtual assets and monetary-system integrity. A standalone fintech commission with an independent mandate is structurally incompatible with that design.

The House moved to reassure the CBN and SEC that the NFRC would function as a “complementary mechanism, deferring to primary regulators in their core areas of responsibility.” That assurance contains no specificity. It does not define which product categories sit with which regulator, how conflicting licensing requirements would be resolved, or which body has enforcement primacy when a fintech falls within multiple jurisdictions simultaneously — which most Nigerian fintechs do.

The absence of a demarcation framework is not a technicality. It is the central flaw. A fintech operating a payment wallet (CBN jurisdiction), offering crypto custody (SEC jurisdiction under ISA 2025), and reporting transactions to FIRS (NTAA 2025 obligation) would face, under the NFRC Bill, the possibility of a fourth licensing requirement from a body whose remit has not been legally bounded relative to the other three. The compliance cost argument made by fintech operators at the public hearing — duplicate licensing, parallel examinations, regulatory uncertainty — is not theoretical. It describes the structural consequence of the bill as currently drafted.

The Support Case

The bill’s supporters are not wrong about the underlying problem. The Association of Telecommunications, Information, Technology, Cable Satellite Network Operators and Allied Services Employers of Nigeria argued that fragmented supervision — the very thing VARA was meant to address — has created compliance gaps and regulatory uncertainty. The argument for a specialised fintech regulator is that fintech products require domain expertise that generalist regulators, built around banking or securities supervision, do not possess.

That is a legitimate institutional design argument, and it is the same argument that has driven fintech-specific regulators in markets like Singapore (MAS’s dedicated payments oversight function) and the UK (FCA’s dedicated fintech unit). The difference is that those models were built as the primary architecture, not grafted onto an existing multi-regulator coordination framework that was explicitly designed as an alternative to specialised new bodies.

What the Comparison Markets Show

Africa’s peer markets have generally moved toward consolidation, not fragmentation. South Africa’s FSCA operates as the single supervisory authority for crypto asset service providers under FAIS, with CASP licensing covering trading, exchange, and custody under one framework. Kenya’s proposed AI regulator notwithstanding, the VASP regulatory model under the Central Bank of Kenya consolidates licensing rather than distributing it. Ghana’s Virtual Asset Service Providers Act 2025 created a single licensing window, even if implementation has been slow.

Nigeria’s VARA White Paper explicitly studied these models before recommending the coordination approach over a standalone regulator. If HB.2389 advances to passage, it will represent a legislative reversal of that institutional reasoning — driven by a parliamentary process that ran parallel to, and apparently without engagement with, the policy architecture the executive branch introduced three months earlier.

What Comes Next

The House committee is reviewing stakeholder submissions from the March 2 hearing before advancing the bill. The CBN’s silence leaves its institutional position formally unregistered, which complicates the committee’s ability to design an NFRC mandate that avoids jurisdictional overlap. Without explicit CBN input on where the commission’s authority ends and theirs begins, the demarcation question will either be resolved by legislative fiat — or left to courts and enforcement disputes to settle after the fact.

For fintechs operating in Nigeria, the practical implication is continued uncertainty. The VARA framework created clarity about who to register with and how. The NFRC Bill reopens that question before the first framework has been fully implemented. The cost of that uncertainty — in compliance planning, investment decisions, and product roadmaps — will not wait for the legislative process to resolve itself.

Related coverage: Nigeria’s VARA Framework · CBN AML Baseline Standards · Nigeria’s FATF Removal

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