The Central Bank of Nigeria has directed banks, fintech companies, mobile money operators, payment processors, and other payment-system participants to store and manage payment transaction data generated within Nigeria locally. The compliance date is 1st January 2027.
The rule is part of a wider CBN framework covering data localisation, ownership disclosure, market structure, and systemic oversight in the payments industry. Here are five areas affected businesses need to examine.
1. Where Payment Data Is Stored
Data localisation means payment transaction data generated in Nigeria must be stored and managed in Nigeria under the CBN directive.
Payment companies that currently rely on infrastructure outside Nigeria may need to review where their transaction records, databases, backups, and related systems are hosted. This can affect technology architecture and vendor arrangements.
Businesses should map where their payment data currently lives. and identify:
- Primary servers
- Backup systems
- Cloud providers
- Disaster-recovery infrastructure
- Third-party processors
The next step is determining which systems fall within the CBN requirement.
2. Cloud and Data-Centre Arrangements
Payment companies may need to adjust their hosting arrangements to meet the local-storage requirement.
Changing infrastructure is not simply a matter of moving files. Businesses need to consider uptime, cybersecurity, backups, performance, disaster recovery, and the cost of maintaining the new environment. Industry reporting indicates the directive could increase demand for Nigerian data-centre and cloud infrastructure.
Technology teams should review existing contracts with cloud and infrastructure providers. They should compare local hosting options based on:
- Security
- Capacity
- Reliability
- Cost
- Backup arrangements
- Regulatory requirements
3. Data Protection Controls
The CBN directive requires local storage to be carried out in accordance with applicable Nigerian data-protection laws and regulations.
Moving data to a Nigerian server does not automatically make a business compliant. The company still needs appropriate controls for collecting, processing, securing, retaining, and accessing personal and financial information.
Businesses should review:
- Data-access permissions
- Encryption
- Retention policies
- Backup procedures
- Incident-response plans
- Third-party access
Legal and compliance teams should work with technical teams rather than treating the change as only an IT project.
4. Third-Party Technology Providers
Payment businesses often depend on external providers for cloud infrastructure, processing, analytics, security, and other services.
A company may comply internally while a third-party system still stores or processes relevant payment information outside the required environment. The CBN framework therefore makes infrastructure dependencies more important to review.
Create a list of every provider that touches payment data. For each provider, identify:
- What data it receives
- Where it is stored
- Where backups are kept
- Who can access it
- Whether the contract covers the new requirement
5. Compliance Deadlines and Internal Planning
The CBN has set 1 January 2027 as the effective date for the payment-data localisation requirement.
Infrastructure migration can involve procurement, testing, security reviews, system changes, and regulatory checks. Waiting until the deadline approaches could leave little time to fix technical problems.
Payment businesses should create an internal compliance plan covering:
- Data mapping
- Infrastructure assessment
- Vendor review
- Migration requirements
- Security testing
- Staff responsibilities
- Final compliance checks
The CBN has said it will monitor compliance and may impose supervisory sanctions where necessary.
What payment businesses should do now
The 2027 deadline gives payment companies time to assess their infrastructure rather than treating localization as a last-minute migration exercise. The immediate task is to establish exactly what payment data the business handles, where that data currently sits, which third parties have access to it, and what needs to change before 1st January 2027.
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