Disconnecting Switching Companies, PSSPs, Super Agents, and Others from NIBSS Instant Payment (NIP) Outward Transfer Platform


Pamela Victor Ibitamuno, Associate

With immediate effect, Payment Solution Service Providers (PSSPs), Super Agents (SAs), Switching Companies (Switches), and others are to be disconnected from outward payments on the NIBSS Instant Payment (NIP) platform.1 This directive was issued by the Nigeria Inter-Bank Settlement System PLC (NIBSS)  on 6 December 2023 to all Deposit Money Banks (DMBs), Merchant Banks, Switches, Mobile Money Operators (MMOs), Payment Service Banks (PSBs), Microfinance Banks, Mortgage Banks, PSSPs, SAs, and others 

The NIBSS explained that listing non-deposit-taking financial institutions as beneficiaries contravenes the Central Bank of Nigeria (CBN) Guidelines on Electronic Payment of Salaries, Pensions, Suppliers and Taxes in Nigeria.2 Only licensed deposit-taking financial institutions can be listed as beneficiary institutions on NIBSS Instant Payment Platform.

While Switches, PSSPs, and SAs may process outward transfers as inflows to banks, they “are not to receive inflows as their licenses do not permit them to hold customers’ funds.” NIBSS also referred to the circular, “Permissible Services and Products of PSSP Operation in Nigeria”.3

Key Points from NIBSS’s Directive

  1. Contravention of CBN Guidelines: According to NIBSS,  permitting Switches, PSSPs, and SAs to receive customer deposits through NIP contravenes the CBN Guidelines on Electronic Payment of Salaries, Pensions, Suppliers and Taxes in Nigeria dated February 2014. Amongst other provisions of the Guidelines, one of the responsibilities of “Paying Organizations” is to maintain e-payment-enabled accounts with DMBs or Other Financial Institutions and adopt a bank-approved end-to-end electronic payment platform for all forms of salaries, pensions, suppliers, and taxes payment.4 On their own part, DMBs are required to provide paying organizations and beneficiaries with e-payment-enabled bank accounts or any other approved electronic channel that promotes financial inclusion.5 NIBSS’s interpretation of the provision above points to a deliberate restriction of non-deposit taking financial institutions, such as Switches,  PSSPs, and SAs, from receiving customer deposits. 
  1. Restrictions on Inflows for Switches, PSSPs, and SAs: NIBSS’s circular specifies that Switches, PSSPs, and SAs may process outward transfers as inflows to banks but are not allowed to receive inflows directly. Apparently, the licenses that these Switches, PSSPs, and SAs have do not permit them to hold customer funds.
  1. Directive to Delist from NIP Outward Transfer Channels: Financial institutions are directed to delist Switches, PSSPs, and SAs from their NIP Outward Transfer channels only. Inward transfers are not affected by the directive. This means that non-deposit-taking financial institutions such as Switches, PSSPs, and SAs may continue to use the NIP platform for outward transfers “to process payments permitted under their licenses such as Salaries, Taxes, Pensions, e.t.c.”.
  1. Safety of Depositors Funds: For NIP services users, the directive ensures that when transferring funds, funds can only be transferred to institutions duly licensed by the CBN to hold depositors’ funds. According to NIBBS, this measure ensures that only institutions that have met the necessary due diligence standards and requirements are able to receive and hold depositors’ funds.

In effect, this circular imposes restrictions on the roles and functions of Switches, PSSPs, and SAs in the NIP Outwards payments, emphasizing compliance with existing regulations and guidelines. However, platforms that have obtained the appropriate license are not affected by the directive. For example, Kuda Bank, Moniepoint, Opay, and Palmpay are not affected. This includes Abeg Technologies, FairMoney, Paga Tech, and others who have been duly licensed by the CBN to receive customer deposits.

What could have prompted NIBSS to issue this directive?

NIBSS’s directive has been received with mixed reactions.  The directive could have been informed by certain concerns which NIBSS must have considered necessary to address. Generally, it may be aimed at maintaining the stability, security, and efficiency of the financial services ecosystem in Nigeria. Some possible reasons for this directive may include:

  1. Risk Mitigation: The directive may be intended to mitigate risks associated with non-deposit financial institutions, such as Switches, PSSPs, and SAs, handling customer funds. Restricting these operators’ role in receiving inflows directly could be a measure to minimize the potential for financial irregularities in Nigeria towards protecting the integrity of the payment system.
  1. Consumer Protection: NIBBS may be concerned about the need to protect consumers’ interests by ensuring that their funds are handled by entities with the appropriate licenses and adequate regulatory oversight. This is crucial for maintaining trust in the financial system and safeguarding the interests of individual customers as well.
  1. Alignment with Existing Regulatory Guidelines: The directive is an effort to bring the operations of financial institutions, especially FinTechs, in line with established regulatory guidelines, particularly those set by the Central Bank of Nigeria (CBN). Ensuring compliance with these guidelines helps maintain a standardized and regulated financial services environment.
  1. Enhanced Clarity and Consistency: The directive might seek to provide clarity on the roles and responsibilities of different entities within the NIP framework. To avoid doubts and confusion, NIBBS may have considered the need to issue the directive. By delisting certain entities from NIP outward transfer channels, NIBSS could be aiming to create a more consistent and well-defined system for fund transfers.
  1. Upgrading Industry Standards: NIBSS may be working towards raising the overall standards and practices within the financial industry, ensuring that all participants meet certain criteria and operate within the bounds of the licensing regime and established regulations. This can contribute to the overall improvement of the financial sector in Nigeria, boosting trust and confidence in the Nigerian banking and financial system.
  1. Preventing Financial Crimes: Restricting non-deposit financial institutions from directly receiving inflows could be a measure to prevent potential financial crimes, including money laundering and fraud. This aligns with global efforts to combat financial crimes and maintain the integrity of financial systems.

List of Fintechs affected by this directive

A day after the directive was issued by NIBBS, a list of operators who (allegedly) contravene the relevant guidelines was published. Generally, as seen below, most of the major operators in Nigeria’s FinTech space are affected:

Switching and Processing Licence Category

1. Appzone Limited

2. Arca Payments Company Limited

3. Chamswitch Limited

4. Coralpay Technology Nigeria Limited

5. eTranzact International Limited

6. Flutterwave Technology Solutions Limited

7. Habaripay Limited

8. Hydrogen Payment Services Limited

9. Interswitch Limited

10. Network International

11. Paystack Payment Limited

12. Remita Payment Service Limited

13. Teamapt Limited

14. Terra Switching & Processing Company Limited

15. Unified Payment Services Limited

16. Xpress Payments Solution Limited

Payment Solution Service Provider (PSSP) Autorization

1. Afara Partners Limited

2. Angala Financial Technologies Limited

3. Appmart Integrated Limited

4. Appzone Limited

5. Artha Fintech Limited

6. Betastack Technology Limited

7. Bud Infrastructure Limited

8. Callphone Limited

9. Capricorn Digital Limited

10. CBI Technologies Ltd

11. Cellulant Nigeria Limited

12. Centric Gateway Limited

13. Ceviant Payments Nigeria Limited

14. Clane Company Nig. Ltd.

15. Cyberspace Limited

16. Demerge Nigeria Limited

17. Dot Financial Inclusion Technologies Limited

18. Easypay International Limited

19. Egole Pay Limited

20. Ercas Integrated Solutions Limited

21. E-Settlement Limited

22. Eyowo Integrated Payments Limited

23. Fincra Technologies Limited

24. Flutterwave Technology Solutions Limited

25. Fountain Payment Systems Solution

26. Gemspay Limited

27. Global Accelerex Limited

28. Gpay Instant Solution Limited

29. GTP Client Services Limited

30. Hellopay Africa Integrated Service Ltd.

31 ICAD Concord Limited

32 Infiniti Segments Limited

33. Irecharge Technology Innovations Limited

34. Irofit Technologies LimitedD

35. Itex Integrated Services Limited

36. Konetpay Nigeria Limited

37. Kora Payments

38. Leadremit Limited

39. Moneta Technology Ltd

40. Multigate Payment Limited

41. Netapps Technologies Limited

42. Netplusdotcom Nigeria Limited

43. Nomba Financial Services Limited (Formerly Cosmic Intelligence Lab Limited)

44. One Payment Limited

45. Onepipe.Io Services Ltd

46. Parkway Projects Limited

47. Payfixy Nigeria Limited (Formerly Innovate 1 Pay Limited)

48. Paylode Services Limited

49. Paysure Technologies Limited

50. Payu Payments Nigeria Limited

51. Pethahiah Rehoboth International Limited

52. Prophius Limited

53. Qrios Networks Limited

54. Redtech Limited

55. Resident Fintech Limited

56. Rexel Limited

57. Routepay Fintech Limited

58. Saanapay Corporate Investments Management Limited (SAANACORP)

59. Shago Payments Ltd

60. Simplify International Synergy Limited

61. Soft Alliance & Resources Limited

62. Spay Business Solutions Limited

63. Spout Payment Solutions

64. Stanbic Financial Services Limited

65. Swift Link-NZ Global Services Ltd.

66. Teinnovate Capital Limited

67. Unlimint Nigeria Ltd

68. Upperlink Limited

69. Vas2net Technologies Ltd

70. Venture Garden Nigeria Limited

71. Vestrapay Nigeria Limited

72. Voguepay Web Solution Limited

73. Waxed Mobile Nigeria Ltd

74. Waya Multilinks Technologies Limited

75. Woven Finance Limited

Super-Agent Authorization

1. 3Line Card Management

2. 5554 Technologies Limited

3. Accelerex Networks Limited

4. Africa Mama Atm Limited

5. Africave Technologies Limited

6. Airtel Mobile Commerce Nigeria Limited (Airtel)

7. Allstream Information Technology Solutions Limited

8. Angala Financial Technologies Limited

9. Appmart Integrated Limited

10. ATN Wayya Limited

11. Betastack Technology Limited

12. C24 Limited

13. Callphone Limited

14. Capricorn Digital Limited

15. CBI Technologies Ltd

16 Cicoserve Payments Limited

17. Citiserve Limited

18. Clane Company Nig. Ltd.

19. Connectpoint Technology Solutions Limited

20. Crowd Force Limited (Formerly Mobile Forms Limited)

21. Dot Financial Inclusion Technologies Limited

22. Egole Pay Limited

23. Errand P Limited

24. E-Settlement Limited

25. Fountain Payment Systems Solution

26. Fucil Datatech Limited

27. Gwills Payments Service Limited

28. Infibranches Technology Limited

29. Innovectives Limited

30. Interswitch Financial Inclusion Services Limited

31. Irofit Technologies Limited

32. Itex Integrated Services Limited

33. Kadick Integrated Limited

34. Lukeport Nigeria Limited

35. Microsystems Investment And Development Limited

36. Moneymaster Limited

37. Nigerian Postal Service (NIPOST)

38. Nomba Financial Services Limited (Formerly Cosmic Intelligence Lab Limited)

39. Paycluster Technology Limited

40. Paygo Limited

41. Shago Payments Ltd

42. Spout Payment Solutions

43. Swift Link-Nz Global Services Ltd.

44. Traction Payments Ltd.

45. Vatebra Pay Limited

46. Waxed Mobile Nigeria Ltd.

47. Y’ello Digital Financial Services

What could these FinTechs be doing wrong that may have led to being delisted from NIP outward transfer platform?

Generally, only financial institutions licensed to hold deposits are permitted to receive customer deposits under existing regulations. Therefore, NIBBS may reasonably consider the act of the delisted platforms receiving customer deposits as a contravention of applicable regulations. 

Except the CBN approves otherwise, FinTech platforms who receive customer deposits without the required license would be treated as being on the wrong side of regulation.

However, since NIBSS is owned by all licensed banks and the CBN, could NIBSS have considered the option of requiring these licensed banks to closely monitor the activities of Switches, PSSPs, SAs and other non-deposit-taking financial institutions? Possibly. After all, the same licensed banks have various levels of partnerships with these non-deposit-taking financial institutions. So rather than directing outright delisting, regular assessments and reporting requirements can be implemented to ensure compliance with standards and regulatory guidelines.


One could rightly describe the NIP platform as a critical national infrastructure, although it is owned by all licensed banks and the CBN. Considering how critical the platform has become in Nigeria’s banking and financial system, it is imperative that it is adequately protected against abuse. It is therefore understandable that NIBSS has issued a directive to DMBs and others that Switches, PSSPs, SAs, and other non-deposit-taking financial institutions be delisted from the NIP transfer list immediately.

In the same vein, it is important that while we protect consumers we do so in a manner that is not necessarily exclusionary. As stakeholders in the financial services ecosystem, Switches, PSSPs, SAs, and other non-deposit-taking financial institutions play critical roles. They in fact constitute a big chunk of FinTech platforms in the country—and the leading ones at that. Therefore, a win-win and an inclusive approach, where possible, should be considered in the collective interest of all stakeholders. Achieving trust and confidence in an industry as sensitive as the financial services industry is a multi-stakeholder affair. Unplugging FinTech platforms or non-deposit-taking financial institutions from the NIP platform—particularly in the sudden and instant manner directed—does not exactly help to achieve this.

On their own part, FinTech platforms and other non-deposit-taking financial institutions should also proactively engage with regulatory bodies, stay informed about evolving regulations, and ensure that their operations align with established guidelines. Regular compliance audits and a commitment to best practices can help to avoid or minimize regulatory issues that may lead to directives such as the one issued by NIBSS. Indeed, FinTech platforms and other non-deposit-taking financial institutions can also decide to obtain the relevant licenses that will make them eligible to hold customer deposits. For brands that may not be able to do this alone, this is where collaboration—through strategic mergers and acquisitions—becomes an option. At Infusion Lawyers where I am a member of the firm’s FinTech team, I am always happy to work with innovators who need a legal partner for professional guidance.

Image source: ThisDay

  1. Full List of PSSPs, Others NIBSS Ordered Banks to Remove from Transfer List by Dipo Olowookere (December 7, 2023) https://businesspost.ng/banking/full-list-of-pssps-others-nibss-ordered-banks-to-remove-from-transfer-list/
  2. CBN Guidelines on Electronic Payment of Salaries, Pensions, Suppliers and Taxes in Nigeria, February 2014, https://www.cbn.gov.ng/out/2014/bpsd/guidelines%20on%20electronic%20payments%20of%20salaries,%20pensions,%20suppliers%20and%20taxes%20in%20nigeria.pdf
  3. Permissible Services and Products of PSSP Operation in Nigeria, CBN, May 11 2018
  4. Section 4.1 of CBN Guidelines on Electronic Payment of Salaries, Pensions, Suppliers, and Taxes in Nigeria
  5. Section 4.3 of CBN Guidelines on Electronic Payment of Salaries, Pensions, Suppliers, and Taxes in Nigeria

Leave a Reply

Your email address will not be published. Required fields are marked *

Back to top