Introduction

The Central Bank of Nigeria has turned its attention to the expanding role of non-banking firms in offering credit-like services to consumers. As digital finance accelerates, the regulator's scrutiny highlights a widening gap between innovative business models and existing oversight frameworks.

What Happened

At Nigeria Fintech Week 2026 in Lagos, CBN Governor Olayemi Cardoso, represented by Abiodun Olalekan Okunola, highlighted how non-licensed businesses are increasingly offering "pay small small" instalment options to customers. Using real-world examples such as Air Peace and Wakanow, he illustrated how embedded finance is crossing into credit territory without proper licensing, prompting urgent questions about regulatory accountability.

Why This Matters

When non-licensed firms extend credit, customers may lack clear avenues for redress if their rights are compromised. The CBN's concern centers on accountability gaps and the risk of consumers being unaware of where to seek help during disputes. Furthermore, the rise of embedded finance—driven by customer data and digital platforms—ties this issue into broader shifts like artificial intelligence, open banking, and cross-border commerce reshaping Nigeria's financial ecosystem.

Key Takeaways

  • The CBN has flagged regulatory uncertainty around non-bank instalment credit products offered to Nigerian consumers.
  • High-profile examples such as Air Peace and Wakanow are already providing pay-small-small payment paths across travel and aviation sectors.
  • Consumer protection gaps exist, particularly around where to report grievances involving unlicensed lenders.
  • The Federal Competition and Consumer Protection Commission has registered over 500 digital lenders and enforced rules on lending practices and debt recovery.
  • Embedded finance is becoming mainstream, but without clear licensing frameworks, risks for consumers persist.

Conclusion

As Nigeria's fintech sector accelerates, the CBN's regulatory questions signal a pivotal moment for the industry. Establishing clear oversight for non-bank credit offerings will be essential to protect consumers while sustaining the innovation driving the country's digital finance growth. The coming months will likely reveal whether the central bank moves to formalise rules or continues engaging stakeholders on the path forward.