ABA Editorial Board · Dec 8, 2025 · 9 min read
Nigeria went live with formal open banking on 1 August 2025, becoming the first African country to do so. The fanfare was considerable. Our view is that the framework, as currently implemented, will underperform its own ambitions by a significant margin over the next three years. The reasons are structural, not political.
Nigeria's Central Bank made history on 1 August 2025 when the country became the first African economy to implement a formal open banking framework. The technical infrastructure was built. The Bank Verification Number (BVN) consent layer was wired in. A handful of early API provider banks (FCMB, Sterling, Sparkle, Wema) made their data available. Industry advocates, led by Open Banking Nigeria and Adedeji Olowe, took a well-earned victory lap. We share the respect for what was accomplished. We also think the framework will underperform its own ambitions over the next three years, and we think the reasons for that underperformance are structural, not political.
Senior practitioners who have built API infrastructure at scale in Nigeria have been consistent on one point: the August 2025 go-live was a regulatory milestone, not an operational one. The CBN framework requires banks to expose standardized APIs. It does not require those APIs to be fast, well-documented, well-governed, or useful. Conversations with fintech engineering leaders in Lagos suggest that the early-adopter banks' APIs have uneven latency, inconsistent error handling, and limited transaction-level depth. The banks that were enthusiastic about open banking before the mandate (FCMB, Sterling, Wema) have built reasonable implementations. The banks that complied reluctantly have built the minimum viable implementation the framework requires.
This gap between regulatory mandate and operational quality is not unique to Nigeria. Every open banking framework on record, including the UK's PSD2 implementation that is often cited as the global benchmark, went through a multi-year period where the APIs existed on paper but barely worked in practice. The difference is that in the UK, regulators actively enforced quality standards and fintech challengers had enough commercial leverage to force laggard banks to improve. Neither of those conditions fully applies in Nigeria.
The collapse of Okra in May 2025, three months before the open banking go-live, has been framed in industry commentary as a tragic case of a pioneer who arrived too early. We think that framing is comforting but wrong. Observers familiar with Okra's commercial struggles consistently point out that the company's core problem was not regulatory timing. It was that the market for paid API access to Nigerian bank data was never going to generate the revenue per customer that Okra's capital stack assumed. Mono, which survived where Okra did not, did so partly through capital discipline but mostly by monetizing narrower, deeper integrations with Mastercard-branded products rather than trying to be a horizontal infrastructure layer.
If the Okra lesson is "open banking needed regulatory backing to work," then the CBN framework solves the problem. If the Okra lesson is "African fintechs cannot pay enough for bank data access to sustain a standalone infrastructure business," then the CBN framework does not solve anything. It simply shifts the cost from bilateral bank integration to API consumption fees, which the surviving API aggregators will still need to charge fintechs who already operate on thin margins.
The most technically interesting part of the CBN framework is the BVN-linked consent management system. Senior fintech product managers we have heard from have been polite but skeptical about whether this consent layer is ready for the volume it will see. Consent registries are notoriously hard to build well. They need to handle revocations cleanly, expose audit trails that regulators can actually use, cope with edge cases like joint accounts and business accounts, and provide user interfaces that ordinary Nigerian customers can understand without pulling in a customer service representative. The consent architecture described in the CBN framework documents is adequate on paper. How it performs under scale will determine whether Nigerian open banking produces a trust crisis within two years of launch.
Our specific prediction is that by the end of 2027, the number of Nigerian fintech products actively consuming live open banking APIs at scale will be substantially smaller than industry advocates are currently forecasting. Mono and Stitch will continue to serve their commercial customers, largely through pre-existing integrations. A small number of challenger banks will use open banking APIs to build account-aggregation features. Consumer-facing open banking use cases (personal financial management apps, automated lending underwriting based on bank statement data) will exist but will not reach mass adoption in the 2026-2027 window the CBN framework was designed to enable.
This does not mean the framework was a mistake. It means the framework is necessary but not sufficient. The additional conditions for success (bank API quality, fintech commercial viability, consumer consent trust, enforcement of standards) are harder to build than the framework itself, and they take longer than the promotional timelines suggest.
Three developments would cause us to update. First, evidence that the CBN is actively enforcing API quality standards against laggard banks rather than treating the framework as a box-ticking exercise. Second, commercial success by at least one fintech operator that built its entire product on top of the open banking APIs, rather than retrofitting existing integrations. Third, a consent management system that handles at least ten million active consents with measured trust from ordinary Nigerian customers. None of those three things has happened as of early 2026. If they happen by the end of 2027, we will revise our view upward. Until they do, we think the quiet conversation among Nigerian fintech operators is the one worth listening to: the framework is live, the plumbing is uneven, and the products that will use it are still mostly on the whiteboard.