The question in Nigerian policy circles has quietly flipped from whether the country can build a full Open Finance regime to whether it can afford not to.
Nigeria has spent a decade building some of the continent’s most admired financial rails, instant transfers, a fast-growing base of digital identities, and a fintech sector that international investors now study as a case model. Yet, the country’s financial data still behaves like it belongs to another era: locked in silos, repeated at every counter, and invisible to anyone outside the institution who first collected it.
Open Finance is the policy answer taking shape to that contradiction, and no single regulator can license it into existence. It is closer to a piece of national infrastructure like roads, electricity or digital identity except that instead of moving people, power or paperwork, it moves economic information. Getting it right will require eight separate institutional mandates to move in step: the Central Bank of Nigeria (CBN), the Securities and Exchange Commission (SEC), the National Insurance Commission (NAICOM), the National Pension Commission (PenCom), the Nigeria Data Protection Commission (NDPC), the Federal Competition and Consumer Protection Commission (FCCPC), the National Identity Management Commission (NIMC), and the Nigeria Inter-Bank Settlement System (NIBSS).
The cost of silos, counted
The case for urgency rests on numbers Nigeria already knows well: a population above 200 million, the largest fintech ecosystem on the continent, rising digital identity coverage anchored by NIMC, and payment volumes that continue to climb. Yet financial data remains fragmented,held separately by banks, insurers, pension administrators, capital market operators, credit bureaux and tax authorities, each seeing only a sliver of the same customer.
The consequences of that fragmentation show up everywhere: as duplicated Know-Your-Customer checks at every new institution a customer touches; as thin-file borrowers who are creditworthy in practice but invisible on paper; as fraud that slips through because no single institution holds a verified, shared view of identity or behaviour; and as fintech innovation that is slowed because each new integration into a bank or insurer has to be negotiated and built from scratch.
Open Finance proposes a different premise entirely: that the customer, not the institution, owns the data. Banks, insurers and pension funds become custodians rather than owners, and information moves only with explicit, granular, time-bound and revocable consent, logged and auditable, so both regulators and customers can see who has accessed what and why.
Not the same as Open Banking
Open Finance is a considerably larger undertaking than Open Banking, the API-driven sharing of bank account and payment data that Nigeria, like the UK before it, has already set in motion with Africa’s first open banking regulatory framework issued in 2021, operational guidelines in 2023 and a phased go-live now rolling out through 2026. Open Finance extends that logic across insurance, pensions, capital markets and credit, covering full financial life data, rather than just transaction histories, and necessarily draws in multiple regulators acting in coordination rather than one payments authority acting alone. The prize, correspondingly, is bigger, economy-wide gains in inclusion, competition and productivity, well beyond payments efficiency.
Other jurisdictions have already sequenced this journey in instructive ways. The United Kingdom mandated open banking through its CMA9 order and is now evolving toward smart data and open finance. Brazil phased its own rollout under the central bank, folding investments in stages while insurance and pensions advanced under its insurance regulator before the two tracks were made interoperable. India built a consent-based account aggregator framework that extends data flows across financial sectors without requiring a single dominant platform. Australia’s Consumer Data Right began in banking and has since extended into energy, with non-bank lending slated to follow from 2026. Singapore’s SGFinDex, arguably the most citizen-facing model on the list, gives individuals a single consolidated view of their accounts across banks, insurers and government agencies. Nigeria does not need to choose one template wholesale. It can borrow the sequencing discipline of Brazil, the neutral-aggregator model of India, and the trust-building instincts of Singapore.
What it could unlock
Look sector by sector, and the gap between fragmented data and a functioning open finance layer becomes concrete. Farmers, largely invisible to formal credit and insurance markets today, could be underwritten using shared cooperative and trade records combined with satellite and weather data. Small businesses, which make up the bulk of Nigeria’s economy, could move from collateral-based lending toward cash flow-based lending, using verified transaction histories to access invoice financing and working capital. Women running informal enterprises could convert savings-group and trade-credit activity into a usable credit history. Young Nigerians without long employment records could build a financial identity from verified skills, training and alternative data rather than waiting years to accumulate a traditional credit file. And the government itself stands to gain: pre-populated tax filings, faster business registration, and social interventions that reach verified recipients rather than leaking to fraud.
Naming the risks honestly
None of this is free of hazard. Twelve categories of risk deserve scrutiny before any regime is built. Nine are named in breath: cybersecurity, privacy, financial crime, algorithmic bias, consent fatigue, cross-border data flows, operational resilience, third-party dependency and digital exclusion. The final three are subtler. Aggregated data can re-identify individuals even when each contributing source seems harmless on its own. Concentration in a handful of API providers or data aggregators creates new single points of failure that did not exist when institutions operated in isolation. And interconnection itself can transmit shocks faster across sectors that were previously walled off from one another. Naming these risks honestly is precisely what makes a regime durable rather than fragile.
The governance question
The central tension is this: eight institutions (seven regulators and one shared infrastructure operator)s, each with a clear and legitimate mandate will all need to act in concert on licensing, consent standards, consumer redress, data security and cross-border data flow. CBN holds the mandate on payments and banking data, SEC on capital markets disclosure, NAICOM on insurance data standards, PenCom on pension portability, NDPC on consent and cross-sector enforcement, FCCPC on competition and consumer protection, NIMC on the identity layer underpinning everything, and NIBSS on shared payment infrastructure. Three governance models could plausibly coexist rather than compete: a Joint Oversight Committee to set policy, a Lead Regulator Model to handle day-to-day supervision, and a shared supervisory technology (SupTech) platform giving every agency real-time visibility into the same data.
A roadmap to 2030
Rather than treat Open Finance as a single switch to flip, a credible build looks like a five-pillar, phased programme running from 2026 to 2030 resting on governance, technology, regulation, industry collaboration and citizen trust. It begins with a joint governance charter and common API standards in 2026, moves through sector-by-sector onboarding of insurance, pensions and capital markets by 2028, and arrives at a matured, cross-sector ecosystem with measured outcomes by 2030.
The stakes are best understood by analogy. Roads connect places. Electricity powers businesses. Digital identity identifies citizens. Open Finance connects economic information and, in doing so, becomes national economic infrastructure in its own right. Countries will increasingly compete not solely on capital, but on how intelligently information moves through their economies. For Nigeria’s regulators, banks and fintechs, that is less a forecast than an invitation: the plumbing is technically within reach; what remains is the harder work of coordinated trust.
Prof. Nkemdilim Iheanachor, a Professor of Strategic Management at Lagos Business School makes the case for Open Finance as national economic infrastructure. It examines why Nigeria’s financial data remains fragmented despite world-class payment rails, what a coordinated regime across the CBN, SEC, NAICOM, PenCom, NDPC, FCCPC, NIMC and NIBSS would unlock for farmers, SMEs and young Nigerians, and proposes a phased roadmap to 2030. With the CBN’s open banking rollout now moving through 2026, the timing is squarely in the news cycle.
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