The first part of this article (published on 2 July, 2026) examines the conceptual underpinnings of the Central Bank of Nigeria’s (“CBN”) new payments framework, focusing on its potential introduction of a form of functional separation within the payments ecosystem. It explores the rationale behind the circular’s restrictions on cross-participation between consumer issuing and merchant acquiring activities, highlighting the CBN’s growing emphasis on market structure and concentration across the value chain. The discussion also addresses key interpretative challenges, including how “consumer issuing” and “merchant acquiring” should be defined in functional terms, and raises the critical issue of market definition, noting that the absence of clear guidance in this area could significantly influence how market share thresholds are understood and applied in practice.
Having examined the conceptual and interpretative issues, the discussion now turns to the operational challenges that may arise in applying the framework in practice, including the measurement of market
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