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PoS geo-tagging: CBN sets N5 million minimum penalty

The Central Bank of Nigeria (CBN) has tightened regulation on agent banking by mandating geo-tagging (or geo-fencing) of Point of Sale (PoS) terminals and introducing a minimum penalty of N5 million, with an additional N300,000 per day for ongoing non-compliance.

The regulator also extended the enforcement deadline for location and exclusivity rules until April 1, 2026, giving industry players more lead time to comply.

In a circular (PSP/DIR/CON/CWO/001/049) released October 6, 2025, and signed by Musa I. Jimoh, Director of Payments System Policy, the CBN introduced fresh compliance measures to reflect the growing sophistication of the PoS ecosystem and Nigeria’s push for deeper financial inclusion.

The CBN said the guidelines would take effect immediately. However, the stricter elements around ensuring agents are tied to fixed locations (agent location) and exclusive operations (agent exclusivity) will begin on April 1, 2026.

The circular read, “This circular takes effect from the date of release, while the implementation of agent location and agent exclusivity shall be with effect from April 1, 2026.” 

The guidelines require that all PoS terminals used in agent banking be geo-locked to their registered premises. Any device operating outside that area may face sanctions. Principals and super agents must ensure these controls are in place.

Also, principals are required to publish and maintain updated registers of all their agents, both online and in physical branches, while super agents are expected to have at least 50 agents spread across Nigeria’s six geopolitical zones at all times. Any proposed relocation, transfer, or closure of agent premises must be approved in writing, with a 30-day public notice required at the agent location to inform customers.

In practice, a prolonged breach could cost an operator tens of millions of naira before further regulatory action (delisting, suspension, blacklisting) is considered.

Other penalties in the guidelines cover late submission of reports, improper agent conduct, fraud, non-permissible activities, and failure to maintain agent records or accounts.

These new rules do not appear in isolation. On August 25, 2025, the CBN had already issued a circular commanding all existing PoS terminals to be geo-tagged within 60 days, and new devices must be geo-tagged before activation.

That earlier document mandated the use of ISO 20022 messaging for payments and required devices to support geolocation and geofencing, limiting operational radius to ~10 metres from registered addresses. Terminals that failed the compliance checks scheduled from October 20, 2025, would be deactivated.

Naijaonpoint earlier reported that PoS terminal issuers in Nigeria, mostly fintechs, are bracing for possible service disruptions and revenue losses as the CBN’s earlier October 31 deadline for the mandatory geo-tagging of all PoS terminals approaches.

With over 8.3 million registered PoS terminals in the country and 5.9 million already deployed as of March 2025, the scale of the exercise is massive.

The extension to April 2026 gives breathing space but does not soften the threat: come enforcement day, non-geo-locked terminals may be shut down, and agents or institutions may incur heavy fines. For merchants, this may limit the mobility of PoS services and reinforce fixed-location operations.

Operators, especially smaller ones, will need capital to upgrade firmware, invest in location-aware devices, integrate with the CBN’s regulatory platforms (e.g. CARDS), and redesign network footprints. However, some industry analysts believe many newer PoS devices already have GPS modules, so reconfiguration may suffice instead of device replacement.