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AFR's payments licensing landscape is fragmented and mobile-money-led: SARB is mid-consultation on its activity-based Authorisation Framework (third draft, comments closed 15 June 2026, final publication expected Q3 2026), running alongside the COFI Bill; Nigeria's CBN reshaped fintech licensing conditions via its Fourth Edition FX Manual and new cross-ownership market-power caps on issuing vs acquiring; Kenya's PSP licensing remains under the 2014 NPS Regulations with no activity-based overhaul yet announced.
In Nigeria, the Central Bank of Nigeria licenses PSPs under four categories — Switching & Processing, Mobile Money Operations, Payment Solution Services, and the Regulatory Sandbox — per the December 2020 categorisation circular and BOFIA 2020. Crucially for the bank vs non-bank distinction, only Mobile Money Operators and Payment Service Banks may hold customer funds, structuring the entire non-bank market. The CBN sets PSB structure via its Guidelines for Licensing and Regulation of Payment Service Banks, requiring at least 25% of access points in rural or underserved areas to drive financial inclusion — tying market-access licensing directly to inclusion policy.
In Kenya, the Central Bank of Kenya vests PSP authorisation under the National Payment System Act No. 39 of 2011 and the NPS Regulations 2014, with four categories: Electronic Retail PSP, Designated Payment Instrument Issuer, E-Money Issuer and Small E-Money Issuer. PSP business is prohibited unless authorised, and the regime sets capital requirements ranging by category. This tiered authorisation underpins the M-Pesa-dominated market.
Outlook
The SARB final Authorisation Framework and Exemption Notice are expected in Q3 2026, moving South Africa decisively to activity-based, direct non-bank authorisation with client-fund segregation — the bloc's most consequential near-term licensing change. Nigeria's and Kenya's regimes are mature and stable, with the fund-holding boundaries (MMOs/PSBs in Nigeria; trust-account model in Kenya) remaining the defining structural features. The trajectory across W1a is established, with South Africa as the active locus of change.
Licensing, Authorisation & Market Access
South Africa and Nigeria are running the two most consequential licensing-architecture stories in the African payments market this cycle, and they point in opposite directions. The South African Reserve Bank has published a third draft Authorisation Framework alongside a draft exemption notice, moving toward an activity-based licensing regime that replaces reliance on bank sponsorship for e-money issuance and money-remittance activity. The practical effect, once finalised, is that non-bank payment service providers would be authorised directly against the activities they perform rather than needing to operate under a sponsoring bank's licence, a structural liberalisation of market access for the non-bank segment even as the framework simultaneously brings that segment inside a formal prudential perimeter for the first time. This runs in parallel with the Cabinet's April 2026 approval of the Conduct of Financial Institutions (COFI) Bill for submission to Parliament, which would establish a single market-conduct framework spanning open finance, crypto assets, and payment-system activity under South Africa's Twin Peaks regulatory architecture, a conduct-side complement to the Reserve Bank's prudential licensing reform. The COFI Bill's inclusion of crypto assets within the same conduct perimeter as traditional payment-system activity is itself notable: it signals that South Africa's regulatory architecture is converging digital-asset conduct oversight with mainstream payments conduct oversight, rather than treating crypto as a separate regulatory silo.
Nigeria's Central Bank moved in the same period, but toward tightening rather than liberalising. The Fourth Edition Foreign Exchange Manual, issued 15 May 2026, revises cash-disbursement rules for personal and business travel allowances and updates eCCI capital-registration documentation requirements, while reaffirming that domestic transactions must be naira-denominated. This is a bank-facing instrument in the first instance, since FX-manual compliance sits primarily with deposit money banks handling FX transactions. Separately, and more consequentially for the non-bank segment, the CBN has imposed a cross-ownership cap: any entity holding more than 25 percent share of the consumer-issuing market is barred from holding more than 15 percent share of the merchant-acquiring market, and vice versa, with compliance deadlines of 31 December 2026 and 1 January 2027. This measure is explicitly aimed at non-bank payment service providers, OPay, Moniepoint, PalmPay, Paystack, and Flutterwave are the named affected entities, and represents a direct market-structure intervention in a segment that has grown large enough, and vertically integrated enough across issuing and acquiring, to attract this kind of competition-style regulatory response. The market-power-cap regime's dual-direction design, capping issuing-side concentration from extending into acquiring, and vice versa, reflects a deliberate attempt to prevent single-group dominance across both sides of the payments value chain, a competition-policy concern that is analytically distinct from, but adjacent to, the safety-and-soundness rationale typically associated with payments licensing. Nigeria's simultaneous FX Manual revision, by contrast, sits squarely within the traditional prudential and macro-stability rationale for licensing intervention.
The bank-versus-non-bank distinction is therefore the analytical spine running through both jurisdictions' licensing developments this cycle, but the direction of travel differs sharply. South Africa's reform lowers the barrier for non-banks to access the market directly rather than through a sponsoring bank, while formalising prudential oversight of that same segment. Nigeria's reform does the opposite in its market-structure dimension: it constrains how large and how vertically integrated a non-bank payment group may become, even as its FX-manual revision continues to route certain categories of FX-handling activity through bank-centric compliance obligations. Any payment group operating across both markets will need to manage two structurally different licensing philosophies: activity-based market access in South Africa, and a market-structure ceiling in Nigeria.
Outlook
The SARB Authorisation Framework's final publication, expected in the third quarter of 2026 following the close of the industry comment period, is the near-term milestone that will determine how quickly South Africa's activity-based regime becomes operative for non-bank applicants. The COFI Bill's parliamentary progress through the second half of 2026 will determine whether the conduct-side framework is in place on a comparable timeline. In Nigeria, the 31 December 2026 and 1 January 2027 compliance deadlines for the cross-ownership cap are the concrete near-term test: whether large, vertically integrated fintech groups restructure their issuing and acquiring businesses ahead of the deadlines, seek exemptions, or contest the requirement will be the clearest signal of how binding this market-structure intervention proves in practice.
Sources and findings (6)
- T2Lexology / Bowmans / SARB draft Authorisation Framework
- T1SARB Authorisation Framework & Exemption Notice; PA Prudential Communication 10 of 2026 (resbank.co.za)
- T1Central Bank of Nigeria — Payment Service Providers framework (cbn.gov.ng)
- T1CBN Payment Service Bank Guidelines (primary)
- T1Central Bank of Kenya — National Payment System Act 2011 (primary)
- T3Lexserve / KDS Advocates