We’ve been in a “waiting season” for some time now. Since 2021, when the CBN issued Nigeria’s Open Banking Framework, the industry has known the direction. Yet, with each public deadline that passes without action, excitement gives way to uncertainty.
This pause isn’t a setback. Ironically, it is an advantage. It’s during lulls that winners differentiate themselves. While others wait for directives, the institutions that act now will innovate faster once implementation begins.
In Nigeria, the regulator hasn’t yet delivered a final “go-ahead.” We’re operating in the realm of intent, not orders. But even without a directive, there is much to do. The following three moves will ensure you don’t start behind the pack when the regulatory hammer drops.
1. Revisit & Internalize the Open Banking Framework as Your Strategic Compass
The four-year-old Open Banking Regulatory Framework remains the most reliable guide to what’s coming. It defines how consent will work, what customer data can be shared, how disputes will be resolved, and the baseline obligations for every participant.
There’s no better time to revisit it, understand the principles, and consider what it means for your operations, products, and customer experiences.
- Conduct a gap analysis between your current systems and the framework’s requirements. How closely do your current data architecture, consent processes, and internal controls align with what’s described?
- What would need to shift if the CBN announced adoption tomorrow?
Institutions that study these frameworks early will become more nimble once full implementation arrives. Those who treat it as an afterthought will scramble to catch up when timelines arrive.
2. Lay the Organizational and Technical Foundations
Readiness isn’t built in the rush of implementation. It starts with coordination.
Institutions will need to assemble a cross-functional Open Banking team, bringing together representatives from legal, risk, technology, data security, and product management. This team will become the nerve center for your open banking readiness
The team’s role would be to translate the framework’s requirements into internal actionable steps, simulate data-sharing processes, identify readiness gaps, and build solutions before they become urgent.
- Legal teams should identify the contractual and consent models that will need revision.
- Risk teams should start defining how data-sharing fits within their current governance frameworks.
- Technology teams should map their API maturity and evaluate infrastructure gaps.
3. Own the Narrative and Educate Customers
Trust will be the real currency post-open banking adoption. Institutions that don’t shape the narrative early risk being misunderstood later. While waiting, banks and fintechs should start shaping the story around open banking.
Communicate clearly to internal teams. Teams across each department should fully understand what customer consent truly means, why data privacy matters, customer rights, and what changes are coming.
Extend the narrative externally: educate your customers on what open banking is, how it benefits them, and how their data will be managed safely. Help partners see what their future could look like with open banking, share thought leadership, run awareness campaigns, and host internal and public webinars.
Silence breeds confusion. For Nigeria, early communication will be key to overcoming public skepticism, and institutions that begin customer education now will build trust, familiarity, and loyalty, even before the regulatory go-ahead.
Read more: How business owners can leverage open banking in Nigeria
In summary
Open Banking in Nigeria is no longer a question of if or when. The real question is how ready each institution will be when the lights turn green.
We have seen that readiness becomes easier when teams fully understand the ecosystem. That’s why we continue to organize technical workshops and readiness assessments to help banks and fintechs interpret the framework and test their capabilities early.
This waiting period is strategic. Those who prepare thoughtfully will define the early success story of Nigerian Open Banking. Those who wait for certainty will only follow closely behind.
Readiness is not optional; it is a mandate in all but name. Open Banking is inevitable; the difference lies in who takes advantage of the lead time to position themselves effectively.
