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The Central Bank of Nigeria (CBN) recently relaunched Nigeria’s cashless policy initiative which seeks to reduce financial crime and tax avoidance, decrease cash dependency, advance the adoption of digital financial services (DFS), decrease the risks to the payment system and foster financial inclusion. This study aims to identify the unique challenges of going cashless in Nigeria, particularly in terms of infrastructural, exclusionary and cost implications of the policy on the average citizens.

The author applies a doctrinal research methodology to identify and reflect on key challenges of the cashless policy from the economic, regulatory and transactional perspectives.

The cashless policy initiative in Nigeria heralds value for financial integrity, financial policy regulation and user convenience. The mode of introduction, however, ushers in significant challenges and hardly considers Nigeria’s inadequate payment infrastructure, persistent financial exclusion, low levels of financial and digital literacy and capability, high cost of using DFS and pervasive proclivity for cash. As Nigerians adjust albeit inconveniently to the policy, the CBN can ameliorate the hardship by strengthening the payment infrastructure, particularly for digital payments, fostering consumer trust by safeguarding user funds and enabling consumer preferences.

Research materials include the national regulator’s policy documents and newspaper articles that have not been published in formal reports but non-the-less adequately mirror the policy intention of the CBN and the lived experiences of Nigerians.

This study identifies the practical steps and regulatory measures that the CBN can take to improve acceptance and meaningful and sustainable adoption of the cashless policy by the majority of Nigerians.

The recommendations that are proffered provide some rich insights to inform regulatory direction for the CBN to seamlessly phase-in the cashless policy and consequently drive down financial exclusion in Nigeria.

This study contributes to the policy discussion around the introduction of the cashless Nigeria project. The doctrinal research method highlights the policy intentions of the regulator in juxtaposition with lived experiences of Nigerians. This study offers recommendations to bolster financial inclusion, stability and integrity.

Nigeria needs to improve its national identification coverage to support improved anti-money laundering and combating of financing of terrorism and proliferation (AML/CFT) measures. This study aims to examine its ongoing identification harmonization project, which seeks to create a central database for digital identification across designated entities. It identifies the key stakeholders in the project, progress to date as well as key challenges, especially relating to the inclusivity and privacy and data protection concerns of the current scheme to provide national identification numbers.

The authors apply a doctrinal research methodology and use the Principles on Identification for Sustainable Development to identify and reflect on key challenges.

The national identification harmonization project and the ongoing drive to register National Identity Numbers for Nigerians could provide valuable support for more effective and efficient AML/CFT identity verification and authentication. The project and processes, however, hold significant risks in relation to data protection. These are exacerbated by the absence of a comprehensive data protection framework. National identity data can be vulnerable to political abuse and targeting by bad actors. National identity data systems must, therefore, be protected by clear, fair and comprehensive privacy and data protection rules and appropriate and accountable governance mechanisms. While Nigeria is adopting and implementing the relevant framework, the NIMC can do more to advance data protection by supporting informed consent and compliance by all participants and publishing this information to build public trust in the system. It can also be disciplined about only collecting minimal and necessary personal data and printing only basic personal details such as name and age on the general multi-purpose ID card. The NIMC should furthermore improve access to the national identification number by streamlining the process of registration, including supporting same day registration and on-the-spot card printing; setting up more registration points as well as mobile registration to cut down queues; and increasing the range of registration agents and points to include schools, police stations and health facilities. Consideration for social, cultural and religious norms is also vital to appropriately accommodate the variety of groups and cultures in Nigeria.

Research materials include government policy documents as well as newspaper articles and reports on more recent developments and experiences that are not yet reflected in more formal documents. The research materials, however, reflect both the intention of the government and the reported experiences of those registering for a National Identification Number.

This study identifies the practical steps that can be taken to enhance data protection and increase the inclusivity of the measures to provide Nigerians with National Identification Numbers.

The recommendations that are made are aimed at increasing the inclusivity of the National Identification Number scheme and at providing improved protection of personal data of applicants for, and holders of, these numbers.

This study contributes to the policy discussion around the national identification harmonization project by applying as a lens key elements of the Principles on Identification for Sustainable Development that are relevant from a financial integrity perspective.