Trust as an Infrastructure Problem · Online Version · Trust Architecture in Platform-Led Finance

Section II  |  Background

Trust as an Infrastructure Problem

Nigeria’s digital financial ecosystem is the product not of infrastructure alone, but of a deliberate sequence of policy choices, institutional investments, market responses, and private capital mobilisation over more than a decade. Since 2010, when Nigeria aligned itself with the Maya Declaration and adopted an 80% financial inclusion target, policy has provided both the strategic direction and the enabling conditions for ecosystem expansion. The National Financial Inclusion Strategy of 2012 established the regulatory framework that progressively licensed new categories of providers, and shared infrastructure investments made interoperability possible rather than optional. Innovation responded: fintechs, payment service banks, mobile money operators, and digital lenders built products and distribution models that the infrastructure made viable. Investment followed, directing capital toward an ecosystem whose policy foundations had reduced the cost and risk of participation and helped produce several of Africa’s most prominent fintech enterprises. The result was not simply a payments system. It was a layered, platform-driven financial ecosystem whose complexity now presents governance challenges that its original architecture was not designed to manage.

Four foundational shared infrastructure initiatives

At the technical core of that architecture sit four foundational shared infrastructure initiatives. The Nigeria Inter-Bank Settlement System (NIBSS), incorporated in 1993 and jointly owned by the Central Bank of Nigeria and all licensed deposit money banks, established the central switching and settlement layer that connects every financial institution in the country. The NIBSS Instant Payment (NIP) platform, launched in 2011, made real-time interbank transactions possible at scale. The Bank Verification Number (BVN), introduced in 2014 through collaboration between NIBSS and the CBN, created a biometric identity anchor linking customers across institutions. The Global Standing Instruction (GSI) added a further accountability layer, enabling cross-institution loan recovery. Together, these initiatives were built not through competition but through deliberate collaboration between the CBN and Nigeria’s banking sector: a jointly owned, jointly governed model designed to serve the system as a whole rather than any single participant.1

That collaborative model is also significant beyond its technical achievements. It demonstrates that Nigeria’s financial institutions, competitors in every other respect, have previously chosen to build together when the stakes were systemic. NIBSS itself is the institutional embodiment of that choice. That model of deliberate collaboration established an institutional precedent for system-wide coordination, showing that shared infrastructure could be built collectively when the stakes were sufficiently high.

These systems allow transactions to be completed seamlessly across banks, fintech platforms, and other service providers in real time. A fully interoperable mobile money framework connects licensed operators across both bank and non-bank channels, while a shared ATM network supports tens of thousands of terminals nationwide.2 More recently, the introduction of AfriGO, developed by the CBN in partnership with NIBSS and launched in January 2023, has added a further layer to the payments ecosystem, positioning Nigeria as the first country in Africa to operate a central bank-led domestic card scheme.3

At the continental level, Nigeria has been a founding participant in the Pan-African Payment and Settlement System (PAPSS), developed by Afreximbank in partnership with the African Union and the African Continental Free Trade Area (AfCFTA) Secretariat, and has played an active governance role since its launch in 2022.4 These developments have extended the system beyond national boundaries, introducing cross-border interoperability as an additional and increasingly consequential dimension of system design.

From shared utility to contested infrastructure

On this foundation, the financial ecosystem has expanded in layers. Fintech platforms have improved user experience and accelerated transaction scale, agent networks have extended physical reach, mobile money operators have brought millions into formal financial activity, and digital lenders have expanded access to credit. Critically, the infrastructure model itself has evolved. The original shared utility model, publicly anchored and jointly owned, has been supplemented by a proliferation of proprietary switching and processing capacity. The CBN has granted full switching licences to private entities including Flutterwave, and major banking groups have established their own fintech switching arms. Paystack and Flutterwave have moved to acquire banking and open banking infrastructure assets ahead of Nigeria’s open banking rollout. The ecosystem’s infrastructure is no longer exclusively shared; it is increasingly contested, proprietary, and commercially strategic.

This evolution reflects genuine confidence in the system: private capital building infrastructure is a signal of maturity, not fragmentation. But it introduces a governance dimension that the original shared model did not face. When infrastructure was jointly owned and centrally governed, accountability was collective and oversight was relatively straightforward. As proprietary rails multiply alongside shared ones, transactions increasingly traverse multiple providers and systems, diffusing accountability, complicating oversight, and raising questions about interoperability that the original architecture was not designed to answer. The coordination complexity this creates is not a peripheral feature of the ecosystem’s development; it is the governance dimension this report addresses.

Persistent operational pressures

This expansion has been accompanied by persistent and deepening operational pressures. Fraud losses rose steadily from ₦12.7 billion in 2021 to ₦17.67 billion in 2023, reflecting the underlying vulnerability trend as transaction volumes expanded. In 2024, losses spiked to ₦52.26 billion – largely driven by a single fraud incident of ₦31.1 billion involving one institution, exposing systemic vulnerability to catastrophic single-point failure – before falling to ₦25.85 billion in 2025 following coordinated industry action. Even setting aside the 2024 outlier, losses roughly doubled between 2021 and 2025. The pattern of declining case volumes alongside rising loss values persists throughout: the system is experiencing fewer but more damaging attacks. Consumer complaints surged 143% in the first half of 2025. Pricing opacity and hidden charges remain a persistent source of consumer friction, eroding confidence among users who cannot easily verify the true cost of services. Dispute resolution mechanisms have not kept pace with the scale and speed of digital payments: when failures occur, the path to resolution is often unclear, slow, and contested across institutional boundaries. In many cases, accountability for failures that span multiple institutions remains undefined.

Fraud losses, 2021–2025  |  ₦ billion

12.7
2021
17.67
2023
52.26
2024
25.85
2025

The 2024 spike was driven largely by a single ₦31.1 billion incident at one institution.

Source: NIBSS Industry Fraud Reports, 2025 and 2026.

Expanded reach has not translated uniformly into active usage or durable confidence across the system, suggesting that access and trust are no longer moving in parallel. According to EFInA’s Access to Financial Services in Nigeria Survey (2023), formal financial inclusion rose to 64% in 2023, a notable increase from 56% in 2020. However, approximately 40 million adult Nigerians remain formally excluded, with exclusion rates considerably higher in rural areas and the north. Growth in active usage has been slower than account ownership alone would suggest, indicating that expanded access has not translated uniformly into confident and active participation.

These conditions provide the context within which questions of coordination, accountability, and system reliability in digital financial services must be understood. The system Nigeria has built is capable. The question this report addresses is whether it is, and can be designed to be, trusted.