On 15 June 2026, the Central Bank of Nigeria (“CBN”) issued a Circular requiring all payment transaction data generated in Nigeria to be stored and managed domestically by 1 January 2027.1 The rule applies across the payments ecosystem: banks, mobile money operators, switching companies, payment solution providers, and their upstream technology partners. Every affected institution now faces the same question – not whether to localise, but how to build the physical capacity to do so before the deadline closes.
This is not, at its core, a data-governance exercise. Nigeria does not yet have sufficient domestic data-centre capacity to absorb the transaction volumes which the Circular contemplates. Nigeria’s electronic payment volumes have already exceeded 60 billion transactions annually, placing further pressure on domestic digital infrastructure. For a significant portion of the market, compliance means delivering new infrastructure: designing, financing, constructing, and commissioning new facilities that do not yet exist. For institutions without sufficient domestic capacity, the Circular effectively creates a construction mandate with a regulatory deadline attached.
