Obtaining an Electronic Money Institution (EMI) License in Nigeria

Electronic money (E-money) has become a universal tool for both domestic and cross-border payments, meeting the needs of businesses and individual users. Accordingly, the demand for EMI licenses in Nigeria is growing—it provides access to legal operations with digital assets.

A license holder receives the status of an Electronic Money Institution (EMI), which allows not only the issuance of E-money but also the execution of payment transactions for third parties. Licenses are issued by national regulators who impose strict requirements on applicants.

The licensing process is complex and requires expertise, knowledge of international norms, and significant resources. Law&Trust will reduce processing times and minimize risks. We will prepare the documents, negotiate with the regulator, and ensure seamless licensing without bureaucratic delays.

Why is an EMI license necessary in Nigeria?

An EMI license grants financial organizations unique opportunities unavailable to traditional banks and issuers. Unlike them, an EMI gains expanded functionality immediately upon licensing.

Key advantages of EMI in Nigeria:

Remote service – opening accounts for individuals and legal entities without visiting an office;
Card issuance – issuing Visa/MasterCard linked to client accounts;
Multicurrency transactions – payments in USD, EUR, GBP, and other currencies through the global banking network;
SWIFT integration – receiving payments from any international accounts;
Autonomy – conducting transactions and opening accounts independently;
Correspondent accounts – unlimited possibilities for opening correspondent accounts.

An EMI license retains all the functions of a payment institution without banking restrictions

Who needs an EMI license in Nigeria?

In Nigeria, where the digital payments market is expanding, this license is a key tool for lawful operations with electronic money. It is regulated by the Central Bank of Nigeria (CBN) and is required for anyone wishing to securely interact with digital assets.

An EMI license in Nigeria is necessary for:

Fintech startups – for launching innovative payment services and mobile wallets;
Neobanks – digital banks without physical branches offering online settlements;
Payment systems – companies involved in transfers and settlements between businesses;
Cryptocurrency platforms – if they operate beyond converting digital assets to fiat;
Large corporations – to create internal payment ecosystems (e.g., corporate cards);

If your activity involves holding client funds or conducting transactions, an EMI license is a mandatory CBN requirement. Without it, operations in Nigeria will be considered illegal.

EMI License in Nigeria: Requirements

The process of obtaining an EMI license is quite complex and requires significant effort. This is due to the large financial and personal investments that will only yield returns once your business is launched in Nigeria. This jurisdiction has established a strict procedure for obtaining an EMI license. The main requirements for applicants include:

Legal status of the company. In addition to registering a legal entity in Nigeria, your company must have a clear structure and a prepared business plan, including revenue forecasts and risk assessment;
Authorized capital. For a full EMI license – 2 billion naira (approximately USD 2.5 million). For a limited EMI license – 50 million naira (approximately USD 60,000);
Compliance with AML/CFT (Anti-Money Laundering/Counter-Terrorist Financing) regulations. This includes implementing KYC procedures (customer identification) and appointing an AML/CFT officer with subsequent regular reporting to the NFIU (Nigerian Financial Intelligence Unit);
A reliable payment platform that complies with PCI DSS, ISO 27001 standards;
Regulator approval (CBN). Verification of beneficiaries and directors for reliability (no criminal records, links to terrorism, or financial fraud);
Completed company audit before license issuance.

Obtaining an EMI license in Nigeria is a complex but necessary process for fintech companies. Without it, working with electronic money will be illegal. Our lawyers can help. Law&Trust specializes in financial regulation to accelerate the process and avoid rejection.

Documents Required to Obtain an EMI License in Nigeria

Certificate of Company Registration (CAC) – the business must be registered in Nigeria as a PLC (Public Limited Company).
Articles and Memorandum of Association (MEMART) – indicating business activities related to electronic money.
Beneficiaries’ and directors’ data (passports, CVs, police clearance certificates).
Proof of authorized capital.
Audited financial statements (if the company is already operating).
5-year business plan – with income, expense estimates, and growth projections.
AML/CFT documentation (measures to combat money laundering and terrorist financing).
Agreement with the NFIU (Nigerian Financial Intelligence Unit) for reporting.
License application (official CBN form).
Proof of physical office in Nigeria (lease agreement or ownership document).

Important note: As of 2024, the CBN requires data localization—servers must be physically located in Nigeria. For cryptocurrency operations, additional approval from SEC Nigeria is required.

EMI License Application Process in Nigeria

Company preparation

First, a legal entity must be registered as a public limited liability company (PLC) with Nigeria’s Corporate Affairs Commission (CAC). A business plan must be developed and the authorized capital deposited. At this point, a team can also be formed, including AML and compliance officers.
Application submission to the CBN

This stage takes 3–4 months to complete all paperwork. In the following months, the regulator reviews the application. A comprehensive evaluation is carried out during this time.
Verification

A financial audit and review of the payment system is conducted. The regulator also verifies the reliability and compliance of beneficiaries and company management with anti-money laundering standards.
Preliminary approval and finalization

The final step includes paying the license fee (1,000,000 naira) and obtaining the EMI certificate, after which the company is listed in the official register of Nigerian payment institutions.

The entire process takes 9 to 12 months.

Our Services in Obtaining an EMI License in Nigeria

Law and Trust International provides the opportunity to obtain the necessary EMI license in Nigeria in accordance with all applicable laws and regulations. We offer a wide range of services tailored to each client. L&T International can assist you with the following:

Highly qualified legal support;
Completion of all required documents and applications;
Legal representation and support when drafting contracts with third parties (auditors, service providers);
Company registration;
Trademark registration;
Opening a bank account in Nigeria;
Legal opinions for payment platforms, crypto operations, and banking partners.

If you are ready to obtain an EMI license in Nigeria, contact our lawyers for a free consultation.

F.A.Q.

Can a company with cryptocurrency products obtain an EMI license?

Yes, but starting in 2024, the CBN requires additional approval from SEC Nigeria. Crypto operations must be clearly separated into a distinct business unit with ring-fenced capital. It must also be proven that crypto services will not be used to circumvent currency controls (e.g., black market dollar purchases).

Is it mandatory to hire local staff to obtain a license?

Yes. Informally, the CBN expects that 60% of IT staff will be Nigerian citizens, and the AML officer must have experience working in Nigeria or other African jurisdictions. The board of directors must include at least one Nigerian citizen.

Is it true that the CBN checks the social media of directors?

Yes, especially if the company is involved in cryptocurrency. If founders were previously engaged in gambling or the forex sector, this could be a reason for scrutinizing social networks.

Timeframe for Obtaining an EMI License in Nigeria

The timeline depends on many factors, including the completeness of submitted documents, how quickly the regulator processes applications, and legal compliance. Typically, the process takes several months to one year.

Where Can an EMI License Be Used?

An EMI license issued by the Central Bank of Nigeria (CBN) permits the following activities:

Issuance of electronic money: Creating digital monetary units used for paying for goods and services.
Payment processing: Conducting transactions between users and service providers.
Holding and managing users’ electronic funds.
Providing payment services: Including money transfers, bill payments, and other financial operations.
Platform development and maintenance: Creating and maintaining platforms for electronic payments.