CBN payment data localisation in Nigeria

Move payment data to Nigeria before the deadline

From 1 January 2027, Nigerian payment data must stay in Nigeria. We find every copy, migrate it without downtime and document it for your auditors.

Payment data map · example● audit
  • Transaction databaseeu-west-1Lagos
  • Nightly backupsus-east-1Lagos
  • Application logsSaaS loggingLagos
  • Product analyticsUS vendorLagos
  • Support desk exportsShared driveLagos
Deadline: 1 January 2027
What's at stake

Most payment companies have more offshore copies of their data than they think

The core database is the easy part. The risk sits in logs, backups, analytics, support tools and vendor SaaS that quietly copy payment data abroad.

What changes on 1 January 2027? A CBN circular dated 15 June 2026 requires banks, fintechs, mobile money operators and payment service providers to store and manage payment transaction data generated in Nigeria within Nigeria.[1] Aitechma runs readiness assessments (from $2,500, 1–2 weeks) and migrations (from $12,000, typically 4–8 weeks).

  • It applies to the whole payments chainBanks, fintechs, mobile money operators and payment service providers are all covered.[1]
  • It stacks on top of the NDPAThe circular complements the Nigeria Data Protection Act rather than replacing it, so you face two overlapping regimes.[3]
  • The CBN says it will enforceThe CBN has said it will monitor compliance closely and apply supervisory sanctions where necessary.[5]
  • WeeksUntil the 1 January 2027 deadline
  • 15 Jun 2026Date of the CBN circular[1]
  • 2Overlapping regimes: CBN circular + NDPA[3]
What we build

Four ways we help

Start with the assessment. Many teams then hand us the migration because we already know their systems.

  • Readiness assessment

    A complete inventory of where payment data lives and flows, a gap list against the circular, and a costed plan.

  • Architecture & migration

    In-country primary storage, re-pointed services, dual-write and a zero-downtime cutover with rollback.

  • Vendor & tooling review

    Logging, error tracking, analytics, support desks and data warehouses: what to move, mask or replace.

  • Evidence & ongoing monitoring

    Data-flow diagrams, configuration evidence and alerts that flag new offshore copies after go-live.

Proof

Built by the team behind Nigerian fintech at scale

We've built and supported payment products used by hundreds of thousands of Nigerians, so we know where payment data hides.

  • Zabira logo
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    A multi-currency wallet for crypto, gift cards and utility payments.

    Our role: Led the v1.0 web and mobile build, plus UI design
  • AjoMoney logo
    Billionsof naira in transaction volume

    AjoMoneyFintech · Savings

    Nigeria's rotating group savings (ajo), rebuilt for mobile, with zero-interest community credit, P2P transfers and bill payments.

    Our role: v1.0 development and technical advisory alongside the founding team
  • CredSol logo
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    CredSolFintech · SME lending

    A loan marketplace that pre-qualifies SMEs in minutes and matches them with the right lenders.

    Our role: Built the platform: AI-assisted matching, borrower and lender dashboards, loan calculator
How we work

Our migration sequence

  1. Inventory

    Every database, bucket, log stream, backup and vendor that touches payment data, mapped in a data-flow diagram.

  2. Gap assessment

    Reviewed with your compliance team and counsel against the circular and the NDPA.

  3. Target architecture

    Where each workload runs, how data is replicated and what stays global (if anything).

  4. Build & dual-run

    Stand up in-country infrastructure and run old and new in parallel with reconciliation.

  5. Cutover

    Switch traffic with a rollback plan, then decommission or mask the offshore copies.

  6. Evidence pack

    Documentation your compliance officer can hand to auditors and the regulator.

Scope

Where payment data hides

We review four layers. The first is obvious; the other three are where most offshore copies sit.

Core dataDatabases · ledgers · warehouses

Transaction stores, ledgers, data warehouses, backups and object storage moved to in-country hosting.

Hidden copiesLogs · analytics · support

Error trackers, log pipelines, product analytics, support desks and staff CSV exports found, masked or moved.

InfrastructureHosting · network · keys

Nigerian data centres or local cloud, hybrid networking, VPN and key management designed for the cutover.

EvidenceCBN circular · NDPA

Data-flow diagrams, access controls and audit trails your compliance officer can hand to auditors.

Price & timeline

Cost and timeline

The assessment price is fixed. The migration is quoted from what the assessment finds.

EngagementFromTypical timeline
Data localisation readiness assessment$2,500approx. NGN 3.8M1–2 weeks
Migration to Nigerian hosting$12,000approx. NGN 18M4–8 weeks

Indicative starting points. Your fixed quote follows a free scoping call. Get an instant estimate →

Why Aitechma

A partner, not a vendor

  • A partner after launchWe stay for the first users and the first revenue: monitoring, fixes, growth experiments and advice.
  • Milestone paymentsYou pay in stages tied to working software you can see, never 100% upfront.
  • You own the codeSource code and IP are yours, in writing. We sign an NDA before you share the idea.
  • A team you can visitEngineers, designers and product managers in Ikeja, Lagos, with full overlap with UK and EU hours and a daily window for US teams.
  • Weekly demosA working build every week and one point of contact, so you're never chasing updates.
  • Senior judgementWe'll tell you what not to build yet. Architecture and scope advice is part of the job.
Questions

Data localisation questions

A CBN circular dated 15 June 2026 requires banks, fintechs, mobile money operators and other payment service providers to store and manage payment transaction data generated in Nigeria within Nigeria, from 1 January 2027. The same circular adds ultimate beneficial ownership disclosure and market structure rules. Read the circular with your legal counsel for how it applies to your licence.

No. Legal analyses describe the circular as complementing the NDPA, so payment companies now work under both regimes at once. Our migration plans cover both.

It depends on where your payment data is physically stored and processed, and on your counsel's reading of the circular. We map every system that touches payment data, then design an architecture that keeps it in Nigeria. That may mean moving some workloads while others stay where they are.

Copies of payment data outside the core database: logs, error trackers, backups, analytics tools, data warehouses, customer-support desks and spreadsheets exported by staff. The inventory step finds them.

A readiness assessment takes 1–2 weeks. Most migrations take 4–8 weeks, depending on data volume, the number of vendors and how much downtime is acceptable (we aim for none).

No. We're an engineering team. We work alongside your compliance officer and lawyers and produce the technical evidence they need.

Start a project

Find out where your payment data really lives

Book a readiness assessment: 1–2 weeks, from $2,500, with a costed plan at the end.

01 I'm building
02 Where it is

Hi Aitechma, we need help with CBN payment data localisation before January 2027.

References

  1. Nairametrics. CBN mandates banks, fintechs to store payment data in Nigeria (15 Jun 2026)
  2. PwC Nigeria. CBN data localisation and market structure rules (2026)
  3. Mondaq. CBN's data localisation directive: compliance considerations for payment system participants (2026)
  4. Techpoint Africa. CBN data localisation push raises concerns (2026)
  5. Techeconomy. CBN orders banks, fintechs to store payment data in Nigeria by January 2027 (2026)