Notes on the Addendum to the BVN Regulatory Framework
The Central Bank of Nigeria works to strengthen the security and integrity of the electronic payments system. In furtherance of that mandate, the CBN issued the Regulatory Framework for Bank Verification Number (BVN) Operations and Watch-List for the Nigerian Financial System on 18 October 2017 (the BVN Framework). It later revised that framework on 12 October 2021.
Fraud has since risen, and public confidence in the banking system needed reinforcing. Accordingly, the CBN issued an addendum to the BVN Framework (the BVN Framework Addendum) on 12 March 2026. It is scheduled to take effect from 1 May 2026.
The additions introduced by the BVN Framework Addendum are summarised below:
- While the Nigeria Inter-Bank Settlement System(NIBSS) is responsible under the BVN Framework for maintaining the Watch-List Portal and updating the Watch-List with the BVNs of designated individuals, the BVN Framework Addendum now requires financial institutions to establish and maintain a temporary watchlist for BVNs linked to suspected fraudulent transactions. Persons listed on the temporary watchlist are to be contacted within twenty-four (24) hours to clarify the flagged transactions.
- The minimum age requirement for BVN enrolment is eighteen (18) years.
- Customers of financial institutions are only permitted to change a phone number linked to a BVN once.
- Access to BVN databases shall be restricted exclusively to financial institutions licensed by the CBN. This represents a departure from the position under the BVN Framework, which permitted tier-2 users of the BVN database such as credit bureaus to access BVN data through the NIBSS in accordance with the Standard Operating Guidelines for the BVN. Regardless, the BVN Framework Addendum provides that the CBN reserves the right to grant access to the BVN databases in extenuating circumstances.
Why the CBN issued the BVN Framework Addendum
The CBN first issued the Regulatory Framework for BVN Operations and Watch-List on 18 October 2017. It revised that framework on 12 October 2021.
Fraud has since risen, and public confidence in the banking system needed reinforcing. Consequently, the CBN issued an addendum on 12 March 2026. It takes effect from 1 May 2026.
What banks should do before 1 May 2026
The commencement date gives institutions a defined window to prepare. Banks and other affected institutions should therefore review their current BVN and watch-list processes against the additions.
Three areas usually need attention. First, how the institution enrols and validates BVN records. Second, how it handles watch-listing and de-listing decisions. Third, how it evidences those decisions if a customer disputes them.
Moreover, operational readiness matters as much as policy. Staff handling these processes need to understand what has changed before the effective date, not after it.
Wider significance
The addendum forms part of a broader effort to strengthen the security and integrity of Nigeria’s electronic payments system. It sits alongside the CBN’s other recent interventions in the payments space.
For customers, the practical effect turns on how carefully institutions apply the watch-list provisions. Fair and well-evidenced processes protect both the customer and the bank.
Our notes summarise the additions introduced by the addendum and their practical implications.