The Central Bank of Nigeria has been at this for almost twenty years, and it’s genuinely good at it. The first vision came in the mid-2000s; the last one launched in November 2022, and between them they took a country where most adults had no bank account, and cash settled almost everything, and turned it into one of the few places on earth where you can send money to a stranger and watch it land in seconds. We built a real financial identity in the Bank Verification Number (BVN), an agent network of close to two million touchpoints, and an instant-payment system the rest of the continent studies, and we now move well over a quadrillion Naira a year through electronic channels. 

PSV 2028 is the next installment, and it’s ambitious, which is the polite way of saying the CBN has handed itself roughly thirty months to deliver a list that would stretch a far simpler country. There’s plenty to like, a few things I’d argue with gently, and a couple of things I wish were in it that aren’t. Thirteen points, in that order.

The good

1. The National Payment Stack is the real deal

The most important thing in the document is as flashy as the foundation of the Burj Khalifa, deep and invisible. The NPS is NIBSS’s full rebuild of the national rails, and it’s already gone live, with its first real transaction running between PalmPay and Wema Bank in November 2025, and it’s now rolling out to the rest of the banks (pages 34 and 42). It replaces the NIBSS Instant Payments engine that’s carried us since 2011 and was processing more than nine billion transfers a year before it ran out of room, and being built on ISO 20022, it finally gives us richer payment data, automated reconciliation, and the international compatibility we’ve lacked. If PSV 2028 shipped nothing else, this would earn its keep.

2. The CBN builds policy with the industry

This is the strength most people don’t appreciate, and it’s a big reason these documents are worth taking seriously. When the CBN wants to set national policy, it convenes the Nigerian experts who actually run the rails, the banks, the fintechs, the switches, the development partners, and the subject-matter experts, and it builds the thing with them rather than handing down an edict and daring everyone to comply. 

PSV 2028 says as much in its own acknowledgements, crediting financial institutions, industry associations, and fintech innovators for shaping the document (page 10), and anyone who’s sat through these working sessions knows how real that process is. When the industry pushed back on the automated-AML timeline, the compliance window was stretched from twelve months to eighteen, and when operators argued the 10-meter POS geo-fence was impossible to hit accurately, the CBN widened it to 70. A regulator that consults and then actually adjusts is rarer than it sounds, and it’s a big part of why Nigerian payments policy tends to stick once it lands.

3. Fraud and cybersecurity are finally first-class, and the work has already left the page

For years, fraud was the thing everyone complained about, and everyone refused to kill. PSV 2028 puts it at the center, with AI-driven monitoring and predictive analytics (page 63), a stronger Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) posture (page 38), a national security operations center, and an industry fraud-intelligence sharing platform (pages 39 and 95 to 103). 

Why it matters is well documented, because NIBSS data shows fraud losses jumped from about ₦11.6 billion in 2020 to 52.3 billion in 2024. And unlike most vision-document promises, this one’s already moving across more than one CBN department at once. The CBN’s Banking Supervision Department issued the baseline standards for automated AML in March 2026, giving deposit banks 18 months and other institutions 24 months to run AI and machine-learning monitoring with annual accuracy testing. The Payments System Supervision Department ordered GPS geo-tagging on every POS terminal layered on device binding and a BVN fraud watchlist on the instant-payment side. Whatever you make of any single rule, the direction’s crystal clear and it’s happening now.

4. The BVN, and the reason NIN exists at all

Give the CBN its due on identity. The BVN sits under more than 320 million accounts and became the backbone of digital Know Your Customer (KYC), and it’s the proof of concept that made the National Identification Number (NIN) program credible, so the two are a sequence and not rivals (pages 32 and 75 to 76). The document puts NIN coverage past 122 million as of late 2025, and it’s refreshingly blunt that enrollment is short of funding and field kits, which is the real reason it still trails the BVN. That candor matters, because the forced bank-account-to-NIN linkage has itself been flagged as a risk that could push people back into the informal system if the identity rails can’t keep pace.

5. The compliance-automation ambition is genuinely modern

PSV 2028 wants a national RegTech and SupTech capability, a machine-readable CBN rulebook in JSON and XML, and 90% of institutions feeding automated compliance data to the CBN by 2028 (page 63). This isn’t blue-sky talk, because the automated-AML baseline standards now in train are already the first concrete move toward supervision that reads structured data in near real time instead of chasing quarterly paper returns. Very few central banks anywhere have committed to this in writing, and it’s the sort of capability that compounds quietly for a decade.

6. Consumer protection and inclusion, which I wish ranked higher

The track record here is real, with the service-level rules that force ATM chargebacks to clear within a day and failed POS reversals within three (page 32), and formal inclusion did climb from 56% in 2020 to 64% in 2023 on EFInA’s numbers, driven mostly by fintech and non-bank channels rather than the banks. My one honest wish is that this theme sat nearer the top of the CBN’s priorities rather than in the middle of the pile, because everything else in the document- the rails, the fraud controls, the new products- ultimately rests on whether ordinary people trust the system enough to keep their money inside it.

Trust is the real asset all of us are building, and it deserves top billing.

7. We still lead the continent, and the vision knows it

PSV 2028 is clear-eyed about where Nigeria sits regionally, building on its participation in the Pan-African Payment and Settlement System (PAPSS) for local-currency cross-border settlement under the African Continental Free Trade Area (AfCFTA), and on a sensible push to widen the rails beyond cards and transfers into contactless, QR, and tap-to-phone (pages 71 to 74 and 84). Nigerian schemes and processors already reach well past our borders, and the document treats that lead as something to defend rather than take for granted.

The bad

8. The plan is sweet on digital currency, and I’m not quite as smitten

Let me declare my bias cheerfully, because the global case for central bank digital currency and regulated stablecoins is real, the rest of the world’s still arguing it out, and a central bank that ignored the question entirely would be asleep at the wheel. So I don’t fault the CBN for paying close attention. My quibble is proportion, because by my own count across the 132 pages, the Central Bank Digital Currency (CBDC), stablecoin, and eNaira family turns up close to 200times and gets a thematic area all to itself (pages 82 to 94), while open finance appears exactly once and lives as a sub-bullet (pages 62 to 64). 

For a document about how money will move in Nigeria for the next three years, that’s a lot of ink on the newest and least proven rail, and rather little on the one that connects everybody. If the pen were mine, I’d have shared it out differently, and I’ll happily lose this argument to anyone at the CBN who can show me the adoption curve that justifies the weighting. It’s a judgment call, but I own my own call.

9. Routing every government payment through the eNaira is where the plan argues with itself

This is the one spot where I push back a little harder, and I do it with respect, because the document is admirably honest about the problem itself. In its own words, it admits that eNaira adoption has been slow and that real-world uptake is a very small slice of the currency in circulation (pages 72, 84, and 89). 

The outside view is blunter, since the International Monetary Fund (IMF) found that 98.5% of eNaira wallets had never once been used, and three years on the wallet app had quietly slipped off the Google Play Store while the USSD code stopped working. And yet the plan still sets a target of routing 100% of government-to-person payments through the CBDC (page 64). I understand the instinct, because G2P is the obvious way to give an ambitious payments rail some traffic. 

My worry’s the order of operations, since hitching the lifeline of the poorest Nigerians to the one instrument they’ve so far declined to use is a heavy load for a young rail to carry. Get people wanting the eNaira first (not sure I want, Naira works!), and the G2P volumes will follow on their own.

10. The headline targets are reachable, which is exactly why they should mean something

My first instinct was to call 95% inclusion by 2028 a stretch. But then Nigeria’s already proved it can move at that speed when it has to. When the 2023 cash crunch pulled physical money out of the system, NIP transaction volume jumped about 46% in a single month, which tells you the rails and the public can swallow a huge shift in weeks. So the number’s reachable, and I won’t pretend otherwise. What gives me pause is what came next, because the moment cash returned, so did our old habits, and the share of currency sitting outside the banking system climbed back above 90%. 

People go digital when nudged hard and drift back the instant the pressure lifts, which says the system hasn’t yet given them enough reason to stay. Those reasons are affordable services and real credit, and an account someone opened once and never touches again counts in a survey without counting for much in a life. The target’s within reach, but the biggest work is to make sure it sticks like gum.

The missing

11. Payments data is the on-ramp to credit, and we haven’t built the ramp

Let me be precise here, because credit isn’t payments and a payment vision isn’t a lending strategy. But the rails we’re building, and the transaction data they throw off every second, are the richest raw material for credit this country will ever have, and that’s the connection PSV 2028 doesn’t quite draw. The document handles payments beautifully and then stops at the water’s edge, leaving credit as a few scattered mentions, a line on credit scoring under fraud (page 63), and a nod to movable collateral (pages 72 to 73), rather than a deliberate path from a person’s payment history to a loan they can actually get. 

It matters because access to a rail isn’t what changes a trader’s life; access to capital is, and the figures from EFInA, the CBN’s own inclusion partner, show how much room we have, with formal credit reaching only about 6% of adults and the share of financially healthy Nigerians slipping from 28% in 2020 to 16% in 2023 even as accounts multiplied. This isn’t a knock on the work; it’s the prize sitting right next to the work, because we’ve already built the thing that generates the data, and the next move is simply to say out loud how that data becomes credit.

12. Open finance deserves more than one line

Full disclosure before I say a word, because I started Open Banking Nigeria back in 2017, so you can fairly say I’m talking about my own book here. With that on the table, the point still stands on its own. Open finance is the rail that turns the credit idea above into something real, the architecture that lets a lender see a person’s financial life across institutions, with their consent, and price a loan for them, and PSV 2028 mentions it exactly once and tucks it into a sub-bullet under innovation (pages 62 to 64), even while it sets a target of connecting 100% of financial-service providers to open banking APIs (page 64). 

The intent’s clearly there, which is exactly why I’d love to see it carried further, because the CBN approved an August 1, 2025 go-live for open banking and the date came and went, and as of early 2026 it’s still not live. Five years on from the first framework, the one piece of infrastructure that would unlock everything in the point before it is the piece that most needs a date, a budget, and a push. Of everything on this list, this is the one I’d put first.

13. The one thing that would make all of this come to life

PSV 2028 stands up a steering committee, technical working groups (page 104), and a stakeholder-engagement framework (pages 105 to 106), which is solid governance and very much how the CBN likes to work. The part that worries me as missing is the one that turns a good plan into delivered outcomes, a costed budget, a sequence that respects what depends on what, and a simple public scorecard that says what should be true by when. 

We’ve all watched strong plans kick the bucket without that backbone, with the open banking go-live that drifted past its own date being the freshest reminder, and with thirty months on the clock, a published budget and an annual scorecard would protect this vision more than any new initiative inside it. Guys, this is the part to lock down, because it’s what lets us point back at this document in 2028 and say we did what we said we would.

The bottom line

PSV 2028 is the work of a central bank that’s earned its confidence, and most of it is the right work. The rails are real, the fraud fight is serious, the identity backbone is solid, and the habit of building policy with the industry is the quiet superpower that holds the whole thing together. 

What I’d love to see in the thirty months ahead is the part that turns all this plumbing into prosperity: payment data that becomes credit, an open finance rail that finally switches on, and a costed scorecard that keeps everyone honest. Get those three right and PSV 2028 won’t just move money faster; it’ll be the plan that moves Nigeria from moving money to building wealth. I want it to work, which is the only reason I read all 132 pages so you didn’t have to. 

Now let’s go and build it.

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Adedeji Olowe is the founder of Lendsqr, a Lending-as-a-Service (LaaS) company that provides the infrastructure powering digital lending for banks, fintechs, credit unions, and financial institutions.