On 27 November 2025, the Central Bank of Nigeria (CBN) issued a circular (Ref: CMD/DIR/PUB/CIR/001/003) to banks, payment service banks, and other financial institutions (the Circular). The Circular introduced enhanced compliance requirements governing advertising and promotional practices in the financial services industry.
According to the CBN, the Circular is an outcome of a thematic review conducted by the CBN, which identified material inconsistencies in how institutions interpret and implement the disclosure, transparency, and fair-marketing obligations prescribed in the Consumer Protection Regulations 2019 (CPR) and the Guidelines on Advertisements by Deposit-Taking Financial Institutions 2000.
The review highlighted significant variations in industry practices, particularly relating to the clarity of disclosures, accuracy of promotional claims, and the robustness of internal compliance checks, prior to public communication.
It is against this backdrop that the CBN issued a set of clarifications and directives to realign the industry with established regulatory standards.
1. Accuracy and Transparency: Firstly, the Circular reiterates that all advertisements must be factual, balanced, transparent, and free from misleading impressions.
2. Prohibited Marketing Practices: Secondly, Financial institutions are expressly barred from:
2.1 exaggerating product benefits;
2.2 omitting material information;
2.3 referencing unaudited financial statements in promotional materials;
2.4 comparative or superlative claims including direct or implied statements that de-market competitors;
2.5 promotional inducements such as lotteries, prize draws, or lucky dips.
3. Pre-Release Advertisement Notifications: To ensure accountability, the CBN has also specified the minimum content required when submitting notifications for advertisements prior to their release. Institutions must now provide full details of:
3.1. the advert’s duration and timelines;
3.2. creative materials to be aired or published;
3.3. target demographics;
3.4. written confirmation of internal clearance by Compliance and Legal; and
3.5. evidence that the underlying product or service has received requisite CBN approval.
Importantly, the CBN emphasised that the notifications are strictly for monitoring purposes and do not constitute regulatory approval or endorsement.
Grace Period & Required Action
Further to the Circular, the CBN has directed all institutions to immediately withdraw any ongoing advertisements or promotional materials that do not conform to existing regulations.
Furthermore, within 30 (thirty) days of the Circular, institutions are required to submit a compliance attestation jointly signed by the Managing Director/Chief Executive Officer, Executive Compliance Officer, and Chief Compliance Officer, confirming full alignment of all advertising and promotional practices with applicable laws, regulations, and internal governance protocols.
Commencing January 2026, the CBN will conduct a follow-up review and impose sanctions for any identified breaches in accordance with BOFIA 2020 and the CPR.
Conclusion
In summary, it is our opinion that this development reinforces the CBN’s commitment to strengthening consumer protection, promoting responsible marketing, and fair competition within the Nigerian financial system.
We also anticipate more stringent supervisory outcomes – including the imposition of substantial sanctions on non-compliant entities by January 2026 to deter further non-compliance.
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