KYC Requirements Nigeria — CBN Three-Tier Framework for Banks and Fintechs

The CBN three-tier KYC framework

Tier	Verification required	Daily transaction limit	Balance limit
Tier 1	BVN or NIN linkage; self-declaration of name, address, and date of birth	NGN 30,000	NGN 300,000
Tier 2	Government-issued photo ID (national ID card, driver's licence, international passport, or voter's card) plus address verification	NGN 500,000	NGN 500,000
Tier 3	Full KYC: Tier 2 requirements plus liveness check, source of income/funds documentation, and beneficial ownership verification where applicable	No limit	No limit

Since December 2023, the CBN requires that all Tier 2 and Tier 3 accounts must have both BVN and NIN linked. Accounts that had only one of these must be updated. Institutions cannot upgrade a customer from Tier 1 to Tier 2 or above without confirming both identifiers are present and valid.

BVN — Bank Verification Number

The BVN is an 11-digit unique identifier issued by NIBSS (Nigeria Inter-Bank Settlement System) to bank customers. It links a customer's biometric data — fingerprints and facial image — to their banking identity across all Nigerian financial institutions. A customer can only have one BVN regardless of how many accounts they hold across different banks.

BVN is used to verify that a person exists in the banking system, cross-check identity across institutions, and detect individuals who have been flagged for financial crime. The CBN requires all account holders to have a linked BVN except for the most basic Tier 1 accounts, which can be opened with NIN as an alternative.

NIN — National Identity Number

The NIN is an 11-digit unique identifier issued by the National Identity Management Commission (NIMC). It is linked to biometric data collected at NIMC enrolment centres and serves as Nigeria's primary national identity credential. Unlike the BVN, which is banking-specific, the NIN is a general-purpose identity number used across government services.

The CBN's December 2023 directive requiring both BVN and NIN for Tier 2 and above accounts strengthened identity verification by requiring customers to be verified against both the banking system's biometric database (BVN/NIBSS) and the national identity database (NIN/NIMC).

KYC for corporate accounts

Corporate accounts require a different KYC process that includes verification of the entity's legal existence, beneficial ownership, and the authority of the individuals acting on its behalf:

Certificate of Incorporation from the Corporate Affairs Commission (CAC)
CAC extract or status report confirming the company's registered details
Memorandum and Articles of Association
Board resolution authorising the account opening and naming authorised signatories
KYC documentation for each beneficial owner holding 5% or more of the entity
KYC documentation for all directors and authorised signatories
Proof of business address

Ongoing KYC and periodic review

KYC is not a one-time event. The CBN requires institutions to conduct periodic reviews of customer information based on risk level. High-risk customers (including PEPs) must be reviewed at least annually. Medium-risk customers at least every two years. Low-risk customers every three to five years. Any material change in customer circumstances — change of address, change of business activity, large increase in transaction volume — should trigger an ad hoc review outside the regular cycle.

Frequently asked questions

Can a Nigerian customer open a bank account without a BVN?

Yes, but only a Tier 1 account, which can be opened with a NIN as an alternative to BVN. Tier 1 accounts have a NGN 30,000 daily transaction limit and NGN 300,000 balance limit. To upgrade to Tier 2 or above, both BVN and NIN must be linked since December 2023. A customer who has neither BVN nor NIN can only hold a Tier 1 account.

Does the three-tier KYC framework apply to fintechs?

Yes. All CBN-licensed financial institutions are required to apply the three-tier framework, including fintechs, payment service providers, and mobile money operators. Digital-only institutions must apply the same verification standards as traditional banks — they cannot lower KYC requirements on the basis of being a mobile-first service. The CBN's framework was specifically designed to accommodate digital onboarding through BVN and NIN verification APIs.

What is liveness detection and when is it required?

Liveness detection is a biometric verification technique that confirms a person presenting a face image or video during remote onboarding is a live human being, not a photograph or video replay. It is required for Tier 3 onboarding. The CBN expects institutions conducting digital Tier 3 onboarding to use liveness detection to prevent identity fraud during the biometric verification step.