Cardoso says instalment payment options offered by businesses outside the banking system could create regulatory and consumer protection gaps……
The Central Bank of Nigeria is examining the regulatory implications of a growing trend in which non-financial companies allow customers to pay for goods and services in instalments.
CBN Governor Olayemi Cardoso raised the concern while speaking through Abiodun Olalekan Okunola, Head of the bank’s Innovation Management Division, at Nigeria Fintech Week 2026 in Lagos.
The governor pointed to the rapid expansion of embedded finance, a model in which businesses outside the traditional financial sector integrate financial services into their products and platforms.
According to Cardoso, the growing practice is creating questions around the boundaries of financial regulation, particularly when companies without banking or credit licences begin providing customers with financing options.
He cited travel companies Air Peace and Wakanow as examples of businesses allowing customers to spread payments for their services over time.
“If you go to Air Peace and you try to book a ticket, you’ll see where they tell you where you want to pay ‘small small,’ right? And then if you go to Wakanow, Wakanow will say, ‘Oh, you want to go to Maldives or Bali,’ and it asks if you want to pay ‘small small,” he said.
For the CBN governor, the central issue is whether such arrangements amount to the provision of credit by companies that are not traditionally regulated as financial institutions.
“Now, think about it: they are offering credit. For us, they are non-bank, they are not licensed to offer credit. How do we regulate?” he said.
Consumer protection also in focus
Cardoso said the regulatory challenge goes beyond determining which institution should oversee the businesses.
He questioned what happens when customers have disputes with companies providing such payment arrangements and attempt to seek help from the CBN’s consumer protection framework.
“Because it means that when your rights are trampled there, if you come to CBN Consumer Protection and ask us, we’ll be like, ‘Who… are they even licensed?’” he said.
The governor’s comments come as embedded finance becomes more prominent in Nigeria, with businesses increasingly using customer data and digital platforms to provide financial products alongside their core services.
Cardoso identified embedded finance as part of a broader transformation taking place across the financial system, alongside developments in artificial intelligence, open banking, digital money and cross-border commerce.
‘Pay small small’ gains ground
The instalment-payment model, commonly associated with Buy Now, Pay Later services, has been expanding rapidly within Nigeria’s consumer-credit market.
The Nigerian Buy Now, Pay Later market was projected to grow from $1.42 billion in 2024 to $2.61 billion by 2030, according to a 2025 report cited by Nairametrics. At the time, more than 400 digital lenders were operating in the country.
The model is also extending into sectors such as travel.
In 2025, Kalabash, the fintech subsidiary of Wakanow Group, partnered with Outpayce, the payments arm of Amadeus, to expand its Pay Small Small travel-payment solution across airline and travel platforms.
The expansion of digital lending has, however, attracted increased regulatory scrutiny.
As of September 2026, 525 digital lenders had been registered with the Federal Competition and Consumer Protection Commission, while another 33 were operating under waivers because they already held licences from the CBN.
The FCCPC has also been enforcing rules covering consumer protection, lending practices and debt recovery.
The latest concerns raised by the CBN highlight a regulatory question that is becoming increasingly relevant as financial services move beyond traditional banks: where should oversight begin and end when ordinary businesses start embedding credit and payment products into their services?
