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As of early 2026, the CBN has finalized the ‘Payment Aggregator Standard (PAS),’ clarifying the role of middle-men in the fintech ecosystem. A Payment Aggregator connects multiple merchants to various payment gateways. If your business facilitates payments for other vendors, you must check your fintech licensing category immediately.
The “Zero-Threshold” Data Mandate
Under 2026 rules, aggregators must provide ‘Zero-Threshold’ reporting. This means every single transaction, regardless of size, must be visible to the CBN’s monitoring system. This is a core part of the AML/CFT compliance drive. You must also ensure your electronic payment checklist is updated for 2026.
2026 Aggregator Requirements:
- Escrow Separation: Merchant funds must never be mixed with the aggregator’s operational cash.
- PSSP Partnership: All aggregators must be backed by a licensed Payment Solution Service Provider.
- Cybersecurity: Must pay the 0.5% Cybersecurity Levy on all aggregate transfers.
The Transition to Open Banking
In 2026, aggregators are the primary beneficiaries of Open Banking Phase 2. They can now use APIs to verify merchant balances instantly, reducing the risk of bounced settlements.
Step-by-Step: Staying Compliant as an Aggregator
- Obtain the PAS License: Apply via the CBN Fintech Office if you process over ₦50m monthly for third parties.
- Link to NIBSS: Ensure your ‘Switch’ is certified by the Nigeria Inter-Bank Settlement System.
- Audit Merchant KYC: You are legally responsible for the KYC of the merchants you aggregate.
- Implement 3DS 2.0: Ensure all web transactions use the latest 2026 authentication standards.
Practical Example: The ‘Market-App’ Startup
‘Oja-Pay’ aggregates 500 small market women. In 2025, they operated without a formal license. In 2026, the CBN flagged their volume. By partnering with a Tier-1 bank as a ‘Licensed Aggregator’ and automating their suspicious transaction reporting, they avoided a shutdown and secured a venture capital round.
External Resources
See the NIBSS portal for aggregator standards. For global payment news, visit Finextra.
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