The gap between CBN account rules and Nigeria’s bank counters

IN January 2013, the Central Bank of Nigeria (CBN) told banks it had taken steps to ensure that “the socially and financially disadvantaged persons should not be precluded from opening accounts or obtaining other financial services for lack of acceptable means of identification.” The circular that said so introduced the three-tiered Know Your Customer (KYC) regime, and its lowest level asks for basic personal details with no documents to back them up.

Thirteen years later, the counter does not always follow the circular. In 2026, Liners researchers walked into 100 bank branches across 18 Nigerian banks to open the account most people open first, an individual savings account, using valid Bank Verification Numbers (BVN) and National Identification Numbers (NIN). At 54 of those 100 visits, they were asked for proof of address.

That number alone proves little, because a bank may open a higher-tier account that lawfully needs more paperwork. The more useful question for a customer is whether a request comes from the rule or from the branch, and whether anyone at the desk says which.

The study was built to record what an ordinary first-time customer meets at the counter, using the same checks at every visit. Its full counts are published in the bank-by-bank tables on the study page. Every study figure in this article can be checked against them or worked out from them.

Method: Liners researchers opened individual naira savings accounts in person at bank branches, using valid BVNs and NINs. Most banks were visited by several independent researchers. At each visit, they logged:

Sample: 100 logged walk-in visits across 18 banks, in branches in Lagos and Ibadan, with a few in Ogun and Ondo. Visits per bank ranged from 10 at Polaris Bank to one at Keystone Bank. Branches were not picked at random; in the study’s own words, “Sample sizes are uneven by design; we went where a first-timer would go.” The study also logged 31 online openings at five digital banks; this article uses only the walk-in visits.

Scope: Walk-in opening of an individual naira savings account. It did not cover:

Limitations: In the study page’s own words, “This is a field study, not a statistically representative survey… it is not enough to claim a precise national rate for any single bank.”

For a Level 1, low-value account, the CBN’s three-tiered KYC circular asks only for basic customer information, such as a passport photograph and personal details, and adds: “Evidence of information provided by customer or verification of same is not required.” It also states that “No amount is required for opening of accounts”, and the same line appears at Levels 2 and 3.

Evidence starts at Level 2, which requires “Evidence of basic customer information” such as the customer’s name and address, with a passport photograph. Full documents come in at the top tier. For a Level 3, high-value account, “Banks are required to obtain, verify and maintain copies of all the required documents for opening of accounts”, and the account “is to be opened at the bank branches by physical presence of the prospective customer.”

The identity step has tightened since then. In December 2023, the CBN required Tier 1 accounts and wallets to have either a BVN or a NIN, with account opening to start by “electronically retrieving BVN or NIN-related information”, which becomes “the primary information for onboarding of new customers,” as The ICIR reported at the time.

On paper, then, a Tier 1 customer with a BVN or NIN needs no document to prove an address. So what were branches asking for?

Proof of address was requested at 54 of the 100 visits, and a utility bill in particular at 13. Nine of those 13 utility-bill requests came from just three banks.

The sharper pattern is inside individual banks. Of the 17 banks visited more than once, 14 asked for proof of address at some visits and not at others. Two banks asked at every visit (six of six, and five of five), and one never asked in five visits.

At least 27 of the 100 visits asked for proof of address without the customer being told which tier the account was on. In those cases, the customer had no way to know whether the paperwork belonged to a higher-tier account, which the circular allows, or to the branch’s own practice. Across all 100 visits, the tier was explained at 29.

The study’s published tables do not show which tier each bank opened, so they cannot show that any single request differs from what the 2013 circular requires of a Tier 1 account. What they can show is that the customer was not told.

The circular is just as plain about money. At 87 of the 100 visits, researchers were not asked for an opening deposit, in line with the circular’s “No amount is required” line.

At the other 13, a deposit was requested. Five of those requests came from a single bank, which asked at every one of its five visits for between ₦1,000 and ₦3,000. Two came from one branch, and six were one-off requests at six other branches.

Most branches matched the rule. The exceptions matter because they fall on the first-time saver the tiered system was written for.

The CBN’s Consumer Protection Regulations of December 2019 are clear about what a customer should hear before signing. Section 4.3.1 requires institutions to “Disclose all terms and conditions of a product or service on offer, as well as the features, risks, benefits, fees and other associated charges.”

For deposit products, section 4.5.2 adds the “minimum balance requirement and other limit on account balances or transactions where applicable” and the “monthly maintenance fee” to what the contract or letter of offer must disclose. In the study, transaction limits were explained at 16 of the 100 visits. At eight of the 18 banks, covering 41 visits, no researcher was told their limits.

Fees fared worse. Maintenance or SMS-alert fees came up at nine visits, and at the other 91 the researcher was told nothing about them.

In April 2026 the CBN circulated a draft revised Guide to Charges by Banks and Other Financial Institutions which, according to Nairametrics, would replace the 2020 guide once final and would require institutions to “draw the attention of customers to their rights to negotiate” where a charge is negotiable. The duty to disclose already exists in the 2019 text; the gap is delivery at the desk.

The researchers were documented adults, so this section leans on other evidence too. EFInA’s Access to Financial Services in Nigeria 2023 survey found that “approximately 40million adult Nigerians remain formally excluded.” Among adults without a bank account, the reasons given include these:

The barrier EFInA groups as institutional exclusion rose from 22 per cent in 2020 to 29 per cent in 2023. The 2019 Regulations already tell institutions to “Consider the needs of the financially excluded”, and the vulnerable groups they name include the “physically challenged and the non-literate”.

At one Lagos branch, a researcher described the account-opening form like this: “Someone who is not used to filling bank forms may find this one frustrating. The texts were tiny, and you may not know which sections to fill unassisted.” At 10 of the 100 branches, the entrance had steps and no ramp.

For a customer without a utility bill, or one who cannot read small print unaided, a proof-of-address request that changes from branch to branch is a bigger obstacle than it was for the researchers. That is an inference, since no such customer was in the sample.

Banks have a case. A bank official told Zikoko in 2022 that “The accounts that require a utility bill are the tier 3 accounts,” the highest level, and that a person without a home “can have a tier 1 account,” in which case “the bank marketers may just write down the address of the place they met the customer.”

Identity checks have also become stricter since December 2023. Asking for documents is lawful for a higher-tier account, and a bank may reasonably prefer to open one.

That case holds when the customer is told it is a choice. The 2013 circular allows a Tier 1 start, and a customer who hears that at the desk can decide whether to come back with a utility bill or begin without one.

The fixes the evidence supports are about saying the rule out loud. Banks could print the Tier 1 requirements at every account-opening desk, and write the tier and its limits on the confirmation a new customer takes home.

The CBN, which already sets the disclosure duty in its 2019 Regulations, could test branch practice through mystery shopping and publish the results by bank.

Thirteen years after the CBN wrote that no one should be shut out “for lack of acceptable means of identification,” a first-time saver still has to be told the rule exists before it can help them.

The author works at Liners, where people find software built for Africa; the company ran the study described in this article.

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