Only 59% Of Financial Institutions Ready For January Data Localisation Deadline

Only 59 per cent of surveyed financial institutions in Nigeria expect to complete measures required for data localisation by January 1, 2027, raising concerns over implementation readiness as the deadline approaches.

At a pre-event survey presented in Lagos, at the Central Bank of Nigeria (CBN)–National Information Technology Development Agency (NITDA) Executive Regulatory Dialogue by Special Assistant on Digital Transformation to the DG NITDA, Dr Aminu Lawal remarked that 26 of the 44 institutions that answered the readiness questions had either completed the required actions or considered completion likely.

However, 15 institutions, representing 34 per cent, said they were unlikely or very unlikely to finish by the deadline, while three said they could not assess their readiness.

The survey which covered financial institutions and digital infrastructure providers, identified uncertainty over the scope of payment transaction data and the meaning of storing and managing data in Nigeria as major obstacles to implementation.

The findings come amid efforts to strengthen domestic digital infrastructure and clarify the regulatory expectations governing the handling, storage and processing of financial-sector data.

According to the presentation, 64 per cent of respondents identified the definition of “payment transaction data” as an area requiring clarification, while 38 per cent sought clearer guidance on what qualifies as data being stored and managed in Nigeria.

The questions include whether metadata, system logs, backups, historical records, derived data, offshore disaster-recovery copies and remote administrative access fall within the applicable requirements.

The survey also exposed a gap between preliminary planning and actual implementation. While 70 per cent of responding institutions said they had identified the data and systems within scope, only 52 per cent had mapped their hosting and administration arrangements.

Furthermore, 32 per cent had developed migration or remediation plans, 25 per cent had secured board or executive approval and budgets, and 23 per cent had contracted local providers. Only 18 per cent had commenced migration or remediation, while 16 per cent had migrated at least one in-scope system.

The presentation identified funding, regulatory interpretation, migration timelines and operational disruption among the major challenges facing institutions as they prepare for the deadline.

Nevertheless, the findings suggest that Nigeria’s local digital infrastructure market may be able to accommodate part of the anticipated demand. Of the 42 infrastructure and service providers surveyed, 79 per cent said they were ready to take on additional financial-sector workloads, while 74 per cent said they could onboard a new financial customer within three months.

Additionally, 83 per cent said they could provide Nigeria-only data arrangements under contract, while 79 per cent reported holding ISO/IEC 27001 certification, an international standard for information security management systems.

The presentation, however, cautioned that provider readiness was self-assessed rather than independently verified. It also noted that significant new infrastructure capacity was expected to come online mainly in 2027, meaning some expansion might not be available before the January deadline.

Meanwhile, financing and the cost of capital were identified by 55 per cent of providers as constraints to expansion, followed by power availability and cost at 38 per cent and foreign exchange challenges at 31 per cent.

The survey also highlighted differences between traditional banks with existing domestic infrastructure and cloud-dependent payment platforms that may need to reconfigure interconnected production systems.

Quoting an unnamed mobile money operator, the presentation noted: “Migrating this volume of interconnected workloads is not a lift-and-shift exercise.”

To address the challenges, 51 per cent of institutional respondents called for phased or risk-based implementation milestones, while the same proportion sought a defined process for exceptions and approvals. Another 47 per cent requested written regulatory guidance, including frequently asked questions, and 38 per cent called for better coordination among the CBN, NITDA and the Nigeria Data Protection Commission (NDPC).

The survey concluded that clearer regulatory definitions, practical transition arrangements and verifiable information on available local infrastructure would be critical to helping institutions complete the transition.

The findings were based on responses collected between October 13 and 27, 2026, from 47 financial institutions counted once and 42 infrastructure and service providers. Of the financial institutions, 44 answered the readiness questions, while three said the circular did not apply to them.

The presentation stressed that the responses were self-reported, anonymised and aggregated, and should not be interpreted as a formal assessment of individual institutions’ compliance with regulatory requirements.