The Central Bank of Nigeria has introduced new consumer protection guidelines requiring Deposit Money Banks and financial institutions to refund customers for failed ATM transactions within 48 hours. The draft policy, titled “Guidelines on the Operations of Automated Teller Machines in Nigeria,” was issued to banks, payment service providers, card schemes and independent ATM operators, with stakeholder feedback expected by October 31, 2025.
Under the proposed measures, failed “on-us” transactions, those conducted on a customer’s own bank’s ATM must be reversed automatically. Where instant reversal is not possible due to technical issues, banks are required to complete refunds manually within 24 hours. For failed transactions on other banks’ ATMs, refunds must be completed within 48 hours. The CBN emphasised that customers must not bear the consequences of system errors or network failures.
This marks a shift from a complaint-based resolution system to automated consumer protection. Banks and ATM operators will now have to deploy software capable of detecting failed transactions and triggering reversals without requiring customers to lodge complaints. Any funds held due to dispense errors must be reconciled immediately and refunded.
The guideline also tackles long-standing infrastructure gaps, including ATM shortages and poor maintenance. Each card issuer will be required to deploy at least one ATM for every 5,000 active cards, with phased compliance — 30 per cent by 2026, 60 per cent by 2027 and full compliance by 2028. This requirement is designed to improve access, particularly in rural areas, where Nigeria currently has fewer than 20 ATMs per 100,000 adults.
Any relocation, removal or deployment of ATMs will now require prior CBN approval, in line with its shift toward data-driven regulation of payment infrastructure.
Operational standards have also been tightened. All ATMs must be fitted with anti-skimming technology, CCTV, and be located in secure, well-lit environments. Machines must comply with Payment Card Industry Data Security Standards and maintain audit logs for regulatory review. To advance financial inclusion, at least 2 per cent of deployed ATMs must carry tactile features for visually impaired users — a first in the sector.
New service requirements will ensure machines:
- Dispense cash before returning cards to avoid retention.
- Allow free PIN changes and provide receipts for all transactions except balance inquiries.
- Dispense only clean notes and maintain regular cash replenishment.
- Run on backup power to support 24-hour operation.
Machines inactive for more than 72 hours must be publicly reported, with reasons and resolution timelines disclosed. The CBN will conduct routine audits and inspections, with monthly reporting on ATM deployment, functionality and location. Although fines were not detailed in the circular, industry stakeholders expect significant penalties for non-compliance, reflecting the enforcement stance of the current leadership.
