In a few days from now, the recent directive issued by the Central Bank of Nigeria (CBN) on advertising and promotional practices will come into effect.
Issued as a Letter to All Banks, Payment Service Banks and Other Financial Institutions (as defined under BOFIA, 2020) and titled “Compliance with Regulatory Provisions on Advertisement and Immediate Withdrawal of Non-Compliant Advertisements,” the directive reinforces long-standing regulatory expectations around financial communication.
The directive requires that advertising in the financial services sector be factual, balanced, transparent, non-inductive, non-comparative, and fully compliant with existing laws.
It further mandates the immediate withdrawal of non-compliant materials, personal sign-off by senior executives, and follow-up reviews, with sanctions commencing in January 2026.
This intervention can be understood within Nigeria’s broader economic ambition to build a $1 trillion economy by 2030. Such a goal cannot be achieved through capital adequacy alone. It requires trust at scale—from depositors, investors, counterparties, and increasingly discerning consumers. In modern economies, advertising functions as information infrastructure, shaping participation, adoption, and capital flow.
When financial institutions communicate poorly or misleadingly, trust erodes faster than weak balance sheets can explain. CBN rightly affirms that advertising communication is a creative expression with prudential consequences, particularly in the final stretch of recapitalization and consolidation.
Understanding the Issues
The central issue is not just the need for communication regulation, but the scope and focus of what is being regulated.
Between March and August 2025, Nigeria’s consumer protection authorities recorded over 4,600 complaints against banks and fintech firms, making financial services the largest source of consumer grievances. The Federal Competition and Consumer Protection Commission reported recovering more than N10 billion for affected consumers within this period.
The complaints ranged from unfair charges and unauthorized deductions to service failures, deceptive marketing practices, poor disclosure, and unresolved disputes. The CBN Financial Stability Report for 2024 similarly indicates a significant increase of 45 percent of financial fraud with 70 percent of the associated losses attributed to digital channels, particularly unregulated virtual asset platforms.
The insight here is critical. The problem is not advertising claims alone, but the entire customer communication and experience value chain. Advertising is only one part of a broader ecosystem that includes product and service design, disclosure and transparency frameworks, customer education, crisis and issue management, User Experience (UX), digital interface messaging such as push notifications and in-app prompts, data-driven personalization, and algorithmic content delivery across multiple channels.
For example, while CBN has consistently issued pragmatic timelines for refunds on failed ATM, POS, and online transactions 48 to 72 hours; many customers continue to experience delays from the financial institutions stretching into weeks or months, sometimes without resolution. Indeed, Advertising (Paid media) represents only a fraction of how banks engage customers today. Effective regulation must therefore reflect this reality.
A Crowded Regulatory Stage
Financial marketing in Nigeria does not suffer from a lack of regulation; it suffers from regulatory congestion. While the Basel Accords (Basel I, II, and III) do not regulate marketing or advertising directly, they set prudential expectations around governance, disclosure, and risk management that require all external communications including marketing to be accurate, transparent, and aligned with a bank’s risk profile.
Against this backdrop of an already dense regulatory environment, CBN’s effort to reinforce compliance has tended to rely on layering additional rules to preserve the effectiveness of its internal hygiene standards. In practical terms, the recent directive has triggered familiar, compliance-heavy responses: senior executives racing to meet compressed attestation timelines and ad-hoc committees being set up to withdraw or extinguish historical marketing assets.
Such knee-jerk actions reduce digital visibility, erode SEO value and trust, increase marketing costs, and ultimately weaken brand equity—effects that can also weigh negatively on shareholder value across the banking sector.
A Realistic Path Forward
What is required is deliberate cross-regulatory dialogue to clearly define how marketing communication affects financial system stability, especially in an era of user-generated content where customers do not require regulatory approval to tell their personal stories. Silence, in such a context, is rarely neutral; it often lets the loudest narrative win by default. Indeed, it is doubtful that the regulator has the internal toolkit to regulate digital communication realtime.
As Banks, fintechs, mobile money operators, and digital banking platforms continue to reshape the financial services landscape, regulation must strike a careful balance between innovation and stability. Institutions must be empowered with the ability to respond promptly with facts, clarity, and accountability not with folded arms, legal disclaimers and rebuttals.
In this context, CBN should revisit and strengthen the Guidelines for the Management of Reputational Risk (2019), aligning them with the Consumer Protection Regulations and related frameworks. Consolidated in this way, they can serve as a practical guide to managing the experience value chain—brand, product, customer, and employee
Industry bodies such as the Association of Corporate Communication and Marketing Professionals in Banks (ACAMB) are better positioned to act as local champions and custodians of ethical communication, while statutory institutions like the Nigerian Institute of Public Relations (NIPR) and the National Institute of Marketing of Nigeria (NIMN) should be engaged as partners in shaping the future of communication and advertising in Nigeria’s financial services sector.
Ultimately, financial stability and long-term market confidence are shared objectives. When everyone carries the load, the road becomes shorter.
Dr. Nduneche Ezurike is an opt-in member of the Harvard Business Review Advisory Council and a Fellow of the National Institute of Marketing of Nigeria (NIMN). He writes from Lagos
