This open letter addresses the recent regulatory position attributed to the Central Bank of Nigeria (CBN), which restricts the modification of the phone number linked to a Ban Verification Number (BVN) to a single instance.
The directive was contained in a circular signed by the Director, Payments Systems Policy Department of the CBN, Musa Jimoh and issued to deposit money banks, merchant banks, non-interest banks, payment service banks, other financial institutions and mobile money operators.
The Governor,
Central Bank of Nigeria (CBN),
AN OPEN LETTER TO THE CENTRAL BANK OF NIGERIA (CBN) ON THE RESTRICTION OF BVN
LINKED PHONE NUMBER MODIFICATIONS: Ensuring Alignment of BVN Data Update Policies with Data Protection Rights and Financial Inclusion Objectives
The Digicivic Initiative respectfully writes to commend the Central Bank of Nigeria (CBN) for its continued
efforts to strengthen the integrity, security, and resilience of Nigeria’s financial system, particularly through identity management frameworks such as the Bank Verification Number (BVN).
We acknowledge that recent regulatory measures concerning restrictions on changes to BVN-linked
phone numbers are motivated by legitimate concerns around fraud prevention, identity theft and the
protection of financial consumers.
However, we wish to draw attention respectfully and constructively to the implications of such restrictions
within the framework of Nigeria data protection Act, particularly Section 34(1)(V), which guarantees data
subjects the right to rectify inaccurate or incomplete personal data.
- Concern on the Right to Rectification
The limitation of BVN-linked phone number modifications to a single instance appears to inadvertently constrain a continuing statutory right. In practice, individuals may need to update their phone numbers multiple times due to legitimate circumstances, including: loss or compromise of SIM cards, changes in telecommunications providers, security concerns or fraud incidents, and evolving personal or professional needs. A one-time restriction may therefore result in persistent data inaccuracies, which could undermine both individual access to financial services and the overall reliability of the BVN system.
- Implications for Financial Inclusion and Consumer Protection
We are concerned that such a restriction, if applied rigidly, may: limit customers’ ability to securely access banking and digital financial services, disproportionately affect vulnerable and mobile populations, and create unintended barriers to financial inclusion, which remains a key national objective. A customer-friendly and people-centred financial system must ensure that individuals retain reasonable control over their identity data, particularly where such data is central to service access and authentication.
- Opportunity for a Balanced, Risk-Based Approach
We respectfully submit that the objectives of fraud prevention and data protection are not mutually exclusive. A more balanced approach could include: – allowing multiple phone number updates subject to enhanced identity verification protocols; – implementing risk-based thresholds and monitoring mechanisms for frequent changes; and – strengthening audit trails and fraud detection systems without restricting legitimate user rights. Such measures would preserve the integrity of the financial system while remaining consistent with data protection principles and global best practices.
In line with Nigeria’s commitment to a rights-based digital economy, we encourage continued collaboration between the CBN and the Nigeria Data Protection Commission (NDPC) to ensure that sector-specific regulations remain harmonized with overarching data protection laws.
Digicivic Initiative remains committed to supporting regulatory efforts that promote secure, inclusive, and rights-respecting digital systems. We respectfully urge the CBN to review the current restriction on BVN linked phone number changes to ensure alignment with statutory data protection rights and to reinforce public trust in Nigeria’s financial ecosystem.
We would be pleased to engage further with the CBN on this matter and contribute to the development of balanced, forward-looking regulatory solutions.
This letter is issued in the public interest to promote responsible data governance, consumer protection, and inclusive financial regulation in Nigeria.
Please accept the assurances of our highest consideration.
Yours faithfully,
Mojirayo Ogunlana
Executive Director, Digicivic Initiative
For more information, please visit Digicivic Initiative’s Instagram, X and LinkedIn or contact:
Morisola Alaba-Akinlabi
Program Coordinator, DigiCivic Initiative
digicivicinitiative@gmail.com
Digicivic Initiative, registered as ‘ADVOCATES FOR THE PROMOTION OF DIGITAL RIGHTS AND CIVIC
INTERACTIONS INITIATIVE’ is a non-governmental entity and is deeply driven by public interest. Our
core mission revolves around advocating for digital rights and civic space. We aim to raise awareness
about digital rights, empower individuals to actively safeguard these rights in accordance with legal
frameworks and collaborate with other industry experts and organizations to create a world in which digital rights are respected and civic space can thrive.
As part of this mission, we actively promote and protect freedom of expression, access to information,
data protection and privacy, and the rights to freedom of association and peaceful assembly.
We also support meaningful civic engagement, both online and offline, recognizing the increasingly interconnected nature of digital and physical spaces in shaping democratic participation and accountability.