Pre-Event Survey: Data Localisation Directive: Financial Institutions and Payment System Participants

Please submit one consolidated response per institution by [Date]. The response should be coordinated by the executive responsible for the localisation programme, with input from technology, compliance and risk. Estimated completion time: about 15 minutes.

Purpose & confidentiality

This survey is a diagnostic planning instrument, not a compliance assessment or enforcement return. Responses will be used solely to prepare regulator briefings, session themes, panel questions and roundtable discussion guides, and to plan post-event follow-up. Individual responses will be seen only by the Joint Secretariat [name the unit], will not be passed to supervisory or enforcement teams, and will not be used as the basis for any supervisory action. Findings will be aggregated and reported without attribution to any institution. Please do not provide sensitive customer data, security configurations or detailed system architecture.

Key terms

'The Circular' means the CBN circular of 15 June 2026 on market structure, data localisation, ultimate beneficial ownership disclosure and systemic oversight in the Nigeria payments system [insert reference number]. 'In-scope data' means the payment transaction data your institution currently treats as subject to the Circular's localisation requirement; an 'in-scope system' is an application or platform that holds it. 'Hosted in Nigeria' means stored on infrastructure physically located in Nigeria. 'Managed in Nigeria' means operated and administered by personnel located in Nigeria. These are working definitions for this survey only, not regulatory interpretations; where your institution's reading differs, answer on your own reading and say so in Section C.