A Lagos founder building a payment gateway read the CBN fee schedule before filing. She noted: NGN 100,000 application fee. NGN 1,000,000 licensing fee on approval.
She had not yet read the page about capital requirements.
The CBN fee schedule is a public document. It publishes the application fee and the licensing fee paid on approval. What it does not publish in one place is the total cost structure a founder needs to survive the process.
A PSSP license requires NGN 100 million in shareholders' funds deposited with the CBN during the application. This capital does not earn a return during the approval period. The approval period runs up to 10 months. Approval-in-Principle takes 3 to 6 months. Final license issuance takes a further 2 to 4 months. During that window, the NGN 100 million is held, not deployed, not earning, and not available for operations.
Legal and compliance preparation to file a complete application runs NGN 3 million to NGN 10 million. The range depends on the complexity of the product and the legal team engaged. The CBN rejected or delayed 65 percent of license applications in 2024 due to errors in documentation or capital requirements. A rejection does not refund the legal fees or the application fee.
For an MMO license, the minimum capital deposit is NGN 2 billion. A Payment Service Bank license requires NGN 5 billion in minimum capital. The IMTO application fee, increased by the CBN, is now NGN 10 million before the full capital requirement is considered.
The PSSP path is the most common entry point for payment product founders in Nigeria. The capital requirement is the lowest of the major categories. It is still NGN 100 million committed before the product has processed a single transaction.
The math that catches founders is not the CBN fee. It is the combination. NGN 100 million locked for 10 months. NGN 3 million to NGN 10 million in legal fees. Ten months of pre-revenue runway required to reach the licensing window. Most teams raise enough capital to build. Few raise enough to survive the 10-month licensing window.
The founders who navigate this well are not the ones who file the fastest. They are the ones who budget for the full cost structure before filing. Capital locked for 10 months. Legal fees to file correctly the first time. Eighteen months of operating runway to cover the gap between application and first legal revenue.
The CBN fee schedule publishes the regulatory cost. Nobody publishes the total cost. That gap is where founders get surprised.
