The CBN Risk-Based Cybersecurity Framework
The CBN maintains strict cybersecurity guidelines for Other Financial Institutions (OFIs) and Payment Service Providers (PSPs). The framework emphasizes a proactive approach to identifying and mitigating technical vulnerabilities.
Vulnerability Assessments
The CBN requires periodic vulnerability assessments to identify weaknesses in your infrastructure, applications, and APIs. These generally must be conducted at least twice annually, and major findings must be remediated promptly.
Penetration Testing
Annual penetration testing by independent, qualified third parties is a standard requirement. The test must simulate real-world attacks against your production-equivalent environments to prove that your defenses hold up under active exploitation.
Data Protection (NDPR/NDPC)
The Nigeria Data Protection Commission requires strict controls over PII (Personally Identifiable Information). Penetration testing proves to auditors that your customer data—like BVNs and transaction histories—cannot be exposed via API flaws (like BOLA) or insecure storage.
Secure Software Development Lifecyle (SSDLC)
Regulators increasingly look at how you build software, not just the finished product. Integrating security reviews into your sprint cycles demonstrates a mature SSDLC to CBN examiners.
How Simpa Labs reports support your audit
A compliance auditor evaluating your application needs proof that you are actively seeking and fixing vulnerabilities. A generic scanner report often raises red flags because it lacks context.
Simpa Labs provides detailed, contextual reporting that helps satisfy auditor requests:
- Executive & Management Summaries: Clear, high-level overviews of your risk posture suitable for board members and CBN examiners.
- Methodology Documentation: Proof that testing was conducted manually using industry-standard frameworks (like OWASP) and tailored to your specific application architecture.
- Remediation Verification: We offer retesting services to provide documented proof that critical vulnerabilities identified in the initial test were successfully patched, completing the compliance loop.
Have a compliance deadline approaching? We scope and execute fast.
Get a Quick Security CheckRelated services and resources
To satisfy CBN requirements, you'll typically need a vulnerability assessment (required at least twice annually) and annual penetration testing. For additional developer guidance, see our fintech security checklist and the OWASP Top 10 for fintech. We test across mobile money, payment gateways, digital banking, and lending platforms.
Frequently asked questions
What are the CBN cybersecurity requirements for fintech companies?
The CBN requires licensed fintechs (PSSPs, MMOs, MFBs, switching companies) to conduct periodic vulnerability assessments (at least twice annually), annual penetration testing by independent third parties, implementation of a Secure Software Development Lifecycle (SSDLC), and compliance with NDPC data protection standards. Reports must demonstrate testing against real-world attack scenarios, not just automated scanner output.
How often must a CBN-licensed fintech do penetration testing?
The CBN requires penetration testing at least annually by an independent, qualified third party. Vulnerability assessments are required at least twice per year. However, we recommend quarterly testing for fast-shipping teams, especially after major feature releases or integration changes.
Can a Simpa Labs report be submitted to CBN examiners?
Yes. Our reports include executive summaries for board members and CBN examiners, detailed methodology documentation proving manual testing using OWASP frameworks, and remediation verification certificates. They are specifically structured to satisfy CBN examiner expectations for independent security testing evidence.
What happens if a CBN-licensed fintech lacks security testing evidence?
Without evidence of independent security testing, you risk regulatory sanctions during CBN examinations, increased liability if a breach occurs, and potential issues with license renewal. The CBN's Risk-Based Cybersecurity Framework explicitly expects proactive vulnerability identification and remediation.