Nigeria’s Approved Persons’ Regime: Experience Thresholds, Biennial Assessment and Remedial Training

Nigeria regulates who may hold senior positions in a bank through an experience ladder, a biennial re-assessment and a two-year remediation window — and, for microfinance banks, one mandatory named certification. What it does not have is a CPD hours requirement, which makes it the opposite of Bahrain in design.

A naming point first, because it matters when searching. The instrument is the Revised Assessment Criteria for Approved Persons' Regime for Financial Institutions, dated October 2015 and effective from 1 January 2016. It is widely referred to as a "fit and proper persons' regime", but that phrase is not its title. It supersedes the Central Bank of Nigeria's circular of 21 June 2011, reference FPR/DIR/CIR/GEN/01/016.

Who it covers

Section 1.2 applies it to commercial banks (regional, national and international), merchant banks, non-interest banks, primary mortgage banks, discount houses, development finance institutions and other financial institutions under the CBN's purview. Section 6 extends it to primary mortgage banks, microfinance banks, finance companies and bureaux de change, and section 7 covers significant shareholders — those holding 5% or more — of all financial institutions.

One drafting gap worth knowing: the document refers throughout to "board, top management and critical operational positions" but never defines "top management" for banks. Section 6 uses "Top Management (Departmental Heads)" for other financial institutions, which is the nearest thing to a definition.

The experience ladder

For banks, discount houses and development finance institutions, each position carries a minimum years-of-experience threshold and a required time in the rank below:

• Managing Director (5.1) — 20 years post-graduation, at least 15 in banking, at least 2 as DMD or ED
• Deputy MD / Executive Director (5.2) — 18 years, at least 13 in banking, at least 2 as General Manager. And a candidate must serve at least two years as DMD or ED to qualify for MD
• General Manager (5.3) — 15 years, at least 12 in banking, at least 2 as Deputy GM, with demonstrated experience in at least three areas of banking operations
• Deputy General Manager (5.4) — 15 years, at least 10 in banking, at least 2 as AGM
• Assistant General Manager (5.5) — 15 years, at least 10 in banking, at least 3 as senior manager or equivalent
• Non-executive director (5.6) — 8 years post-graduation, plus proven skills, knowledge of the sector and the ability to interpret financial statements
• Independent director (5.7) — "not less than 10 years of relevant working experience", with the NED requirements also applying

The academic requirement is consistent: a first degree plus, for executive roles, "a higher degree or professional qualification in any business related discipline", and for non-executive directors "membership of any other relevant and recognized professional institute". No specific professional qualification is named for any bank role.

Thresholds are lower across the other institution types — a microfinance bank MD needs 8 years with 5 in financial services and 3 at senior management; a bureau de change MD needs 3 years' relevant post-graduation experience. Microfinance bank non-executive director requirements scale by licence tier, with unit MFBs requiring no degree, state MFBs at least two graduate NEDs, and national MFBs "more than 80%".

Section 3.0 is clear that these are floors: the CBN "shall take into account all relevant considerations, including but not limited to factors listed against each of the positions", and section 8.3 calls the provisions "minimum requirements".

The one mandatory certification

Across the whole document, exactly one named certification is compulsory. Microfinance bank managing directors, executive directors and top management must have "undergone the microfinance Certification Programme and obtained a Certificate in Microfinance Banking issued by the Chartered Institute of Bankers of Nigeria (CIBN)" (sections 6.2.1 and 6.2.2).

CIBN appears elsewhere only as an example of a professional body whose fellows may provide reference letters, alongside ICAN. No other named qualification is required anywhere in the regime.

Non-interest banks have an additional subject requirement: Islamic banking knowledge or training under sections 5.1 to 5.5, and section 5.7(f) says such banks should "preferably" have an independent director who is "an expert in Islamic Commercial Jurisprudence (Fiqh Mu'amalat)".

Training: two provisions, no hours

There is no CPD requirement in this regime. There are two training obligations, and both are situational rather than periodic:

Directors' training (section 4.0). Non-executive directors must "undergo directors' training at the institution's expense, aimed at acquiring or having the prerequisite knowledge of their responsibilities and duties". No hours, no frequency, no deadline and no recording requirement are attached.

Remedial training (section 3.0). This is the more interesting one. A candidate who is "deficient or fail[s] the fitness test" has "a period of two years within which to undergo training to remedy the deficiency". If they cannot meet the requirements after that, "he/she may be required to relinquish his/her board/top management appointment".

So training is the prescribed remedy for a failed assessment, with a two-year clock and the loss of the position as the consequence. That is a stronger incentive attached to training than most CPD regimes manage, and it is entirely reactive.

The biennial assessment is the institution's job

Section 3.0 places a recurring duty on the firm, not the regulator: "the financial institution shall conduct an assessment of the fitness and propriety of its board/top management staff biennially or any other period as may be specified by the CBN. Performance on the job shall be an integral part of this assessment."

That second sentence is the one to note. This is not a document check — performance has to be assessed as part of fitness and propriety, every two years, for every board and top management position.

What the document does not say is who signs that assessment off, what form it takes, or what evidence must be kept. There is no record-keeping or retention provision anywhere in the regime. An institution wanting to show the CBN it has done the biennial assessment has to design that evidence itself.

What goes to the CBN

Section 4.0 requires the institution to submit a completed Approved Persons Regime questionnaire "to be administered by the CBN", a status report from the candidate's last place of work "not later than six months after engagement", and three reference letters — two from the last place of work, dated within the last five years, from persons "not below the rank of a director".

The questionnaire itself asks for evidence of qualifications, a net-worth statement with a sworn affidavit, a bankers' declaration and tax clearance for the last three years. Significant shareholders must additionally attend "an oral interview with the CBN" (section 7.0), and the questionnaire preamble notes the CBN "would periodically request you to attend a performance review interview".

Two things are absent from the process. The document does not say in terms that CBN approval is required before appointment — it says only that the CBN "may at its discretion, approve or disapprove the appointments". And no CBN processing timescale is given at all. The only stated periods are the six-month status report and the two-year remediation window.

The Framework it points at but does not contain

Section 8.2 is the regime's only reference to the separate competency instrument, and it is worth quoting because it creates an obligation without describing it:

"In addition to the general fitness and propriety requirements for Board and top management positions stated in these guidelines, any director or top management staff performing any of the control functions stated in the 'Competency Framework for the Nigerian Banking Industry' must meet the specific requirements of that function as outlined in the Framework."

The regime gives the Framework no date, no version and no status, does not list the control functions it covers, and does not reproduce any of its requirements. So anyone holding a control function in a Nigerian bank is subject to requirements this document makes binding and does not state. The Framework itself has to be obtained from the CBN.

Sanctions, and some drafting to watch

There is no penalty on the institution anywhere in the regime. The consequences all attach to the individual: relinquishing the appointment after a failed assessment and two years, and — for concealment or false information in the questionnaire — disqualification "from the appointment being sought and subsequent appointments by any financial institution under the purview of the CBN", plus prosecution for false declaration.

Three internal inconsistencies are worth flagging if you are citing the document. It cites BOFIA as "Cap. B3, LFN 2004" in section 2 but as "BOFIA, 1991, as amended" in the questionnaire declaration. Section 6.4 cross-refers to "4.4.1 or 4.4.2", which appear to be errors for 6.4.1 and 6.4.2. And the questionnaire uses the term "recertification" without defining it anywhere.

Three things to check

First, whether your biennial assessments have actually happened, and whether they assess performance on the job as section 3.0 requires rather than re-checking documents.

Second, whether anyone in a control function has been assessed against the Competency Framework, which section 8.2 makes binding without reproducing.

Third, for microfinance banks, whether every MD, ED and top management holder actually holds the CIBN Certificate in Microfinance Banking. It is the only mandatory certification in the regime and the easiest to assume rather than verify.

Compared with Bahrain's Training and Competency Module, which sets 15 CPD hours and seven record categories, Nigeria relies on entry thresholds and periodic re-assessment with no ongoing hours at all. South Africa's FSCA regime sits between the two. For structured development — including the remedial training a failed assessment triggers — see our CPD programmes.

Sources and limits: written from the Central Bank of Nigeria's Revised Assessment Criteria for Approved Persons' Regime for Financial Institutions, October 2015, effective 1 January 2016, read in October 2026. The document shows no amendment notes or revision history, but it is eleven years old and this copy cannot show whether it has since been amended or replaced — check the CBN's circulars directly. The Competency Framework for the Nigerian Banking Industry, which section 8.2 makes binding for control functions, was not read and is not summarised here. General information about a published instrument, not legal or compliance advice.