Abstract
Nigeria’s FinTech sector now functions as the primary channel of financial inclusion for millions of previously unbanked citizens, yet it operates without a unified cyber-security governance instrument. Unregistered schemes such as MMM Nigeria and CBEX have processed the financial data of millions of Nigerians under no 153IDEAS: Uniuyo Journal of Philosophy and Multi-Disciplinary Studies Vol. 2, No. 1, SEPTEMBER 2026 governance obligation whatsoever, while Chinese-backed superapp platforms such as OPay and PalmPay, which together serve more than 30 million accounts, raise unresolved data-sovereignty questions. This study designed the Nigerian FinTech Cybersecurity Governance Framework (NFCGF), a six-layer, tiered, and implementable governance architecture grounded in the principles of Transparency, Accountability, and Explainability (TAE). The framework was developed using Design Science Research (DSR) methodology, drawing on quantitative and comparative evidence from Nigeria, Kenya, India, South Africa, and Ghana, and benchmarked against ISO/IEC 27001:2022, NIST CSF 2.0, PCI DSS v4.0, COBIT 2019, and SOC 2 Type II. A structured rubric-based expert review (n = 3) across five evaluation criteria produced an aggregate mean score of 4.20 out of 5.0 and yielded three traceable revisions. The NFCGF’s mandatory pre-operational registration requirement, its OPay/PalmPay backend audit protocol, and its four-tier cost-proportionate implementation model together provide a governance pathway applicable to Nigerian FinTech operators of every size. The study concludes that institutional will, not framework design, is the harder constraint on implementation, and recommends a multi-round Delphi validation and pilot deployment as the necessary next stage.
Keywords: Cyber-security Governance, Nigerian FinTech, Financial Inclusion, Data Sovereignty, Regulatory Compliance.
Authors:
Jennifer Chiamaka Udeh
Department of Cyber Security, Faculty of Computing, Air Force Institute of
Technology, Kaduna, Nigeria
Corresponding Author Email: udehjennifer73@gmail.com
Osichinaka Chiedu Ubadike
Department of Aerospace Engineering, Faculty of Air Engineering, Air Force
Institute of Technology, Kaduna, Nigeria
Adeniran Kolade Ademuwagun
Department of Cyber Security, Faculty of Computing, Air Force Institute of
Technology, Kaduna, Nigeria
Obunike Arinze Ubadike
Department of Computer Science, Faculty of Computing, Air Force Institute of
Technology, Kaduna, Nigeria
Samaila Musa Abdullahi
Department of Cyber Security, Faculty of Computing, Air Force Institute of
Technology, Kaduna, Nigeria
Dr. Suleiman Abu Usman
Department of Cyber Security, Faculty of Computing, Air Force Institute of
Technology, Kaduna, Nigeria