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CBN asks who is licensed when Nigerians “pay small small”

At Nigeria Fintech Week in Lagos, the CBN's innovation chief named Air Peace and Wakanow instalment plans and asked how to regulate non-bank credit. It was a question, not a rule. Here is what the products do, which FCCPC rules already apply, and what merchants should check.

By Chioma Okeke · 6 Oct 2026 · 11 min

If you have booked a Lagos–London ticket on the Air Peace website lately, you have probably seen the line. Lock the fare with a down payment and pay the rest “small small.” Wakanow shows a similar prompt for holidays. At Nigeria Fintech Week 2026 in Lagos, the Central Bank of Nigeria put that checkout button on stage and asked a plain question about it.

Abiodun Olalekan Okunola, Head of the Innovation Management Division at the CBN, spoke on behalf of Governor Olayemi Cardoso. According to Nairametrics, which reported the remarks on 26 September, he described embedded finance as moving into the mainstream and used the two travel brands as his examples.

“If you go to Air Peace and you try to book a ticket, you’ll see where they tell you where you want to pay ‘small small,’ right? And then if you go to Wakanow, Wakanow will say, ‘Oh, you want to go to Maldives or Bali,’ and it asks if you want to pay ‘small small,'” he said, as reported by Nairametrics.

Then came the line that matters for anyone building or selling with instalments in Nigeria: “Now, think about it: they are offering credit. For us, they are non-bank, they are not licensed to offer credit. How do we regulate?”

He also raised the consumer side. “Because it means that when your rights are trampled there, if you come to CBN Consumer Protection and ask us, we’ll be like, ‘Who… are they even licensed?'”

CTN has not seen a CBN transcript or a CBN press release of the speech. The quotes above are as Nairametrics reported them, and other outlets, including TV360 Nigeria and Osun Report, carried the same account. No new circular, exposure draft or ban came with the remarks. The regulator was thinking out loud in public. That still tells merchants where the questions are coming from.

What “pay small small” means at the checkout

The phrase covers a lot of products. One of them is easy to read in detail, so start there.

On the Air Peace website, the option is branded Kalabash Pay Small Small. Kalabash Technology Solutions Limited is a Lagos fintech and, per its own announcements, a subsidiary of the Wakanow Group. The Air Peace page describes the plan this way: a customer can lock a fare with as little as 10 percent down, choose a down payment between 10 and 90 percent, and pick a repayment window from 24 hours up to six months. Service charges apply to every Pay Small Small booking. Reminders go out by email.

One detail on that page changes the conversation. Air Peace says the ticket is issued once the down payment is received, but it is only released to the customer after the final payment on the schedule. Kalabash’s own product page says the plan is for completing payment before the travel date.

So in the Air Peace version, the traveller does not fly first and pay later. They reserve today’s fare, pay over time, and get the ticket when they have paid in full. In everyday terms that looks more like layaway with a price lock than a loan, where you would get the goods first. The customer still pays a service charge and still carries the risk of missing an instalment.

That is one product’s design, described by the company and the airline. CTN has not reviewed the full terms and conditions, and other “pay small small” offers in the market may work differently. TNP’s review of the federal lending rules, covered below, names BNPL platforms such as Carbon and Specta that provide goods or services on deferred payment terms. Where the customer gets the item first and pays later, the product looks a lot more like credit.

The distinction matters because the CBN’s question rests on the word credit. If the merchant hands over value before the customer has paid, it is extending credit in the ordinary sense. If the customer is pre-paying in parts to hold a price, the argument is different. Regulators do not have to accept that line, but merchants should know which side of it their own product sits on.

Where the product travels

Kalabash has also been pushing the plan beyond Air Peace. In August 2025, it announced a partnership with Outpayce, the payments arm of Amadeus, to put Pay Small Small inside the Amadeus Xchange Payment Platform. The stated goal was to let airlines using that platform offer the same down-payment-and-instalments option at their own checkouts. Kalabash’s product page also lists airline partners including Air Peace, United Airlines and Arik Air. Those are company claims; CTN has not confirmed the status of each integration with the airlines.

Embedded finance often spreads this way. A payment option built for one Lagos travel brand becomes a module that other merchants plug in. The airline sees a higher conversion rate. The traveller sees a smaller number at checkout. The question of who is responsible for the financial product gets pushed down the stack, to a fintech partner most customers have never heard of.

That last part is what the CBN is pointing at. When a customer has a dispute, they think of the airline. The airline points to the payment partner. The payment partner may sit under a different regulator, or under none that the customer can name.

Rules that already exist

The speech described a gap. Part of that ground is already covered, because another regulator has written rules for digital instalment credit.

The Federal Competition and Consumer Protection Commission issued the Digital, Electronic, Online, or Non-Traditional Consumer Lending Regulations, 2025, often shortened to the DEON regulations. The FCCPC says they took effect on 21 July 2025. They replaced the commission’s 2022 interim digital lending guidelines.

The scope is wide. The regulations apply to unsecured consumer lending done by digital, electronic, online or non-traditional means, whether the value is cash, airtime, data, cashback, services or barter. They also reach beyond the lender itself. Under Regulation 3, they extend to anyone involved in the transaction as a primary or secondary lender, a vendor, a service provider, or a partner of the lender, to the extent that party receives a benefit or a share of revenue from the deal. Law firm summaries, including Koriat Law’s, read that scope as covering instalment payment and BNPL arrangements.

The FCCPC announced the framework with registration requirements, transparency rules on loan terms, limits on aggressive recovery and data misuse, and penalties that can reach ₦100 million or 1 percent of turnover, plus director disqualification of up to five years. Digital lenders were told to register within 90 days.

Banks and other institutions licensed under the Banks and Other Financial Institutions Act sit outside the FCCPC registration requirement, according to a review by TNP. They answer to the CBN.

Nairametrics reported in September 2026 that 525 digital lenders were registered with the FCCPC, with another 33 operating under waivers because they already held CBN licences. That count is from the FCCPC’s register as Nairametrics described it; CTN has not checked whether any specific “pay small small” provider is on the list.

The CBN licenses banks, microfinance banks, finance companies and payment service providers. The FCCPC registers and polices digital consumer lenders, including many that hold no CBN licence at all. A travel merchant offering instalments through a fintech partner could fall under the FCCPC rules, depending on how the product is structured and who earns from it, without ever touching a CBN licence.

The open question for the CBN is whether the central bank should have a say over non-banks that extend what looks like credit, and how customers will know which door to knock on when something goes wrong.

Why the CBN might care now

Okunola did not announce a policy, and CTN will not guess one. The usual reasons a central bank watches this kind of product are well known.

Credit that sits outside the banking system is hard to see. When merchants carry instalment balances through a few fintech partners, that exposure does not show up the way bank lending does. Okunola did not describe travel instalments as a stability risk; his remarks were about visibility and who handles problems.

The second reason is consumer redress, which Okunola named directly. CBN’s consumer protection unit handles complaints against institutions it supervises. A customer who misses a payment on a holiday plan, loses part of a deposit and feels cheated may not know that the CBN cannot act on a firm it does not license. The FCCPC may be the right door. Most customers will not know that.

The third reason is data. Okunola, per Nairametrics, linked embedded finance to businesses using customer data to offer financial products. A travel site that knows your booking history, payment timing and destination choices has the raw material for credit decisions. How that data is used and stored overlaps with the Nigeria Data Protection Act, which CTN covered on 1 October in its NDPA and GAID audit explainer.

What it means on the ground in Lagos

For a Lagos travel agency, Computer Village gadget seller, or school-fees platform weighing an instalment option, the remarks do not change the law today. They do change the questions a partner, investor or bank may start asking.

These are the checks worth doing now.

Start with the product itself. Does the customer get the goods or service before full payment, or after? If before, assume you are in credit territory and price your compliance that way.

Next, work out who holds the risk. Is your fintech partner the lender, or are you? Who carries a default? Who earns the service charge? The FCCPC rules reach partners who share in the revenue, so a revenue-share line in the contract matters.

Check registration. Ask your provider whether it is registered with the FCCPC under the DEON regulations, or holds a CBN licence that exempts it. Get the answer in writing.

Put the terms where customers can see them: down payment, service charge, repayment window, what happens on a missed instalment, and refund rules. Air Peace publishes most of this on a public FAQ page; that is a reasonable minimum.

Name the complaints channel. If a customer has a problem, tell them who to call at your company, at your partner, and which regulator handles escalations. That is the gap Okunola described, and merchants can close part of it themselves.

Finally, watch for a CBN document. If the central bank turns this question into an exposure draft, it will be published and open for comment. Until then, there is nothing to comply with from the CBN side, and nobody should sell you a “CBN BNPL licence” that does not exist.

What travellers and shoppers should check

For customers, the advice is simpler. Before choosing “pay small small,” read four things: the total cost including service charges, what you get and when, what happens if you miss a payment, and how refunds work if the trip changes. If you cannot find those on the merchant’s site, ask before paying the deposit. Keep the payment confirmations. If a dispute comes up and the merchant and partner do not resolve it, the FCCPC is the regulator that has published rules for digital consumer lending.

What happens next

Nothing is scheduled. The CBN has not said it will issue guidelines on non-bank instalment credit, and CTN has no information that it plans to. What it has done is say, in public and in front of the Lagos fintech crowd, that it sees embedded credit at non-banks as an open question. That is usually how this kind of policy work starts in Nigeria: a speech, then a discussion paper or exposure draft, then comments.

Kwesi Addo on the CTN policy desk will cover any instrument if one appears. Until then, merchants can get ahead by knowing exactly what their own instalment product does and who stands behind it. CTN flagged the same Fintech Week remarks in its 5 October Morning Brief. Remita launched its consumer app at the same event, which CTN covered on 1 October.

What this piece is not

This is not a report of a ban, a new licence category or an enforcement action. None of those exist in our sourcing. It is not a market-size story; CTN has not used BNPL market estimates here. It does not claim that Air Peace, Wakanow or Kalabash are breaking any rule. The CBN official raised a regulatory question, and the companies named are examples he chose, not targets of an action.

Sources