The Dual Connectivity Circular: Infrastructure Redundancy Is Now Mandatory
David Salami
Deep Nigerian Regulatory & Enterprise Expertise
The Central Bank of Nigeria December 11, 2025 Circular requires every financial institution and payment processor to maintain active connections to both licensed Payment Terminal Service Aggregators: Nigeria Inter-Bank Settlement System and Unified Payment Services Limited.
The compliance deadline has passed.
Institutions without automatic failover routing are exposed to supervisory scrutiny.
What Technology Leadership Should Understand
1. Dual Routing Is Mandatory
All PoS and electronic channels must maintain active connectivity to both aggregators.
Single dependency architecture is no longer acceptable.
2. Automatic Failover Is Required
Outage detection and transaction redirection must occur without manual intervention.
Redundancy must function in production.
3. Testing Is Ongoing
Aggregators are required to verify failover capability with regulated institutions.
Test evidence feeds into supervisory oversight.
4. Incident Reporting Has a 24-Hour Window
Detailed incident reports must be submitted within 24 hours of disruption.
Monitoring and documentation must be systemised.
5. The Policy Is Part of a Broader Shift
Under Payments System Vision 2028, resilience and interoperability are strategic priorities.
Redundancy is no longer optional engineering discipline. It is regulatory design.
Strategic Implication
Institutions architected around a single aggregator now face remediation complexity across:
- Routing logic
- Health monitoring
- Alerting
- Reporting workflows
The regulator has reclassified payments infrastructure as a strategic national asset.
System resilience is now supervisory terrain.
Next Step
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