While there is no named “2026 CBN Gift Card Exchange Regulation” published as a standalone document, industry observers and practitioners can reasonably anticipate several key features in any guidance affecting this ecosystem:

1. Compliance with AML and KYC Standards

Given the CBN’s emphasis on risk management, any gift card exchange platform operating in Nigeria is likely expected to implement robust KYC procedures and report suspicious activity to Nigerian authorities. This aligns with broader CBN expectations for payment and card‑based services and helps reduce fraud, money laundering, and financing of illicit activities.

2. Consumer Protection and Transparency

The CBN has long prioritized clear communication of transaction terms, fees, and exchange rates. For gift card exchanges, platforms may be required to display transparent rates, breakdowns of fees, and the basis for determining how much naira a customer receives for a card. This mirrors recent CBN transparency expectations for foreign card usage.

3. Data Security and Digital Standards

With digital transactions under scrutiny, strict guidelines around data protection and cybersecurity are expected — tying into Nigerian data protection laws and CBN’s broader requirements for payment systems. Platforms may be encouraged or required to implement encryption, secure storage of user data, and policies aligned with consumer safeguards.

4. Risk Monitoring and Reporting

CBN has reinforced requirements for continuous fraud monitoring and risk assessment in recent directives. Platforms dealing with gift card exchanges are likely to fall under similar expectations — with obligations to monitor unusual activities, report suspicious transactions, and maintain audit trails.