Nigeria Software Guide

CBN Dormancy Rules: A Pre-Dormancy Framework for Banks, Fintechs and Mortgage Lenders

The CBN expects institutions to warn customers, track silent accounts, try to reach holders or beneficiaries and report. This guide summarises the rules and sets out a step-by-step way to act before an account is declared dormant.

By Olalekan. Last checked 22 October 2026. General information, not legal advice.

Entrustt and Remayn are affiliated with this site.

The rules in short

  • The guidelines. The CBN issued its guidelines on dormant accounts, unclaimed balances and other financial assets in July 2024.
  • Duties. Warn customers before an account turns dormant, track and record inactive accounts, try to reach account holders or their beneficiaries, verify identity before reactivation and report to the CBN.
  • Publication. A February 2025 circular directs institutions to publish dormant account details online and annually in the press.
  • Transfer. Balances dormant for ten years move to the CBN-managed Unclaimed Balances Trust Fund pool.
  • Reactivation. The March 2026 circular removed the affidavit for accounts not yet transferred.

These are summaries of press reports and commentary. Read the CBN texts and take advice before changing a process.

The gap before dormancy

By the time an account is formally dormant, the institution has usually lost contact. The useful work happens earlier: noticing that a customer has gone quiet, reaching them, and finding out who else to ask. Most institutions have no system for that stretch, so it is done by hand or not at all.

A step-by-step pre-dormancy framework

1

Pick the signals

Logins, transactions, card use, responses to messages and repayments. Use what you already record.

2

Set quiet periods by product

A current account, a savings account, a wallet and a mortgage do not behave alike. Decide how long each can be silent before action.

3

Warn the customer

Use more than one channel, in your name, and log each attempt. Never ask for a PIN, password or money.

4

Reach the named contact

If the customer stays silent and consented to a next of kin, contact that person through a reviewed process.

5

Review before disclosure

A staff member approves anything that goes to a third party, and the decision is recorded.

6

Declare dormancy under the rules

Apply the CBN’s definition and exemptions, such as accounts under litigation or pledged as collateral.

7

Prepare publication and transfer

Build the publication list and the quarterly reporting pack from the same records, so nothing is reconstructed later.

For mortgage lenders

A mortgage can run for many years. Over that time a borrower’s phone number, employer and family circumstances change, and a co-borrower or guarantor may become the only reachable person. A consented contact record, refreshed on a schedule, and a quiet-period check on repayment and contact signals help the lender notice trouble early. RSA funds can be used for a mortgage equity contribution only after PenCom data recapture, so lenders and pension administrators share the same stale-data problem. See PenCom next of kin for PFAs.

For fintechs

A fintech sees every login and transaction, which makes inactivity easy to measure and hard to act on. A webhook-based service can take those signals, start the clock and tell your systems what is due, so engineers do not have to build a next-of-kin engine from scratch. The Entrustt developer page shows the flow: get sandbox keys, send a signal, receive a signed webhook.

Where Entrustt fits

The Entrustt solution for banks and fintechs is about reaching customers who went quiet. The product has four modules: a next-of-kin register, inactivity checks, human-reviewed disclosure and audit reports. It handles information, never money, and it does not make an institution compliant. Entrustt’s own guide to the CBN guidelines and its guide to deceased customers go further on process. For buyers, see pricing, security, subprocessors and the contact page.

Related reading: unclaimed dividends and NGX registrars.

Common questions

When is an account dormant under the CBN rules?

TheCable’s report on the CBN circular describes a dormant account as one inactive for at least one year, and summaries of the 2024 guidelines put it at about one year for current accounts and two years for savings. Exact periods can depend on account type, so check the CBN text.

What happens after ten years?

Reports on the guidelines say balances dormant for ten years move to the CBN’s Unclaimed Balances Trust Fund pool. The owner or a legal representative can still claim the money through the institution.

What must institutions publish?

A February 2025 CBN circular, as reported by TheCable, directs banks and other financial institutions to publish details of dormant accounts and unclaimed balances on their websites: the names of people authorised to operate the account, the account type, the bank and the branch. The same details go into at least two national dailies each year, or at the premises of State and Unit microfinance banks.

Do these rules cover microfinance and mortgage institutions?

The circular covers banks and other financial institutions, and it makes provision for microfinance banks. Whether a particular licence category is covered should be confirmed with the CBN or your counsel.

What changed in March 2026?

Reports on the 12 March 2026 CBN circular say it dropped the affidavit requirement for reactivating accounts not yet transferred to the UBTF pool. An affidavit is still needed to reclaim funds already transferred.

Does software make us compliant?

No. Compliance is the institution’s duty. Software helps run the quiet period, contact attempts, review and records so the work is done on time and can be shown.

General information, not legal advice. Rules change, so check the current CBN text.

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