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| The regulation does not require an affidavit. It requires a written recall, a lien on the funds, and — if the recipient refuses — a two-week mediation between the two banks' internal auditors. |
What this guide covers
- The affidavit claim: what changed and what didn’t
- The five steps to recover a wrong transfer
- The lien and the two-week mediation window
- What happens when the recipient has spent the money
- If money is wrongly credited to you
- The different rule when the bank made the error
- The deadlines that actually apply
- FAQ
The affidavit claim: what changed and what didn’t
The headline says “no more affidavit.” The reality is more precise, and the difference matters if you are the one trying to recover money.
The EFT Regulation does not list an affidavit as a required step. Section 10.4 sets out what happens when a customer makes a transfer in error: the sending bank must notify the receiving bank after establishing that the claim is tenable, the receiving bank must place a lien on the amount if it is still in the account, and the beneficiary’s consent is then sought for the reversal . No affidavit appears in that sequence.
But banks have asked for them anyway, because a sworn affidavit and an indemnity letter shift the risk of a wrongful recall onto the customer. If the sender later turns out to have been wrong — or the recall is challenged — the bank has a document to point to. That is an internal control, not a CBN requirement.
There is a separate, newer rule that does require an affidavit — but it applies to airtime and data sent to the wrong number, not bank transfers. Under the CBN/NCC framework proposed in February 2026, transactions of ₦20,000 and above require an indemnity affidavit or a notarised indemnity letter before reversal, while smaller amounts follow a lighter process . That framework is about telecom recharge errors, not interbank transfers, and conflating the two is where most of the confusion comes from.
The five steps to recover a wrong transfer
The process is set out in Section 10.4 of the EFT Regulation and has been restated in the CBN’s recent guidance. It is designed to be used without a lawyer, a court order or a sworn affidavit .
| Step | What to do | What to have ready |
|---|---|---|
| 1. Report | Contact your bank through official customer service channels as soon as you realise the error . | Your account number and the time of the transfer |
| 2. Evidence | Submit the receipt, transaction reference, amount, date and beneficiary account details . | Screenshots or a downloaded receipt |
| 3. Formal recall | Ask your bank to initiate the interbank recovery process. Do this in writing, not just by phone . | An email or in-app chat record |
| 4. Reference | Obtain a complaint reference and keep every piece of correspondence . | A notebook or folder with dates and names |
| 5. Escalate | If the bank fails to resolve it, escalate to the CBN Consumer Protection Department with your evidence and proof of the earlier complaint . | The complaint reference and the bank’s written responses |
Two practical points that the steps do not spell out. First, call and then write. A phone call gets the process started; a written complaint creates the record you need to escalate. Second, do not resend the money while a recall is in progress. A second transfer to the same wrong account complicates the recovery and may be treated as a separate transaction.
The lien and the two-week mediation window
The mechanism that makes recovery possible is the lien — a temporary hold on the disputed amount in the recipient’s account. The regulation is specific about how it works.
The sending bank must first establish that the claim is tenable — meaning there is credible evidence of a genuine error, not a buyer’s remorse or a dispute about a legitimate payment. Once that threshold is met, the receiving bank is required to place a lien on the amount where funds are available, and then seek the beneficiary’s consent to reverse .
If the beneficiary refuses consent, the process moves to a second stage. The internal auditors of both banks must mediate between the two customers within two weeks of the complaint, and their decision is final under the regulation. The lien cannot remain in place beyond those two weeks .
What happens when the recipient has spent the money
This is the scenario most people fear, and the regulation does address it — but the remedy is a sanction on the recipient, not an automatic refund to the sender.
Where the beneficiary has utilised the funds such that a lien cannot be placed, and refuses to fund the account to facilitate the refund, the receiving bank’s internal auditors must watch-list the customer’s BVN, and the sending bank may report the incident to law enforcement agencies .
The CBN has since sharpened the consequence. Governor Olayemi Cardoso warned in October 2026 that a customer who fails to refund wrongly deposited money to the rightful owner “attracts 5–10 years’ imprisonment” . The warning was issued through the bank’s spokesperson at a stakeholder engagement in Ibadan, and it is a significant escalation in tone from the earlier “watch-listing” language .
If money is wrongly credited to you
This is the mirror-image scenario, and the rules are clear about what you must do.
If you receive a credit you were not expecting and the bank notifies you that it was made in error, the receiving bank must tell you the consequences of not funding the account within 24 hours. Those consequences include watch-listing in the banking industry and credit bureaux, and reporting to law enforcement. If you fail to provide the funds within seven days, the receiving bank is required to watch-list you .
There is also a prohibition on the receiving bank: it must not use the wrong credit to settle your outstanding indebtedness to it, and must not treat the credit as your property . That prevents a bank from using an erroneous credit to offset a loan or an overdraft without your consent.
The different rule when the bank made the error
Not every wrong transfer is a customer error, and the regulation draws a sharp distinction between the two.
Where the bank erroneously sends value contrary to the customer’s instructions — wrong account number, wrong amount, duplication — the sending bank must request a reversal in writing within 14 working days. The receiving bank must then reverse the amount within one business day, without seeking the beneficiary’s consent, provided the funds are available. An automatic indemnity is inferred against the sending bank .
| Who caused the error | Is beneficiary consent needed? | Time limit on the bank |
|---|---|---|
| Customer error (you sent it to the wrong account) | Yes — the receiving bank seeks consent; if refused, auditors mediate within two weeks | Lien limited to two weeks |
| Bank error (the bank sent it contrary to your instruction) | No — the receiving bank reverses without beneficiary consent | Receiving bank must reverse within one business day of a valid written request |
| Fraud | Handled under the separate CBN fraud desk circular, not the customer-error procedure | Fraud desk procedures apply |
That distinction is why the first question your bank should ask is who made the error. A customer-error claim depends on the recipient’s cooperation, or on auditor mediation if that cooperation is refused. A bank-error claim does not.
The deadlines that actually apply
| Deadline | What it applies to |
|---|---|
| Immediately | Reporting the error to your bank. Speed is the single biggest factor in whether the funds are still available to lien . |
| 24 hours | Receiving bank must notify the beneficiary of the consequences of not funding the account, where funds are unavailable . Also the reversal expectation for a failed transaction on complaint, with a ₦10,000 fine on the bank for non-compliance . |
| 7 days | Receiving bank watch-lists the beneficiary if the account is not funded within seven days . |
| 2 weeks | Auditor mediation window for a disputed customer-error transfer; the lien cannot outlast it . This is also the general period customers are advised to allow before escalating an unresolved complaint to the CBN . |
| 14 working days | Outer limit for a bank to request a reversal of a bank-error transfer . |
One point on the “two weeks” figure: the EFT Regulation uses it for the auditor mediation window, and the CBN’s general complaints guidance also refers to two weeks as the period to allow before escalation . Those are not the same clock, and they can run concurrently. If the mediation is under way, say so when you escalate — the CBN can see from the reference that a process is already in train.
Frequently asked questions
Do I need an affidavit to recover money sent to the wrong account?
The EFT Regulation does not require one. Section 10.4 sets out a process based on a written recall, a lien and auditor mediation. Banks have often asked for an affidavit as their own internal risk control, but it is not a regulatory requirement. The CBN did remove the mandatory affidavit for dormant account reactivation in March 2026, but that is a different process.
What are the five steps to recover a wrong transfer?
Report to your bank immediately; provide the transaction evidence (receipt, reference, amount, date, beneficiary details); request a formal recall in writing; obtain a complaint reference; and escalate to the CBN Consumer Protection Department if the bank fails to resolve it.
What happens if the recipient refuses to return the money?
The receiving bank places a lien on the disputed amount if it is still available. If the recipient refuses consent, the internal auditors of both banks mediate within two weeks, and their decision is final under the regulation. The lien cannot last beyond that two-week window.
What if the recipient has already spent the money?
The receiving bank’s auditors watch-list the recipient’s BVN across the banking industry and credit bureaux, and the sending bank may report the matter to law enforcement. The CBN has warned that keeping wrongly credited money can attract 5 to 10 years’ imprisonment. But the criminal sanction is a deterrent, not an automatic refund — the sender still has to pursue recovery through the bank process or a civil claim.
Is there a deadline to report a wrong transfer?
Report immediately. The sooner the report, the higher the chance the funds are still in the recipient’s account and can be liened. For a bank-error transfer, the sending bank has 14 working days to request a reversal. For a customer-error transfer, the lien and mediation window is two weeks.
What if the bank made the error, not me?
The rule is different and stronger. Where the bank sent value contrary to your instruction, the receiving bank must reverse within one business day of a valid written request, without seeking the beneficiary’s consent, provided the funds are available. The sending bank has 14 working days to make the request.
Can I escalate to the CBN if my bank does nothing?
Yes. The CBN Consumer Protection Department accepts complaints with transaction evidence and proof of the earlier complaint to the bank. The general guidance is to allow two weeks for the bank to resolve it before escalating, unless the bank has failed to acknowledge the complaint at all.
Does the “no more affidavit” rule apply to airtime sent to the wrong number?
No — the opposite. Under the CBN/NCC framework for airtime and data errors, transactions of ₦20,000 and above require an indemnity affidavit or a notarised indemnity letter before reversal. That framework is separate from the interbank EFT Regulation and applies to telecom recharge errors, not bank transfers.
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