The 90-Day Regulatory Readiness Checklist Every Pre-Launch Founder Needs

Twenty days of Founder Readiness guides cover the why and the how. This article consolidates everything into a single execution checklist — the 90-day plan every pre-launch Nigerian fintech founder should run with their team.

The Founder's Guide Appendix A is the definitive version. This is your operational summary.

Days 1–30: Foundation

Corporate structure

• Classify your product (DAX, DAOP, DAC, payments, hybrid)
• Draft fintech-aligned MEMART and objects clause
• Incorporate with CAC (private company limited by shares)
• Obtain certified true copies and status report
• Register for TIN with FIRS
• Create beneficial ownership register (PSC)
• Appoint minimum two directors with Nigerian-resident CEO/MD

Governance

• Appoint compliance officer (documented board resolution)
• Maintain statutory registers (members, directors, charges)
• Draft founder vesting schedule (if equity allocated)
• Open corporate bank account

Product and regulatory orientation

• Map primary and secondary regulators
• Schedule SEC Innovation Office pre-screening (Tue/Thu 10am–2pm)
• Log initial regulator engagement in CRM

Days 31–60: Compliance infrastructure

AML/CFT programme

• Complete Business-Wide Risk Assessment (BWRA)
• Draft AML/CFT policy manual (board-approved)
• Appoint MLRO with written terms
• Initiate NFIU goAML registration
• Define KYC tiers (NIN/BVN integration planned)
• Configure transaction monitoring thresholds
• Conduct tabletop STR filing exercise

Product architecture

• Integrate KYC tier gates into onboarding flow
• Implement audit logging for all customer and admin actions
• Build consent flows (NDPA 2023 compliant)
• Tag product features with regulatory classification metadata

Team

• Execute employment contracts with IP assignment
• Deliver initial AML/CFT team training
• Document data protection training (NDPA 2023)

Days 61–90: Regulatory engagement and fundraising prep

Regulator engagement

• Complete SEC pre-screening meeting
• Submit follow-up correspondence documenting discussion
• Initiate CBN engagement (if payment flows exist)
• Confirm goAML registration complete
• File first PEP register submission

ARIP preparation (if applicable)

• Engage registered solicitor/adviser (mandatory for formal application)
• Begin ARIP document preparation (operational plan, entity rules)
• Confirm minimum capital requirements (SEC Circular No. 26-1)
• Verify fidelity bond requirements

Fundraising readiness

• Generate regulatory DD pack
• Achieve Readiness Score baseline (target: 50+ before investor outreach)
• Prepare investor-facing compliance summary
• Identify appropriate funding instrument for your stage

Weekly rhythm

How Klarify helps

This entire checklist maps to Klarify's ComplianceOS:

• Product Classifier — Day 1 classification
• Incorporation Wizard — Days 1–30 corporate structure
• Compliance Roadmap — all 90 days, phased and dependency-locked
• Document Generator — BWRA, AML policy, KYC tiers, ARIP documents
• Readiness Score — live progress gauge across all eight dimensions
• Regulator CRM — engagement logging from first meeting
• FundRaise Mode — Day 90 DD pack and funding readiness check

This is regulatory information and operational guidance — not legal advice. Your 90-day plan should be customised with qualified Nigerian fintech regulatory and corporate counsel.

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This article adapts themes from Appendix A of The Founder's Guide to Building in Regulated Markets (Chuta, 2026). Klarify provides regulatory information, not legal advice. For advice specific to your situation, consult a qualified practitioner.