Four currency blocs, four architectures
The phrase “African payments market” covers national and regional systems that do not form a uniform whole. Between Dakar and Johannesburg, the main dividing line is less consumer habit than the currency in which payments are collected, and with it the entire settlement chain. Analyzing a project therefore starts with the infrastructure, which establishes the currency in which a payment becomes final, and the central bank on whose books it settles. Those two facts determine the available rail, the competent regulator, the license required, and whether the funds can be repatriated.
Four configurations cover most of the region. WAEMU (the West African Economic and Monetary Union) is a monetary union of eight states that share a currency, a central bank, an RTGS system, and a card scheme. A payment from Abidjan to Lomé is technically domestic. Nigeria is the opposite case: a sovereign currency that is not convertible outside the country, but the highest-volume instant rail on the continent. Ghana has built a complete suite of public infrastructure, in a country where retail payments nonetheless belong to the telecom operators. Southern Africa revolves around the South African rand, which is used for regional settlement well beyond South Africa's borders.
| Bloc | Currency and authority | Instant rail | Domestic card scheme | Final settlement |
|---|---|---|---|---|
| WAEMU (8 states) | CFA franc (XOF), BCEAO | No unified regional instant rail; instant payments run on mobile money and GIM-Switch | GIM-UEMOA | STAR-UEMOA (regional RTGS), with bulk clearing through SICA-UEMOA |
| Nigeria | Naira (NGN), Central Bank of Nigeria | NIBSS Instant Payment (NIP), since 2011 | Verve (private, Interswitch) and AfriGO (sovereign, NIBSS) | CBN RTGS, launched in December 2006 as CIFTS |
| Ghana | Cedi (GHS), Bank of Ghana | GhIPSS Instant Pay (GIP), since 2016 | gh-link, e-zwich, GhDual Card | Net settlement computed by GhIPSS and settled at the Bank of Ghana |
| Southern Africa | Rand (ZAR) and pegged currencies, South African Reserve Bank | PayShap (2023) domestically, TCIB (2021) regionally | None; Visa and Mastercard dominate | SAMOS (South Africa's RTGS); SADC-RTGS for regional payments |
WAEMU: one currency, eight states, three infrastructures
The West African Monetary Union (UMOA) brings together Benin, Burkina Faso, Côte d'Ivoire, Guinea-Bissau, Mali, Niger, Senegal, and Togo around the CFA franc, issued by the BCEAO, the Central Bank of West African States (BCEAO, UMOA overview). The exchange-rate regime is a fixed peg to the euro. The central bank quotes the euro at the same buying and selling rate, 655.957 FCFA (BCEAO, exchange rates as of July 31, 2026), whereas a market rate would show a spread between the two sides. For an operator, euro-XOF exchange risk is therefore zero, which sets WAEMU apart from Nigeria, Ghana, and Angola.
The term “CFA franc” refers to two separate currencies: the West African CFA franc (XOF, BCEAO) and the Central African CFA franc (XAF, BEAC). Both have the same quoted parity with the euro. They are not interchangeable, and their infrastructures are separate: SICA-UEMOA and STAR-UEMOA in the West, SYSTAC and SYGMA in the CEMAC zone since 2007. A contract denominated in “FCFA” without an ISO code therefore leaves open both the settlement currency and the central bank where the transaction settles.
GIM-UEMOA is a multi-country domestic card scheme, set up as an international economic interest grouping by the BCEAO and the Union's banks and in service since 2003. That regional reach makes it an exception in the region: a GIM card is accepted in all eight states. The grouping now has more than 130 members, including banks, financial and postal institutions, microfinance institutions, and e-money issuers (GIM-UEMOA, official website, 2025–2026). For an issuer in the Union, GIM is the structural alternative to Visa and Mastercard, and the choice between them comes down to interchange cost and ATM acceptance.
Most retail volume in the Union runs on mobile money, not cards. Wave Mobile Money is licensed as an e-money institution in Senegal, Côte d'Ivoire, Mali, and Burkina Faso. It set pricing at 1% on transfers with free deposits and withdrawals, forcing Orange Money to cut its prices. That price cut remains the defining market shift in French-speaking West Africa. Wave claims more than 20 million monthly active users and 150,000 agents as of mid-2025, including 8 million monthly users in Senegal, all unaudited company figures. Orange Money remains dominant across the franc zone. It operates country by country through e-money subsidiaries licensed by the BCEAO, such as Orange Finances Mobiles Mali under license EME.ML.008/2015. A separate banking entity rounds out the group's setup: Orange Bank Africa, launched in Abidjan in July 2020 under a BCEAO license.
- An intra-WAEMU “cross-border” payment is nothing of the kind: same currency, same central bank, same RTGS. Do not charge FX or correspondent fees on this flow.
- Outside the franc zone, West Africa fragments: Mauritania (the GIMTEL switch, with 17 banks and Mauripost), the Gambia (Gamswitch, whose BANTABA 2.0 platform launched on December 15, 2025), and Cape Verde (Vinti4, operated by SISP). Each country has its own switch, currency, and regulator.
- Wizall Money fills a niche worth knowing: a non-telco wallet licensed by the BCEAO as an e-money issuer, focused on bulk payments from companies and governments (salaries, allowances, social benefits) in Senegal, Côte d'Ivoire, Burkina Faso, and Mali rather than on P2P.
- YUP, the wallet Société Générale launched in 2017 across its West African subsidiaries, shut down in 2023: the region has already pushed major banks out of this market. Mobile money there is not an extension of banking.
Nigeria: NIBSS, NIP, and the dominance of the “transfer”
Nigerian retail payments rely mainly on account-to-account credit transfers, known locally as the transfer. This makes the country an exception to the telco-led model common elsewhere on the continent, where a mobile operator's wallet fills that role. Transfers run on NIP (NIBSS Instant Payment), an instant rail live since 2011. It is operated by NIBSS plc (Nigeria Inter-Bank Settlement System), a company owned by the Central Bank of Nigeria and the Nigerian banks. A street vendor can receive a NIP transfer with no equipment, since the payer pushes the payment to an account number. Card acceptance, by contrast, requires a terminal and an acquiring agreement.
The Nigerian system has three separate components that documents often confuse. NIP is the 24/7 instant rail, addressed by NUBAN account number plus the BVN (Bank Verification Number), the unique biometric identifier of every Nigerian bank customer. NEFT (NIBSS Electronic Funds Transfer, 2004) is the bulk ACH with deferred net settlement, which originally took up to 24 hours. NIP was designed to eliminate that delay. NEFT lives on for batch payments (payroll, suppliers). The CBN's RTGS handles final settlement. Launched in December 2006 as CIFTS (CBN Interbank Funds Transfer System), it was redeployed on December 18, 2013, and upgraded in April 2023.
bank_code : 058 NIBSS institution code of the beneficiary bank
account_number : 0123456789 NUBAN, 10 digits
=> name_enquiry : MANDATORY prior call on the NIBSS side
response : account_name = "ADEYEMI OLUWASEUN B"
bvn / session_id returned by the switch
=> the payment order carries the session_id from the name enquiry
What the "name enquiry" means in operations:
. the beneficiary name is RETURNED before the order, not after
. a name mismatch is handled BEFORE irrevocability, not as a dispute
. an executed NIP push is irrevocable: no chargeback,
only a request to the beneficiary to return the fundsA layer of private providers has grown on top of the interbank rail. Interswitch (2002) is the incumbent switch, now a pan-African group with more than 11,000 ATMs on its network. Paystack (2015), acquired by Stripe in 2020, remains the benchmark for developers in the region. Its application programming interface (API) set the standard that regional players have since adopted. Flutterwave claims more than 500,000 payments a day and a presence in 18 countries. These figures are self-reported and unaudited, and are useful only as a commercial order of magnitude. Moniepoint, licensed as a microfinance bank by the CBN in February 2022, owns the neighborhood merchant's terminal and the agent network. On the wallet side, OPay has its deposits covered by the NDIC, Nigeria's deposit insurer, a protection that e-money issuers do not get.
Verve and AfriGO: two domestic schemes, two opposite logics
Nigeria has two domestic card schemes, which differ in both ownership and purpose. Verve, launched in 2009 by Verve International, an Interswitch subsidiary, is a private scheme that grew on the back of its interchange cost and ATM acceptance. Its card base reached more than 70 million cards issued in Nigeria in October 2025, up from 50 million in July 2024, or +40% in a year (Interswitch, October 2025 press release). It is the first and largest scheme on the continent, and it is now expanding abroad, with a launch in Kenya.
AfriGO is a national card scheme launched on January 26, 2023 by the Central Bank of Nigeria and NIBSS, billed as the first card scheme backed by an African state. It is operated by AfriGoPay Financial Services Limited, a NIBSS subsidiary licensed by the central bank. Its rationale is monetary, not commercial: its transactions never leave the country, which saves the foreign currency otherwise spent on international scheme fees. At the end of 2025, it claimed more than 1 million cards issued and more than ₦70 billion in transactions, with acceptance at more than 16,000 ATMs and about 70% of POS terminals in the country (NIBSS, 2025).
| Verve | AfriGO | Visa / Mastercard | |
|---|---|---|---|
| Type | Private scheme (Interswitch) | Sovereign scheme (NIBSS / CBN) | International schemes |
| Launch | 2009 | January 26, 2023 | Long established |
| Cards issued | 70M+ cards (Interswitch, Oct. 2025) | 1M+ cards (NIBSS, 2025) | Not published by country |
| Transaction scope | Domestic, with the scheme expanding abroad (Kenya) | Strictly domestic, no foreign currency outflow | Domestic and international |
| Selling point | Interchange cost, ATM acceptance | Sovereignty and foreign currency savings | Global acceptance, cross-border e-commerce |
| What an acquirer should do | Accept it: it has the largest card base | Accept it when targeting mass retail and the public sector | Essential for any payment leaving the country |
Two digital money instruments round out the Nigerian landscape. The eNaira, launched in 2021, is the first retail central bank digital currency (CBDC) issued in Africa, with about ₦29 billion in cumulative transactions three years after launch (BusinessDay, 2024). Adoption failed: almost none of the wallets opened were ever used. Yet it has never been shut down. The Nigeria Payments System Vision 2028 acknowledges the slow adoption and announces a refocus on government-to-person and cross-border payments. The cNGN, a naira stablecoin backed 1:1 and issued since 2024 by the African Stablecoin Consortium under the supervision of the CBN and Nigeria's SEC, takes the opposite approach. Its adoption depends on voluntary commercial use rather than a public mandate.
Ghana: the most complete infrastructure suite, in a mobile money country
Ghana has the most complete suite of public payment infrastructure in the region: a card switch, an instant rail, an ACH, check truncation, a QR standard, an alias directory, a request to pay service, and mobile money interoperability. It is operated by GhIPSS (Ghana Interbank Payment and Settlement Systems Limited), a wholly owned subsidiary of the Bank of Ghana incorporated in May 2007. Yet Ghanaian retail payments remain in the hands of the telecom operators, whose volumes exceed those of the entire public suite.
| Service | Since | What it does | What an operator should take away |
|---|---|---|---|
| gh-link | 2012 | National switch and domestic card brand: ATM, POS, online, net settlement computed at the Bank of Ghana | The switching layer every other service runs on |
| e-zwich | 2008 | Chip card with fingerprint authentication, usable offline, no bank account required | The rail for public payments: public-sector salaries, national service allowances, social programs |
| GhDual Card | – | Dual-interface card combining e-zwich and gh-link on a single card | A pragmatic answer to fragmented domestic instruments |
| GhIPSS Instant Pay (GIP) | 2016 | Real-time interbank account-to-account credit, capped at GHS 50,000 per transaction | Matters less than MMI: the country was built on wallets, not bank accounts |
| MMI | 2018 | Interoperability across mobile money ↔ mobile money ↔ bank accounts ↔ e-zwich cards, mandated by the regulator | First system of its kind in Africa; the model was copied by Tanzania and Rwanda |
| GhQR | 2020 | National QR standard for merchant acceptance | Technically deployed, commercially disappointing. A mandate does not create usage |
| ACH Direct Credit / Direct Debit | – | Outbound bulk payments and recurring direct debits under mandate | The bulk-payment layer people forget when they focus only on GIP and mobile money |
| Proxy Pay / Request to Pay | – | Alias-based addressing, and payment requests initiated by the payee | The directory and collection layer that makes interoperability usable for customers |
| CCC | – | Check clearing by truncation (the image and code line travel, the paper stays put) | A minor rail by volume, still central to business payments |
These four figures show how public infrastructure compares with private wallets. Ghana's entire public suite processed GHS 1,730 billion in 2025, while the wallet of Mobile Money Limited alone processed GHS 4,100 billion. This MTN Ghana subsidiary is licensed by the Bank of Ghana as an EMI separate from the telco, a model of separating the telecom operator from the e-money issuer that other countries have since copied. The interbank infrastructure provides the interoperability layer that sits beneath the collection channel; it is not the channel itself. A Ghanaian merchant therefore collects payments in mobile money, and GhIPSS links the competing wallets, bank accounts, and e-zwich cards.
South Africa: RTC, PayShap, and a distinctive direct debit setup
South Africa's payment system combines a central bank RTGS, interbank retail clearing, and a self-regulatory framework. It is the most banked and most standardized market on the continent, and the only one in the region genuinely built around cards. Final settlement takes place in SAMOS (South African Multiple Option Settlement), the RTGS operated directly by the South African Reserve Bank, which itself manages participant admission. Retail clearing is handled by PayInc, an operator whose name and ownership changed in 2025.
Two interbank credit rails coexist. RTC (Real-Time Clearing), live since 2006, is the long-standing near-instant credit. It has remained expensive and, in practice, confined to large amounts. PayShap, launched in 2023 on ISO 20022 with alias-based addressing (the ShapID), targets the small payments that RTC's cost left out. Uptake was slow for three years, held back by participating banks' pricing, and volumes are taking off in 2026.
South African debit collection runs on three separate direct debit streams, distinguished by the mandate regime that authorizes them. This is the most finely tuned setup in the region, and it governs every recurring collection. The three streams are not processed at the same time, and their order during the day matters. DebiCheck runs in the first morning window. This authenticated-mandate debit requires the payer to confirm the mandate electronically with their bank when the contract is signed. The Registered Mandate (RM), launched on May 12, 2025 to replace RMS, runs in the evening. The legacy EFT debit, whose mandates are not registered with the banks, runs late in the evening. The framework is administered by the Payments Association of South Africa, a self-regulatory body founded in 1996 and recognized by the SARB as a payment system management body in 1999.
Southern Africa: the rand as the regional settlement currency
Beyond South Africa, the region settles in rand. The SADC-RTGS, formerly SIRESS and live since 2013, is operated by the South African Reserve Bank under a mandate from the SADC Committee of Central Bank Governors. It has 16 participating states: South Africa, Angola, Botswana, Comoros, DR Congo, Eswatini, Lesotho, Madagascar, Malawi, Mauritius, Mozambique, Namibia, Seychelles, Tanzania, Zambia, and Zimbabwe (SARB, SADC-RTGS page, accessed July 2026). Settlement is in ZAR only. The system is the backbone of high-value payments in the region. An interbank payment from Lusaka to Maputo routed through it therefore settles in rand, not in either national currency. On top of this, the Common Monetary Area pegs the currencies of Lesotho, Namibia, and Eswatini to the rand.
The instant retail counterpart to the SADC-RTGS is TCIB (Transactions Cleared on an Immediate Basis), live since 2021. PayInc operates it for a scheme run by the SADC Banking Association and the SADC Payment System Oversight Committee. TCIB works as an immediate credit push with deferred net settlement. Its access rules set it apart from the other regional rails: it remains the only cross-border instant scheme in SADC open to non-banks, meaning e-money institutions and mobile money operators. It explicitly aims to formalize the South Africa → Zimbabwe, Malawi, and Mozambique migrant remittance corridors, which are still largely informal. The South Africa–Zambia corridor is advertised at 60 seconds end to end (BankservAfrica, 2025–2026). Volumes are not published, so that claim cannot be checked against measured usage.
| Country | RTGS | Switch / retail rail | Published figure |
|---|---|---|---|
| Namibia | NISS (Bank of Namibia, 2002), migrated to ISO 20022 | NAMSWITCH (cards) and NamPay (EFT, 2019), operated by Namclear; Instant Payment Programme live since June 2026 | More than 97,000 transactions and more than N$1,200B settled between April 2024 and April 2025 (Bank of Namibia, 2025) |
| Botswana | BISS (Bank of Botswana) | BACH (ACH); long-standing mobile money service MyZaka (Mascom) | Governed by the National Clearance and Settlement Systems Act of 2003 |
| Zimbabwe | ZETSS (Reserve Bank of Zimbabwe) | Zimswitch (1994), designated the National Payment Switch, and ZIPIT (2011), instant account↔account and account↔wallet | Zimswitch processes more than 75% of the country's card transactions (Zimswitch, public data) |
| Zambia | ZIPSS (Bank of Zambia) | TCIB corridor with South Africa | – |
| Malawi | – | Natswitch (ATM, POS, mobile money, instant) | 72.7M transactions in 2025 vs. 33.5M in 2024 (+117.3%), worth MWK 13,900B; mobile money accounts for 64.1% of volume (Reserve Bank of Malawi, 2025 National Payments System Report, March 2026) |
| Mozambique | MTR (Banco de Moçambique, Montran platform) | SIMO / SIMOrede (2011); M-Pesa Moçambique (Vodacom) | – |
| Angola | SPTR (Banco Nacional de Angola, with EMIS) | Multicaixa / EMIS, Multicaixa Express (2018), KWiK (instant, 2022) | Multicaixa Express: more than 2.1B transactions in 2025, ~62% of all transactions on the network; KWiK: 35M transfers in 2025 worth Kz 590B, more than 100% growth (EMIS, 2025 annual review) |
One last data point completes the regional picture. Vodacom M-Pesa was shut down in South Africa, with about 76,000 active users at closure, even though the brand dominates elsewhere on the continent. The difference comes down to South Africa's banking penetration and card coverage: the wallet filled no gap in access to banking services. Mobile money adoption follows a lack of accessible banking, not merely the availability of a wallet.
PAPSS: a bid to take African cross-border payments off the dollar
A payment between two African currencies runs through the dollar and a correspondent bank outside Africa, with double conversion, correspondent fees, and delays. That detour drives the structural cost of African cross-border payments. PAPSS (Pan-African Payment and Settlement System), live since 2022, was designed to eliminate it. Settlement takes place in local African currencies, with daily netting and the net balance settled in hard currency through Afreximbank. PAPSS is operated by PAPSS SA, a subsidiary of Afreximbank, which also acts as its settlement agent. The system serves as the payment infrastructure of the AfCFTA (African Continental Free Trade Area). The African Union and the AfCFTA secretariat sit on its Governing Council as non-voting members, providing institutional support rather than operating it.
| Rail | Since | Scope | Settlement currency | Open to nonbanks? |
|---|---|---|---|---|
| PAPSS | 2022 | Pan-African, 28 states announced | Local currencies, with net balances settled in hard currency via Afreximbank | Through connected banks and switches |
| SADC-RTGS (formerly SIRESS) | 2013 | 16 SADC states | ZAR only | No, RTGS participants only |
| TCIB | 2021 | SADC, remittance corridors | Credit push, deferred net settlement | Yes: EMIs and mobile money |
| REPSS | 2012 | COMESA, eight countries actually connected (Mauritius, DR Congo, Malawi, Eswatini, Uganda, Zambia, Rwanda, Kenya) | USD and EUR, via national RTGS systems | No, access through the national RTGS |
| GIMACPAY | 2020 | CEMAC (for comparison with WAEMU) | XAF, via SYSTAC / SYGMA | Yes, 124 participants including payment institutions and MFIs |
| Onafriq (formerly MFS Africa) | – | Private multi-country aggregator | Depends on the corridor | Yes, wallet aggregation model |
Two sets of figures show the scale of these regional rails. In CEMAC, GIMACPAY processed more than FCFA 600 billion in 2025, with 124 participants: 58 banks, 12 payment institutions, 14 microfinance institutions, 37 aggregators, two public treasuries, and the central bank. It connects 37 million mobile wallets and 2 million bank accounts, and nearly three in four transactions go through a wallet (Investir au Cameroun / La Finance Digitale, 2025–2026; BEAC). In COMESA, REPSS still has only eight countries actually connected after more than 10 years in service (Central Bank of Kenya, 2026). Both cases show the same gap. Across the continent, institutional membership moves much faster than actual bank usage: institutions decide among themselves to connect, while volume depends on how end customers behave.
Licensing, where funds are held, and what breaks in collection
Each jurisdiction's licensing regime sets the license a payment operator needs, which institution may hold the funds, and the conditions for moving them out of the country. The license required, the jurisdiction that grants it, and where the money is allowed to sit all vary from bloc to bloc. None of the four blocs recognizes another's licenses. There is no passporting, either continent-wide or within SADC. Only WAEMU offers genuine pooling: a license granted in one member state is valid throughout the Union.
| Jurisdiction | Legal basis | Status / categories | Minimum capital | Sticking point |
|---|---|---|---|---|
| WAEMU | BCEAO Instruction No. 001-01-2024 on payment services, in force since January 23, 2024 | Payment institution status created for legal entities other than credit institutions; in scope: banks, credit institutions, payment institutions, MFIs, and e-money issuers; services covered (cash-in/cash-out, credit transfer, direct debit, card, money transfer, instrument issuance, acquiring, initiation, account aggregation) | FCFA 10 to 100 million in fully paid-up capital, depending on the services provided | Review period of six months from a complete application; the compliance deadline was extended to May 1, 2025, after which any unlicensed entity must stop offering payment services in the UMOA |
| Nigeria | CBN circular of December 9, 2020, New License Categorisations for the Nigerian Payments System | Switching & Processing, Mobile Money Operator (MMO), Payment Solution Services (PSS), PSSP, PTSP, Super-Agent | Switching & Processing: ₦2B · MMO: ₦2B · PSS: ₦250M · PSSP: ₦100M · PTSP: ₦100M · Super-Agent: ₦50M | Categories cannot be combined freely: Switching & Processing covers PSSP, PTSP, and Super-Agent activities; MMO covers Super-Agent. Pick the wrong category and you start over |
| Ghana | Payment Systems and Services Act, 2019 (Act 987) | DEMI (Dedicated Electronic Money Issuer), PSP Scheme, PSP Enhanced, PSP Medium, PSP Standard, PFTSP | Bank of Ghana integrity capital schedule: DEMI GHS 20M · PSP Scheme GHS 8M · Enhanced GHS 2M · Medium GHS 800,000 · Standard: no regulatory capital | Capital is held in a blocked account at the Bank of Ghana for as long as the business operates. And the PSP Standard category is reserved for 100% Ghanaian-owned entities, so foreign investors are shut out |
| South Africa | National Payment System Act 78 of 1998; SARB draft directive, Directive in respect of specific payment activities within the national payment system, November 2025 (under consultation, not yet in force) | Regime organized by activity, not by status: A1 e-money issuance, A2 instrument issuance, B acquiring, C1 clearing and settlement, C2 initiation, D third-party payment provider, E schemes, F money remittance, G payment accounts | Initial capital in the draft: e-money R8M (tier 1) / R5M (tier 2) · acquiring R3M · clearing R1M · settlement R3M · initiation R2M · TPPP R2M / R500,000 · money remittance R2M / R500,000 · schemes and instrument issuance: no requirement | Any activity involving deposit-taking counts as the “business of a bank”: it requires either a banking license or a sponsorship arrangement with a bank. Holding customer funds without a sponsor is prohibited |
- Chargebacks do not exist on instant push payments. NIP, GIP, PayShap, ZIPIT, and TCIB are credits pushed by the payer and irrevocable once executed. There is no scheme dispute process, only a request to the payee to return the funds. A dispute setup modeled on cards will not work. Checks happen before the payment order, through name enquiry (Nigeria) or the alias directory (Proxy Pay in Ghana, ShapID in South Africa).
- Identity is national and cannot be substituted. BVN in Nigeria, the Ghana Card in Ghana, national identifiers in South Africa, state-by-state e-money licenses in WAEMU: no KYC database crosses a border. Plan a country-by-country onboarding flow, not a regional flow with variants.
- An e-money issuer's float is a major prudential issue, not a treasury line item. Mobile Money Limited's float in Ghana reached GHS 38.4 billion in 2025 (MTN Ghana / MML results, March 2026). Central banks in the region require it to be ring-fenced, and the interest paid on it is a regulatory issue in its own right.
- A company's name and status change fast, and documents reflect it retroactively. BankservAfrica became PayInc in August 2025, TymeBank became GoTyme Bank, and MFS Africa became Onafriq: the same entity appears under two names depending on the year of the document, and only the date of the source tells you which name refers to the company as it operates today.
- User figures from the region's fintechs are self-reported. Flutterwave, Moniepoint, OPay, and Wave publish unaudited user counts, sometimes inconsistent from one page to another on the same website. Using them as a commercial order of magnitude is fine; presenting them as measurements is not.