An electrically erasable programmable read-only memory ("CMOS NON-VOLATILE MEMORY") cell is fabricated using standard CMOS fabrication processes. First and second polysilicon gates are patterned over an active area of the cell between source and drain regions. Thermal oxide is grown on the polysilicon gates to provide an isolating layer. Silicon nitride is deposited between the first and second polysilicon gates to form a lateral programming layer.