Samson Akintaro

Senior Analyst

4 min read

The Central Bank of Nigeria (CBN) has set a minimum paid-up capital of N15 billion for issuers of foreign currency-backed stablecoins seeking to operate in Nigeria, while introducing stricter approval and identity verification requirements for platform-facilitated peer-to-peer (P2P) cryptocurrency transactions.

The requirements are contained in the apex bank’s Regulations for the Operations of Non-Security Virtual Assets in Nigeria, issued on November 5, 2026.

The framework establishes licensing, capital, governance and operational requirements for stablecoin issuers and other virtual asset service providers operating within its regulatory scope.

Under the new rules, foreign currency-referenced stablecoins, classified as Class 2 stablecoins, can only be issued through a Nigerian-incorporated entity holding a valid CBN licence. The issuer must maintain a staffed physical office in Nigeria, effective local management and the capacity to meet the regulator’s supervisory requirements.

The regulations also require Class 2 issuers to maintain minimum paid-up capital of ₦15 billion, or any higher amount the CBN may prescribe. The capital must be maintained upon entry and throughout the issuer’s operations.

The requirements place a significant regulatory and financial obligation on foreign stablecoin businesses seeking access to the Nigerian market, including those operating through international parent companies or affiliated entities.

Section 15.2 of the regulations sets the minimum paid-up capital for a Class 2 Licensed Issuer at N15 billion. This is higher than the N10 billion required of issuers of naira-referenced stablecoins, classified as Class 1.

  • The CBN also sets a minimum capital requirement of N1 billion for providers of other non-security virtual asset services, including relevant exchanges, wallet providers and payment-related virtual asset businesses.
  • For providers that already hold a Securities and Exchange Commission (SEC) licence, the CBN’s capital requirement is additional to the capital prescribed by the SEC for the relevant service.
  • The regulations state that the same capital cannot be counted towards meeting both regulatory requirements. This means affected operators may need to commit separate capital to satisfy the CBN and SEC frameworks, depending on the services they provide.

The apex bank further requires stablecoin issuers to provide evidence of their capital funding and deposits before receiving final approval.

Eligible capital must generally be held in cash in a designated account at the CBN or in Federal Government securities held with an approved custodian and subject to a lien in favour of the Bank.

The CBN’s local incorporation requirement also applies to foreign-backed stablecoins. While a Nigerian Class 2 issuer may be controlled by or affiliated with a foreign issuer or international group, the Nigerian entity remains fully responsible for compliance with the regulations.

The local entity must also ensure that the CBN has unrestricted supervisory access to its books, records, systems, reserve arrangements, and relevant group information.

In addition, the issuer must maintain effective Nigerian management and supervisory access, including a resident Chief Compliance Officer, local customer and redemption operations, and access to records in Nigeria.

The regulations also introduce tighter controls on platform-facilitated P2P cryptocurrency transactions, requiring providers to obtain specific CBN approval before operating the service.

Under Section 10.2, a licensed or authorised virtual asset provider seeking to operate or facilitate a P2P service must obtain the applicable approval from the Bank.

  • The approval may be subject to conditions covering supported tokens, eligible customers, transaction limits, payment channels, foreign exchange treatment and geographic scope.
  • The rules require providers to verify every customer’s identity using their platforms and maintain sufficient information to identify the counterparties involved in each transaction.
  • More significantly, Section 10.3.3 provides that a provider must not release or credit a regulated token in a P2P transaction unless it has verified that the name and Bank Verification Number (BVN) of the account from which the naira payment was made, or to which it was made, match the verified customer on whose behalf the provider acts.

The requirement aims to strengthen the link between crypto traders’ identities and the bank accounts used to settle the naira leg of their transactions.

The CBN also prohibits providers from knowingly allowing third-party, nominee, mule, fictitious or improperly attributed accounts and wallets to be used to conceal the identity of customers, counterparties or beneficiaries.

Platforms must additionally maintain systems that can link and reconcile the virtual asset leg of each transaction with the corresponding naira payment or settlement leg.

They are also required to operate transaction monitoring, fraud prevention, sanctions screening and anti-money laundering controls, as well as procedures for identifying failed, incomplete, disputed, fraudulent or suspicious transactions.

The new CBN regulation builds on other recent policy moves targeted at regulating the crypto market.

Earlier this year, President Bola Tinubu signed the Presidential Executive Order on Virtual Assets Coordination, 2026, establishing a new framework to coordinate the regulation of cryptocurrencies, stablecoins, tokenised assets, and other digital assets across government agencies.

Weeks after that, the Nigeria Revenue Service (NRS) also released new Guidelines on the Taxation of Virtual Assets targeting companies, individual taxpayers, Virtual Asset Service Providers (VASPs), peer-to-peer (P2P) marketplace operators, and other participants in Nigeria’s digital asset ecosystem.

Before that, the Securities and Exchange Commission (SEC) had intensified efforts at granting approval in principle to crypto exchanges under its Accelerated Regulatory Incubation Programme (ARIP).

In the latest development under the SEC regulatory sandbox, the Commission has cleared three additional Virtual Asset Service Providers (VASPs) for admission into its ARIP, bringing the number of crypto firms under the regulatory sandbox to 14.

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