BY BUKOLA ARO-LAMBO and OLAMIDE OJUOKAIYE, Lagos

The Central Bank of Nigeria’s (CBN) new N15 billion minimum capital requirement for foreign currency-referenced stablecoin issuers may shut out smaller indigenous fintech companies and emerging players from the digital asset market, industry experts have warned.

The experts, however, acknowledged that the new regulations would strengthen accountability, restore public confidence and promote stability in Nigeria’s rapidly expanding digital asset ecosystem.

They urged the apex bank to adopt a flexible, risk-based licensing framework that would protect investors and strengthen regulatory oversight without stifling innovation or forcing legitimate operators out of the country.

Their concerns followed the issuance of the CBN’s Regulations for the Operations of Non-Security Virtual Assets in Nigeria, which introduce stricter licensing, capital adequacy, reserve management, consumer protection and anti-money laundering requirements for stablecoin issuers and other virtual asset service providers.

Under the new framework, which took effect on November 5, 2026, foreign currency-referenced stablecoin issuers are required to maintain a minimum paid-up capital of N15 billion, while issuers of naira-referenced stablecoins must have N10 billion.

Other providers of non-security virtual asset services are also required to maintain a minimum paid-up capital of N1 billion.

The regulations further require platforms facilitating peer-to-peer (P2P) cryptocurrency transactions to obtain specific approval from the CBN, while imposing stricter customer identification, transaction monitoring and reporting obligations.

Speaking on the development, President of the Stakeholders in Blockchain Technology Association of Nigeria (SiBAN), Barrister Mela Claude Ake, described the capital requirements as necessary safeguards to ensure that operators have the financial capacity to protect customers and support their operations.

 

Ake said the requirements were designed to ensure that only financially capable and credible operators participate in a financial sector where public confidence remains critical.

 

“For non-security virtual assets, talking about stablecoins, issuers of stablecoins and so on, the requirements on paid-up capital are about ensuring that these entities have skin in the game and the financial capacity to truly play in the country’s financial space,” Ake said.

 

Ake, who is also a venture capital analyst and trained compliance officer, said the financial sector was too sensitive to accommodate operators without adequate financial resources to absorb potential risks arising from their activities.

 

He recalled Nigeria’s history of banking failures and other financial sector challenges, noting that regulators were justified in introducing measures to prevent a recurrence of such incidents.

 

“One thing any economy cannot afford is a lack of confidence in the financial sector. One of the ways of ensuring that an operator or intending operator is legit is to ensure they have the treasury and war chest to act as a buffer for the funds they take from the public,” he said.

 

While acknowledging that some operators might find the requirements difficult to meet, Ake maintained that the measures were not excessive, arguing that the broader objective of protecting the public should take precedence over individual operators’ concerns.

 

On the restriction of P2P transactions, he explained that the CBN’s provisions were targeted at third-party platforms facilitating such transactions rather than private transactions conducted directly between individuals.

 

According to him, the regulator wants platforms to ensure that the identities of parties involved in transactions are traceable, including through their Bank Verification Numbers (BVN).

 

He said operators unable to meet the new capital requirements could explore mergers and consolidation to strengthen their financial positions.

 

“At some point, operators who know they don’t have what it takes to meet up with these requirements may have to consider mergers and consolidation. Operators may have to come together, pool their resources, and merge to form a stronger whole that can meet these thresholds,” he said.

 

Ake, however, urged the CBN to consider a tiered licensing framework that would allow operators to participate based on their financial capacity, transaction limits and the scale of their activities.

 

Similarly, Founder and Chief Executive Officer of Cyberchain Consult, Jude Ozinegbe, warned that the N15 billion capital threshold for foreign currency-referenced stablecoin issuers could create significant barriers to entry, particularly for indigenous fintech entrepreneurs and emerging stablecoin projects.

 

He described the new regulatory framework as an important development that could bring greater structure, accountability and confidence to Nigeria’s digital asset ecosystem.

 

According to him, the increasing use of stablecoins beyond cryptocurrency trading, particularly in payments, cross-border settlements and digital commerce, makes stronger regulatory oversight necessary.

 

“My first position is that regulation must protect the market without suffocating innovation,” Ozinegbe said.

 

He expressed support for the CBN’s efforts to strengthen oversight of stablecoin issuance, reserve management, capital adequacy, anti-money laundering and transaction monitoring.

 

“From a compliance standpoint, I support the CBN’s efforts to strengthen oversight of stablecoin issuance, reserve management, capital adequacy, anti-money laundering and transaction monitoring. Stablecoins are no longer just digital assets for trading. They are increasingly being used for payments, cross-border settlements and digital commerce. That makes proper regulation essential,” he stated.

 

While acknowledging the need for issuers to demonstrate the financial capacity to meet reserve and redemption obligations, Ozinegbe argued that capital requirements should reflect the actual risks and scale of individual businesses.

 

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He said transaction volumes, customer exposure and systemic importance should determine the level of capital required of operators rather than imposing uniform thresholds that could disadvantage smaller but credible businesses.

 

“I believe a graduated, risk-based framework would give smaller but credible innovators an opportunity to participate while maintaining appropriate safeguards,” he said.

 

Ozinegbe warned that excessively restrictive compliance requirements could have unintended consequences, including forcing legitimate businesses to relocate to more favourable jurisdictions or pushing digital asset transactions into informal channels where regulatory monitoring would be difficult.

 

“The real challenge is implementation. If compliance requirements become too restrictive or difficult to meet, legitimate users and businesses may simply migrate to more favourable jurisdictions or move towards informal channels where transactions are harder to monitor. At the end of the day, regulation should encourage transparency and responsible participation, not unintentionally drive activity underground,” he said.

 

The CBN, in the new regulations, said the framework was designed to support responsible innovation while safeguarding the integrity, stability and efficiency of Nigeria’s financial system.

 

The apex bank also introduced requirements covering corporate governance, reserve backing, liquidity, redemption, cybersecurity, customer protection, transaction monitoring and regulatory reporting.

 

The regulations prohibit the issuance and trading of algorithmic stablecoins and other stablecoins that are not adequately backed by eligible reserve assets or do not provide holders with enforceable redemption rights.

 

They also require stablecoin issuers to maintain adequate reserves and ensure that customers can redeem their holdings in line with prescribed conditions.

 

For P2P services, the regulations distinguish between transactions facilitated by third-party platforms and private bilateral transfers between individuals.

 

Platforms must obtain specific CBN approval before providing such services, while purely private transactions involving only the transacting parties are excluded from the provisions.

 

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