The Central Bank of Nigeria (CBN) has set a minimum paid-up capital requirement of ₦15 billion for Class 2 licensed issuers of foreign-currency-referenced stablecoins under its Regulations for the Operations of Non-Security Virtual Assets in Nigeria. The rules, issued via a circular dated November 5, 2026, and signed by Musa I. Jimoh, Director of the Payments System Policy Department, took effect the same day.
Naira-referenced (Class 1) stablecoin issuers face a lower threshold of ₦10 billion, while other non-security virtual-asset service providers must maintain at least ₦1 billion. The capital must be held on entry and at all times thereafter; the CBN may prescribe higher amounts. Foreign-currency issuers must incorporate in Nigeria, obtain a Class 2 licence, and secure CBN approval of the specific token—foreign licences do not substitute for these requirements. Issuers must also maintain full reserve backing plus an additional buffer of at least 2% of the face value of coins in circulation. Existing operators have a transition window (registration within 30 days and licence application within 180 days).
The Drivers of the Current Situation
The central development is the CBN’s new regulatory framework establishing differentiated capital floors for stablecoin issuers, with the ₦15 billion minimum applying specifically to foreign-currency-backed tokens. Confirmed elements include the November 5, 2026 effective date of the Regulations for the Operations of Non-Security Virtual Assets in Nigeria, the Class 2 capital requirement of ₦15 billion (versus ₦10 billion for Class 1 naira-referenced issuers), the mandate for Nigerian incorporation and local licensing even for offshore-origin tokens, the separation of capital from reserves and customer assets, the 2% over-collateralisation buffer, and the limited transition period for existing operators. The rules also cover related services such as payments, custody and certain peer-to-peer activity.
Further guidance, licensing decisions or enforcement actions will determine how the capital thresholds are applied in practice.
Impact and Broader Context
The capital floors raise the barrier to entry for foreign-currency stablecoin issuers seeking to serve the Nigerian market and reinforce local supervisory control. They raise questions about the ability of global issuers to comply through Nigerian subsidiaries, the competitive position of naira-referenced versus dollar-referenced tokens, the interaction between CBN and Securities and Exchange Commission capital rules where both apply, the practical effect on liquidity and availability of foreign stablecoins for Nigerian users, and the broader tightening of oversight over non-security virtual assets used for payments and transfers. Coverage notes that the framework aims to strengthen reserve, redemption and prudential safeguards while limiting unlicensed offshore activity.
Subsequent licensing outcomes, industry responses or any adjustments to the capital levels will clarify the near-term impact on the local stablecoin landscape.
This analysis draws from the CBN’s November 5, 2026 regulations and contemporaneous reporting. The ultimate number of licensed issuers, the practical enforcement of the ₦15 billion floor, and any effects on stablecoin availability or market structure remain subject to implementation, compliance by operators, and further regulatory guidance.