In November 2026 the Central Bank of Nigeria issued its Regulations for the Operations of Non-Security Virtual Assets in Nigeria: a full licensing and supervision regime for stablecoins, Deposit Money Tokens, and the businesses that issue, distribute, hold, or trade them. It is issued under the Presidential Executive Order on Virtual Assets Coordination, 2026, and it runs to more than 160 pages.
The tempting read is "another compliance file for legal." That misses what the regulation actually does. As with the CBN's June payments rules, which we covered as a business-model decision, not just a compliance cost, the hard questions here are commercial and technical. Its capital floors decide whether you can issue at all. Its list of banned tokens can end a product. And most of the remaining work is systems work, on short deadlines.
This piece covers the structural decisions. It is not legal advice, and it does not cover every provision.
First, check whether you are in scope
The regulation covers non-security virtual assets only. Tokens that are securities or investment products stay with the Securities and Exchange Commission, and the CBN says plainly that nothing in the regulation extends to them. If your token is non-security, look for yourself in this list of licences and approvals (§2.1, §6.2):
- Class 1 Issuer Licence: you issue a naira-referenced stablecoin.
- Class 2 Issuer Licence: you issue a stablecoin referenced to a foreign currency, such as a dollar stablecoin offered to people in Nigeria.
- Other Services Licence or Authorisation: you do not issue, but you provide services such as custody, exchange, or distribution. The authorisation route is for firms that already hold an SEC licence.
- Approval to Extend Permitted Activities: you are an existing CBN-licensed institution adding virtual-asset payment activities.
- Deposit Money Token Licence: for deposit tokens.
Two points catch people out. First, peer-to-peer platforms do not get their own licence. If you match buyers and sellers, hold escrow, or settle the naira leg, you need an Other Services Licence, an Other Services Authorisation, or an Approval to Extend, plus express CBN approval for P2P services within it (§10.2). Second, a foreign licence does not count. Naira stablecoin issuers must be incorporated in Nigeria (§6.5), and a dollar stablecoin can be made available here only through a Nigerian-incorporated Class 2 issuer. The regulation states there is no offshore issuer exemption from incorporation, licensing, or capital (§15.3).
The capital floor is a gate, not a line item
The paid-up capital requirements are where many business cases end (§15–16):
- ₦10 billion for a Class 1 (naira) issuer.
- ₦15 billion for a Class 2 (foreign-currency) issuer.
- ₦1 billion for providers of other non-issuance services. If you also hold an SEC licence, this sits on top of the SEC's own capital requirement.
These are minimums, held "on entry and at all times thereafter," and the CBN may set higher amounts. A stablecoin can also be designated systemic if its circulating supply stays above ₦500 billion for 30 consecutive days, or more than five million people in Nigeria hold or use it, which brings enhanced supervision (§3.6).
For most startups, ₦10–15 billion means issuing is not a near-term option. The realistic choices are to partner with a licensed issuer, operate under a services licence, or raise for issuance knowing the floor. Make that call before you spend on anything else.
Some products are simply banned
Section 2.2 lists Prohibited Tokens that may not be issued, offered, distributed, or traded in Nigeria:
- Algorithmic stablecoins, meaning tokens that hold their value through supply mechanics rather than full backing by eligible reserves.
- Fiat-referenced tokens backed mainly by other crypto assets.
- Tokens issued by or for sanctioned persons or jurisdictions.
- Tokens marketed as stablecoins that give holders no enforceable right to redeem at par.
If your product lists, routes, or settles in any of these, you have a product decision to make, not a paperwork task. Anyone who facilitates access to a prohibited token is exposed to enforcement too (§2.3).
What you will actually have to build
Read the obligations as a systems specification and the work becomes clearer:
- Identity that links to the payment rail. KYC requires NIN and, where the customer has one, BVN (§26.3.4). P2P providers may not release a token until they have verified that the name and BVN on the naira account match the verified customer (§10.3.3). That is an integration, not a form field.
- Reserves and redemption you can prove. Holders have a legal right to redeem at par, processed by the end of the next business day, with no fee for a standard redemption (§23.2–23.4). Issuers may not mint until reserves have been received (§23.1).
- Monthly attestation. Licensed issuers must publish a reserve attestation by an approved independent auditor within 15 business days of each month-end (§20.7). Your ledger and reconciliation have to produce that evidence on schedule.
- Per-token approval. No stablecoin may be made available until it has received Token Approval (§6.5). You approve tokens one at a time, not once for the business.
- Supervisory reporting. Periodic returns cover volumes, reserves, redemption performance, complaints, and incidents. Class 2 distributors add monthly transaction reports (§20.8–20.9).
The clocks are short
If you already operate, the transition rules in §54.1 apply. They run from the commencement date, which the CBN specifies in its issuing instrument rather than in the regulation itself (§56.1), so confirm that date first.
- Within 30 days: register with the CBN.
- From commencement: comply with AML/CFT requirements.
- Within 60 days, or an earlier prescribed period: begin supervisory reporting.
- Within 180 days: submit a complete licence application. P2P operators apply in the same window.
Until then you may continue only at your existing scale, under the CBN's interim conditions. If you miss the 180-day deadline, you must stop operating until you are licensed. The penalties are not small either. Running a regulated activity without the required licence carries a fine of at least ₦100 million plus at least ₦1 million for each day it continues (§51.1).
Your readiness check
Work through this before anything else:
- Scope: Is your token non-security, and which licence or approval fits what you do?
- Capital: Can you meet the floor, or is partnering with a licensed issuer the realistic path?
- Product: Does anything you list or route fall into a prohibited category?
- Systems: Can your stack do BVN-matched identity, next-day par redemption, monthly attestation, and regulatory returns?
- Dates: Do you know the commencement date and your 30-, 60-, and 180-day deadlines?
If the systems question is the one that worries you, that is the work we help teams scope: reporting, reconciliation, and identity integrations built to produce evidence a regulator will accept. The first conversation is a free, no-pressure 45-minute structured call: start the conversation.
Source: Central Bank of Nigeria, Regulations for the Operations of Non-Security Virtual Assets in Nigeria (November 2026), read directly; section numbers are cited inline. This is a summary of headline provisions, not legal advice. Requirements differ by licence type, and the CBN may prescribe further rules.
