Nigeria crypto and stablecoin licence 2026: what the CBN rules require before 4 May 2027

By Harry Khan, Founder · Published 9 November 2026 · Last reviewed 9 November 2026

The short answer

Nigeria now licenses crypto and stablecoin businesses through its central bank. The Regulations for the Operations of Non-Security Virtual Assets in Nigeria took effect on 5 November 2026. They cover any business that issues stablecoins, exchanges or converts virtual assets, holds them for customers, runs wallets or payment gateways, or operates a peer-to-peer trading platform, where the asset is not a security. Securities-type tokens stay with the Securities and Exchange Commission (SEC).

The rules reach beyond Nigeria's borders. Section 6.1 says no person may carry on a regulated activity in or from Nigeria, or direct one at persons in Nigeria, without the licence the activity requires. A global exchange or wallet that markets to Nigerian users or accepts naira is therefore in scope, even with no office in Lagos.

For firms already serving Nigeria, the rules set a hard timetable: register with the CBN by 5 December 2026, start reporting by 4 January 2027 and file a complete licence application by 4 May 2027. A firm that has not filed by then must stop until it is licensed. This guide sets out who needs which licence, the capital, the stablecoin rules and the file the CBN expects.

Key dates for existing operators

Section 54.1 lets existing operators continue during the transition, but only at their existing scale, under the CBN's interim conditions and on four conditions. The dates below count from commencement on 5 November 2026.

Two groups get specific treatment. Existing arrangements for foreign-currency stablecoins are assessed against the Class 2 rules, including Nigerian incorporation, and any continued access during the assessment needs the CBN's express interim permission. Platforms running peer-to-peer services at commencement must apply for the separate peer-to-peer approval within the same 180 days and may only continue on the same terms meanwhile.

New entrants have no transition. From 5 November 2026 they need a licence before they start.

The six CBN permissions

Section 2.1.1 lists six licences and authorisations. Which one a firm needs depends on whether it issues coins, whether it already holds an SEC licence and whether it is already a CBN-licensed institution.

A licence covers only the activities and tokens stated in it, and it cannot be transferred. No firm may hold both issuer classes without the CBN's prior written approval. The services that sit under the Other Services Licence are listed in section 9.1: custody and custodial wallets, non-custodial wallet services, exchange, conversion, transfer and remittance, token distribution, virtual asset payment gateways, stored-value facilities and platform-facilitated peer-to-peer services.

Capital requirements

Capital is set in sections 15 to 17. It must be paid up on entry and kept at all times, and the CBN may set a higher amount for any firm.

Three points catch firms out. First, CBN capital is separate from capital held for the SEC or any other regulator, and the same money cannot count twice (section 16.2). An exchange licensed by the SEC that adds non-security services therefore holds both amounts. Second, a bank or payment firm extending its licence cannot count its existing capital towards the ₦1 billion. Third, section 15.3 states there is no offshore issuer exemption from incorporation, licensing or capital.

Class 2 issuers also hold dollar liquidity for Nigerian redemptions, separate from capital and reserves. Section 11 sets it at the highest of US$10 million, 15% of Nigeria-linked outstanding liabilities, and the amount needed for 30 days of stressed Nigerian redemptions and payments.

CBN or SEC: which regulator covers your activity

Section 4 divides the work by the type of asset. The CBN regulates non-security virtual assets and the payment, settlement, transfer, remittance, foreign exchange, deposit, lending and custody services linked to them. The SEC regulates virtual assets that are securities and the capital market activity around them. A CBN licence never authorises dealing in a security token.

Where a firm works across both mandates it needs both permissions, and the regulator for its main activity leads supervision. Where a security token trade settles in naira, a foreign currency or a stablecoin, the settlement leg falls under the CBN. A firm unsure how a token is classed must ask the CBN for a classification opinion before dealing in it, and the CBN consults the SEC where the token may be a security.

Stablecoins: Class 1 and Class 2

The stablecoin rules are among the most detailed anywhere. Every holder has an absolute, legally enforceable right to redeem at par at any time (section 23.2). The issuer must pay out by the end of the business day after a valid request, with no fee for a standard redemption. Coins may not be minted against money not yet received.

Section 2.2 bans five kinds of token outright: algorithmic stablecoins, fiat-referenced tokens backed mainly by other crypto, tokens issued by or for sanctioned persons, coins marketed as stablecoins without a right to redeem at par, and any other token the CBN finds too risky. Anyone who offers, distributes or gives access to a banned token faces enforcement.

The Class 2 rule is the one with the widest reach. A foreign licence, registration or arrangement with a Nigerian intermediary does not substitute for a Class 2 licence and token approval. A global issuer whose dollar coin is used in Nigeria, and the platforms that list it, need to decide how that coin will reach Nigerian users after the transition: through a Nigerian Class 2 entity, or not at all. Our comparison of stablecoin licences by country shows how Nigeria compares with the UK, EU, US and other markets.

Exchanges, wallets and peer-to-peer platforms

Most firms affected are not issuers. Exchanges, custodial and non-custodial wallets, merchant gateways and peer-to-peer platforms need an Other Services Licence, or an Other Services Authorisation if they already hold an SEC licence, and ₦1 billion of CBN capital.

Peer-to-peer trading gets its own section. A platform that matches counterparties or holds funds in escrow for peer-to-peer trades needs a licence and the CBN's express approval for that service. Before a trade, the platform must check that the name and Bank Verification Number on the naira bank account match the verified customer. The platform also reports its peer-to-peer activity to the CBN, and trades of naira against a dollar stablecoin face added restrictions.

Every licensee must also meet the conduct, AML, technology and governance parts of the rules: sanctions screening against the UN, EU and UK lists, customer agreements and pre-contract information, complaint handling, refunds for unauthorised transfers, information security, and business continuity with an orderly wind-down plan. These are the parts of the file that take longest to evidence.

The application file and approval in principle

Issuer licensing runs in two stages. The applicant first seeks an Approval-in-Principle (AIP), which can be granted before the company is incorporated. The AIP is not a licence and does not permit any regulated activity. The CBN then checks operational readiness and grants the final licence once the AIP conditions are met. The CBN may offer a preliminary meeting before filing and consults any foreign regulator of the applicant or its parent.

Section 7.6 lists what an issuer submits:

• incorporation documents, ownership and group structure down to ultimate beneficial owners;
• a three-year business plan covering token design, markets and projections;
• a whitepaper for each token seeking approval;
• two years of audited accounts, or management accounts for a new company;
• governance, risk management and internal control frameworks;
• an AML, counter-terrorist financing and proliferation financing programme;
• a description of the issuance platform, smart contracts and minting and burning controls, with an independent smart contract security audit;
• agreements or term sheets with reserve banks, custodians and distributors;
• reserve management, valuation, reconciliation and segregation policies, and the appointment of an approved independent assessor;
• business continuity, incident response, recovery and orderly wind-down plans.

Applicants from foreign groups must also describe their foreign supervision, which supplements but does not replace Nigerian oversight. Directors, shareholders and controllers are assessed for fitness and propriety under section 18. Our guide to obtaining a crypto licence explains how these documents are usually built.

What to do before 5 December

1. Map every activity you provide to Nigerian users against the section 9.1 services and the CBN and SEC split, and decide which permission each needs.
2. Register with the CBN by 5 December 2026 if you were operating on 5 November.
3. Hold your current scale. The transition only covers existing activity, so new products and new markets wait for the licence.
4. Check every token you list against the banned categories and the Class 2 rule, and plan for any dollar coin that has no Nigerian Class 2 issuer.
5. Plan the capital, keeping CBN capital separate from SEC and other licence capital.
6. Build the reporting needed from 4 January 2027, including peer-to-peer reporting where relevant.
7. Prepare the full file so it can be filed well before 4 May 2027.

How Buckingham Capital Consulting supports Nigeria market entry

Buckingham Capital Consulting has handled payments, e-money and cryptoasset licensing since 2013, obtaining authorisations for firms including Nexpay, Orbital, Dzing Finance and Hryze. Our crypto licensing team prepares CBN applications for exchanges, wallet providers, payment gateways and stablecoin issuers, from the activity map and capital plan to the policy set, whitepaper and technology evidence. For firms expanding across Africa, our Kenya VASP licence guide covers the Central Bank of Kenya and Capital Markets Authority regime. Contact us to discuss your Nigerian application.

Questions

Get in touch: +44 7563 115980 (phone and WhatsApp) or [email protected].

This article is general information, not legal advice. Requirements change, and the regulator’s own publications take precedence.