The Central Bank of Nigeria (CBN) now has five licence and approval routes for crypto businesses, from a ₦10 billion (about $7.4 million) naira-stablecoin licence to a bolt-on approval for banks. Firms already operating have 180 days to apply.
TL;DR
- Naira stablecoin issuers need ₦10 billion (~$7.4M); dollar stablecoin issuers need ₦15 billion (~$11M).
- Apps that send stablecoins for customers or swap them for naira generally need ₦1 billion (~$740,000) in CBN capital, on top of any SEC capital. Holding coins only for trading stays with the SEC.
- P2P trading stays legal. Platforms that run it need CBN approval and must match your name and BVN; private trades between two people are not covered.
Key facts
- The rules are the CBN’s 167-page Regulations for the Operations of Non-Security Virtual Assets in Nigeria (CBN).
- They took effect on 5 November 2026, according to the CBN circular published with them, signed by Musa Jimoh, Director of the Payments System Policy Department (CBN).
- Running a CBN-regulated crypto service without the right licence or approval carries a fine of at least ₦100 million (~$74,000), plus ₦1 million (~$740) a day (Section 51).
Dollar figures use the official rate of ₦1,358.50 per dollar at the close on 12 November 2026 (Nairametrics, citing CBN data), rounded.
The document is long, so we went through all 167 pages and pulled out what a founder, an investor, a bank or a trader needs to know. The rules cover “non-security” virtual assets: tokens used to pay, save or move money, such as stablecoins, rather than tokens sold as investments. Investment tokens stay with the Securities and Exchange Commission (SEC).
They are issued under the Presidential Executive Order on Virtual Assets Coordination, 2026, which President Bola Tinubu signed in July. That order made the CBN chair of a new Virtual Asset Council, with the SEC and the Nigeria Revenue Service as vice chairs (State House, Nairametrics).
Why it matters: Nigerians received about $59 billion in crypto between July 2023 and June 2024, according to Chainalysis. In December 2023 the CBN let banks open accounts for crypto firms again (Nairametrics). The new rules go further: they set out who may run these services, and on what terms. They also reach foreign firms serving people in Nigeria, whether or not they have an office here (Part 1).
The five CBN crypto licence routes at a glance
Which route you need depends on the service, the token and the licences you already hold. The companies named are examples of each kind of product, not a statement of their licence status: the CBN has not said which firms need which route.
1. Naira-referenced Issuer Licence (Class 1)
If you: issue a naira stablecoin
For example: cNGN, a naira token issued by Wrapped CBDC Ltd (SEC)
Minimum CBN capital: ₦10bn (~$7.4M)
2. Foreign Currency Issuer Licence (Class 2)
If you: issue a dollar (or other foreign-currency) stablecoin for people in Nigeria
For example: USDT, issued by Tether, or USDC, issued by Circle; to reach retail customers here, either would need a Nigerian Class 2 issuer
Minimum CBN capital: ₦15bn (~$11M), plus a cash buffer for redemptions
3. Other Services Licence
If you: hold, swap or send stablecoins and other non-security tokens for customers, with no SEC licence
For example: a crypto app such as Roqqu, which lets users hold, buy and swap stablecoins (The Condia), or a stablecoin payments firm such as Yellow Card, which is working with Mastercard on stablecoin remittances in Nigeria (BusinessDay)
Minimum CBN capital: ₦1bn (~$740,000)
4. Other Services Authorisation
If you: do the same, and already hold an SEC licence for virtual-asset services
For example: an exchange in the SEC’s programme, such as Busha or Quidax, both of which let users trade USDT with naira (The Condia)
Minimum CBN capital: ₦1bn (~$740,000), on top of SEC capital
5. Approval to Extend Permitted Activities
If you: are already licensed by the CBN and want to add crypto payments
For example: a bank or licensed payment company
Minimum CBN capital: Your existing capital, plus the ₦1bn rules
Sources: CBN regulations, Sections 6, 9, 15 and 16.
Where the line falls matters. Converting stablecoins and other non-security tokens to naira for customers is a CBN service (Section 9). Holding coins only for trading or investment stays with the SEC, unless the app also uses them for payments, such as sending them for a customer, paying merchants or storing value (Section 4). A consumer app such as Roqqu, Quidax or Busha would need to check each service it offers against that line; the CBN has not said which firms fall under which route. The SEC lists Busha and Quidax in its Accelerated Regulatory Incubation Programme, a provisional stage that is not CBN approval (SEC).
Two more permissions sit outside the five. A peer-to-peer (P2P) marketplace does not get its own licence; it needs one of the three service routes plus the CBN’s express approval for P2P (Section 10). Banks that want to issue Deposit Money Tokens, digital tokens that represent an ordinary bank deposit, need the CBN’s prior written approval (Section 41).
Application fees for the two stablecoin licences are ₦10 million (~$7,400) each, with ₦5 million (~$3,700) yearly renewals (Schedule 3). Fees for the other routes are “as prescribed by the Bank”: the document does not name an amount.
What stablecoin issuers must hold
A stablecoin is a token meant to stay worth one naira, one dollar or another fixed amount. cNGN, for example, is pegged one-to-one to the naira and run by WrappedCBDC Limited, which the SEC lists in its regulatory incubation programme for August 2024 to August 2025 (SEC).
Issuers must be incorporated in Nigeria and keep a staffed office here (Section 7). There is “no offshore issuer exemption” (Section 15). The capital must be cash in a designated account at the CBN, or Federal Government securities under a CBN lien (Section 17).
Every token must be backed one-to-one, plus a 2% buffer (Section 24). At least 40% of reserves must be cash or similarly liquid assets. Naira stablecoin issuers must also keep at least 20% of reserves as a cash deposit at the CBN, on top of that 40%. They must use at least three banks and hold no more than 30% of reserves at any one bank.
Holders get an “absolute, legally enforceable right” to redeem at par (Section 23). Issuers must pay out by the end of the next business day, free of charge, for a standard redemption. An independent auditor must check the reserves every month.
What it means for dollar stablecoins like USDT and USDC
Section 11 says no foreign-currency stablecoin may be offered, distributed, marketed or exchanged to people in Nigeria unless it is approved as a Class 2 stablecoin and issued through a Nigerian-incorporated Class 2 issuer. On the text as written, that reaches the dollar coins Nigerians use most, unless a licensed local issuer brings them in. There is one narrow exception: the CBN may recognise a dollar stablecoin issued abroad for wholesale cross-border settlement by banks and other approved firms, but it cannot be offered to retail customers in Nigeria (Section 11). Existing arrangements can apply for interim permission during the 180-day transition, which “shall not confer a permanent exemption” (Section 54).
Dollar stablecoin issuers carry extra weight. They must keep operational liquidity of at least US$10 million, 15% of Nigeria-linked liabilities, or 30 days of stressed outflows, whichever is highest (Section 11). They must also appoint a Nigerian bank as their redemption agent. Foreign sponsors can be involved, but the Nigerian company stays fully responsible.
What if you want to issue both naira and dollar stablecoins?
One company can hold both a Class 1 (naira) and a Class 2 (dollar) issuer licence, but only with the CBN’s express prior written approval (Section 6).
The capital minimums are ₦10 billion for Class 1 and ₦15 billion for Class 2. The rules don’t say how the CBN would assess capital for one company holding both, so confirm it before you plan. If the two minimums are counted separately, that is ₦25 billion (~$18.4 million), plus a US$10 million-plus liquidity buffer for the dollar coin.
Banks and financial holding companies must issue through “a separately incorporated subsidiary” (Section 18). That does not, on its own, mean one subsidiary for each coin.
What is banned
Section 2 lists tokens nobody may issue or offer in Nigeria:
- algorithmic stablecoins, which hold their value “solely or primarily” through code that adjusts supply;
- tokens that claim a fiat value but are backed mainly by other crypto assets;
- tokens marketed as stablecoins without an enforceable right to redeem at par;
- tokens linked to sanctioned people or countries.
Stablecoin issuers may not pay interest or yield, directly or through partners (Section 13). Firms must also tell customers clearly that a stablecoin is not a bank deposit and is not insured by the Nigeria Deposit Insurance Corporation (Section 27).
What it means for P2P traders
P2P trading is not banned. But a platform may not release or credit tokens until it has checked that the name and Bank Verification Number (BVN) on the paying bank account match the verified customer (Section 10). Naira payments must move through channels the CBN permits, and splitting trades to avoid oversight is prohibited.
For users, that means a platform without CBN approval will have to stop offering P2P once the transition period ends. It also means a trade on a covered platform paid from a relative’s or friend’s account would fail the name check. The rules do not cover a purely private trade between two people with no platform or middleman involved (Section 10).
What it means for exchanges, startups and foreign firms
The CBN’s ₦1 billion is “distinct from and additional to” any capital held for the SEC (Section 16). The SEC already asks ₦2 billion (~$1.5 million) of a digital asset exchange and ₦2 billion of a digital asset custodian, with a 30 June 2027 deadline (SEC Circular 26-1). An SEC-registered exchange that also converts stablecoins to naira for customers, or offers another CBN service, could therefore need at least ₦3 billion (~$2.2 million) across both regulators.
Smaller builders offering a CBN-regulated service, such as stablecoin payments, remittances or naira conversion, face the ₦1 billion floor; trading-only custody can stay with the SEC. These services also need a chief compliance officer and a money laundering reporting officer resident in Nigeria (Section 9).
Foreign firms serving Nigerians are covered whether or not they have an office here (Part 1), and must incorporate in Nigeria before final licensing (Section 9). For an overseas exchange or stablecoin company eyeing Nigeria, that means a local company, local compliance staff and the required capital held in a form the CBN accepts: cash in a designated CBN account, or Federal Government securities under a CBN lien (Section 17).
Anti-money-laundering rules apply from day one. Firms must verify customers and record the sender and receiver of every transfer. For transfers of US$1,000 or more, or the naira equivalent, they must collect fuller details and pass them to the receiving provider (Section 26).
What’s next for existing operators
Firms already running a covered service must register with the CBN within 30 days and start supervisory reporting within 60 days (Section 54). They must submit a complete application for the right licence or authorisation within 180 calendar days of commencement, or stop operating.
If the clock started on 5 November, those dates fall on 5 December 2026, 4 January 2027 and 4 May 2027. Until they are licensed, operators may only continue at their existing scale.
How unbacked crypto assets, such as bitcoin, will be classified is still for the Virtual Asset Council to confirm. Until it does, payment use sits with the CBN and trading with the SEC (Schedule 8).
