CBN Imposes N1 Billion Capital Requirement On Crypto Operators, Gives 180 Days To Obtain Licence

The Central Bank of Nigeria (CBN) has given existing cryptocurrency service providers 180 days to apply for operating licences or authorisation, warning that those who fail to comply must stop operations until they obtain the required approval.

The directive is contained in the bankโ€™s Regulations for the Operations of Non-Security Virtual Assets in Nigeria, issued on Thursday, which also introduce a minimum capital requirement of N1 billion for certain virtual asset service providers.

The regulations establish new licensing, capital and supervisory requirements for businesses involved in cryptocurrency-related payment services, including stablecoins, digital wallets, transfers, remittances and settlement activities.

Under Section 54.1 of the regulations, existing operators must register with the CBN within 30 days of commencement, begin submitting supervisory reports within 60 days or an earlier period prescribed by the bank, and submit complete licence applications within 180 days.

The document states that operators may continue providing services during the transition period only at their existing scale and subject to conditions imposed by the CBN.

โ€œFailure to submit within that period shall require cessation until the required licence or authorisation is obtained,โ€ the regulations stated.

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The CBN also requires operators to comply with anti-money laundering, counter-terrorist financing and counter-proliferation financing requirements from the commencement of the regulations.

The circular accompanying the document stated that the regulations took effect on Thursday.

Under Section 16.1, the CBN requires providers of other non-security virtual asset services to maintain a minimum paid-up capital of N1 billion. The requirement applies to businesses holding an Other Services Licence, Other Services Authorisation or Approval to Extend Permitted Activities under the regulations.

โ€œA provider of Other Non-Security Virtual Asset Services shall maintain minimum paid-up capital of N1 billion, or such higher amount as the bank may prescribe, on entry and at all times thereafter,โ€ the document stated.

For operators already licensed by the Securities and Exchange Commission (SEC), the N1 billion requirement is additional to the capital prescribed by the securities regulator.

The regulations prohibit operators from using the same capital to satisfy both regulatorsโ€™ requirements.

Similarly, existing financial institutions seeking approval to provide covered virtual asset services must maintain the additional N1 billion without counting capital already committed to their principal banking or payment services licences.

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The CBN may also require higher capital or additional liquidity, depending on the nature, scale and risks of the approved activities.

Stablecoin issuers face N10 billion, N15 billion capital requirements
The regulations prescribe higher minimum capital requirements for businesses seeking to issue stablecoins. Under Section 15, issuers of naira-referenced stablecoins must maintain paid-up capital of at least N10 billion, while issuers of foreign-currency-referenced stablecoins must maintain at least N15 billion.

The CBN classifies the two categories as Class 1 and Class 2 stablecoin issuers, respectively. The regulation states that a Class 1 licensed issuer must maintain the prescribed capital โ€œon entry and at all times thereafterโ€.

The same requirement applies to Class 2 issuers, although the CBN may prescribe higher amounts for either category.

Both categories must also meet additional capital deposit requirements under Section 17. The regulations further require stablecoin issuers to maintain eligible reserve assets to back tokens in circulation and meet redemption obligations.

These requirements are intended to reduce the risks of financial losses, reserve shortages, and issuersโ€™ inability to repay customers.

Foreign Crypto Firms Must Meet Nigerian Licensing Rules
The regulations also extend the CBNโ€™s oversight to foreign virtual asset businesses offering regulated services to Nigerians, even if they have no physical presence in the country.

It said foreign-currency-referenced stablecoins might be issued only through Nigerian-incorporated entities holding a valid Foreign Currency Issuer Licence from the CBN.

โ€œNo foreign-currency-referenced stablecoin shall be offered, distributed, marketed, exchanged, custody-held, redeemed or otherwise made available to persons in Nigeria unless it has been approved by the bank as a Class 2 Stablecoin and is issued through a Class 2 Licensed Issuer,โ€ it said.

The regulations allow foreign companies to participate through Nigerian-incorporated licensed issuers, but require such entities to remain responsible for compliance with Nigerian regulatory requirements. They also provide that licences or approvals obtained from foreign regulators cannot replace those required by the CBN.

Existing foreign-currency stablecoin arrangements must be assessed against the new incorporation, licensing and service-provider requirements. During the assessment period, continued access to the Nigerian market will require the CBNโ€™s express interim permission.

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The regulations also cover operators of platform-facilitated peer-to-peer cryptocurrency services, requiring those already operating at the time of commencement to apply for the relevant approval within the transition period.

CBN, SEC Divide Cryptocurrency Oversight
Under the framework, the CBN regulates non-security virtual assets and related payment, settlement, remittance, foreign exchange and banking activities.

The SEC retained responsibility for virtual assets classified as securities, investment contracts and other capital market products. Section 4.1 states that regulatory responsibility depends on the nature of the virtual asset and the activity involved.

The framework also provides for coordination between the two regulators where an activity falls within their respective responsibilities.

However, an existing licence issued under another regulatory framework does not automatically exempt an operator from obtaining the specific CBN approval required for non-security virtual asset services.

The regulations were issued under the CBN Act 2007, the Banks and Other Financial Institutions Act 2020 and other applicable laws, in accordance with the Presidential Executive Order on Virtual Assets Coordination, 2026.

According to the CBN, the framework is intended to support innovation in digital payments while addressing risks related to financial stability, foreign exchange management, money laundering, and consumer protection.

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