Nigeria Sets N15bn Capital Bar for Dollar Stablecoin Issuers

Nigeria's central bank has set a paid-up capital floor of N15 billion for any company that wants to issue a foreign-currency stablecoin, such as a dollar-pegged token, to people in the country. The requirement sits inside a wider rulebook for non-security virtual assets that took effect on 5 November 2026 and gives existing operators a conditional 180-day window to apply for a licence.

According to Stablecoin Insider, which reviewed the Central Bank of Nigeria (CBN) regulations, the circular is titled Regulations for the Operations of Non-Security Virtual Assets in Nigeria, carries the reference PSP/DIR/PUB/CIR/001/004 and was signed by Musa Jimoh of the CBN's Payments System Policy Department. The framework covers licensing, capital, reserves, redemption, anti-money laundering and prohibited tokens for stablecoins and related virtual asset service providers (VASPs).

Contents

01

Two Classes, Two Capital Floors

02

No Offshore Shortcut for Dollar Tokens

03

Reserves, Redemption and Banned Tokens

04

The Transition Clock for Existing Operators

Two Classes, Two Capital Floors

The rules split stablecoin issuance into two classes. Class 1 covers tokens referenced to the naira, and a licensed issuer must keep paid-up capital of N10 billion under Section 15.1. Class 2 covers tokens referenced to a foreign currency, including dollar stablecoins, and a licensed issuer must hold N15 billion on entry and at all times afterwards under Section 15.2.

The capital is not a tax on the USDC or USDT balances that users already hold. It is a gate that a Nigerian-incorporated company must clear before it can issue a foreign-currency-referenced token under CBN rules. Other non-security virtual asset services outside Class 1 and Class 2 issuance need N1 billion in paid-up capital under Section 16.1, separate from any capital the Securities and Exchange Commission (SEC) requires of the same operator.

What counts as eligible capital is narrow. Under Section 17.1 it must be cash in a designated capital account at the CBN, or Federal Government of Nigeria securities held with an approved custodian under a bank lien. Virtual assets, guarantees and money that is merely expected to arrive do not qualify. Section 17.3 adds that this capital cannot be the same funds as the reserve pool, the CBN reserve deposit, customer money or day-to-day operating liquidity.

No Offshore Shortcut for Dollar Tokens

The provision with the widest reach is Section 6.5. It says a foreign-currency-referenced stablecoin may be made available to persons in Nigeria only as a Class 2 stablecoin issued through a Nigerian-incorporated Class 2 licensee. Section 15.3 states plainly that there is no offshore issuer exemption from incorporation, licensing or capital.

CryptoSlate reports that a foreign licence, a regulatory status elsewhere or an agreement with a Nigerian intermediary cannot stand in for the Class 2 Foreign Currency Issuer License and a separate approval of the token itself. The rules reach regulated activity directed at people in Nigeria even when the provider has no physical presence in the country. Issuer applicants must also set up a staffed Nigerian office with effective local management, including a resident chief compliance officer, before final licensing, and a licence for non-issuance services does not permit a firm to issue stablecoins.

There is one narrow exception. Section 11.10.17 lets the CBN recognise a foreign-issued stablecoin solely for expressly approved wholesale cross-border settlement. That route excludes retail customers in Nigeria, so it does not replace the retail licensing path. Class 2 token approval also does not authorise a token to settle, price or discharge a naira-denominated domestic obligation unless foreign-exchange or other law expressly permits it.

Stablecoin Insider's reading is that global dollar brands do not get a passport-style free ride, and that distribution models built on offshore minting and redemption while serving Nigerian users now need a local Class 2 balance sheet. In its analysis, the capital floors, untouchable full reserves and a 2% buffer will thin the field of would-be issuers and push dollar distribution toward well-capitalised Nigerian entities or joint ventures. That is the publication's assessment, not a statement of fact about how the market will develop.

Reserves, Redemption and Banned Tokens

Capital is only one layer. Every licensed issuer must keep a reserve pool worth at least the par value of all its stablecoin obligations at all times, not just on reporting dates, and must add overcollateralisation of at least 2% under Sections 24.1 to 24.4. New tokens may be minted only after equivalent eligible reserve assets have already arrived in the pool, so issuing against expected future receipts is barred under Section 24.3. Class 1 issuers must additionally hold at least 20% of the reserve pool as a cash deposit with the CBN, with same-day notice and remediation if that deposit falls short.

Punch summarised the redemption standard as face value, generally no later than the next business day after a valid request, with no charges for standard redemptions. That pairs with the prohibited token list in Section 2.2, which bars tokens that do not carry an enforceable right to redeem at par. The same section bans algorithmic stablecoins and tokens that reference a fiat currency but are backed wholly or primarily by other virtual assets from being issued, offered, distributed or traded in Nigeria.

The Transition Clock for Existing Operators

Firms already serving Nigerian users are not switched off immediately. Section 54.1 gives existing operators 180 calendar days from commencement to submit a complete application for the appropriate licence or authorisation, and they may keep operating only at their existing scale and subject to CBN interim conditions. Registration with the bank is required within 30 days and supervisory reporting within 60 days, or an earlier prescribed period. Anti-money laundering, counter-terrorist financing and counter-proliferation financing duties apply from commencement.

Continued access during the CBN's assessment of Nigerian incorporation, issuer licensing and service-provider approvals requires the bank's express interim permission and does not create a permanent exemption. Filing an application alone does not establish permission to keep serving the market, and operators that miss the deadline must stop until they hold the necessary licence or authorisation.

The regulations preserve the SEC's statutory jurisdiction and do not automatically cancel approvals granted under other Nigerian frameworks, but an existing principal licence does not remove the need for express CBN approval for non-security virtual asset services. Stablecoin Insider lists the first Class 1 and Class 2 licence awards, any CBN guidance on how existing dollar-stable wallets and exchanges must route Nigerian users, and whether global issuers announce Nigerian incorporation or local partners capitalised to the N15 billion bar as the developments to watch. It also flags the attestation schedule for reserve pools and whether Class 1 reserve shortfalls trigger the cease-issuance path in Section 24.5.

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