Key takeaways

• The CBN has introduced new minimum capital requirements for stablecoin issuers in Nigeria.

• Class 1 naira-backed stablecoin issuers must maintain at least ₦10 billion in paid-up capital.

• Class 2 foreign-currency-backed stablecoin issuers must maintain at least ₦15 billion.

• The capital requirements must be maintained at entry and throughout operations.

• Foreign-based issuers are not exempt from Nigerian incorporation, licensing or capital requirements.

• The new guidelines also cover stablecoins, Deposit Money Tokens and Virtual Asset Service Providers.

• Virtual asset providers must monitor customers who regularly engage in P2P trading as a business.

• The CBN says the rules are intended to strengthen financial stability, consumer protection and regulatory oversight.

The Central Bank of Nigeria (CBN) has introduced new capital requirements for companies issuing stablecoins in the country, directing operators to maintain a minimum paid-up capital of ₦10 billion or ₦15 billion, depending on the category of digital currency they issue.

Under the new guidelines, companies issuing naira-backed stablecoins must maintain at least ₦10 billion in paid-up capital, while issuers of foreign-currency-backed stablecoins, including those backed by the US dollar, are required to maintain a minimum of ₦15 billion.

The requirements form part of a regulatory framework aimed at strengthening oversight of stablecoins and other virtual assets operating within Nigeria’s financial system.

The CBN announced the new rules in a circular dated November 5, 2026, with reference number PSP/DIR/PUB/CIR/001/004. The circular was signed by the Director of Payments Systems Policy, Musa Jimoh.

CBN Introduces Different Capital Requirements for Stablecoin Issuers

The new guidelines divide stablecoin issuers into two categories, with different minimum capital requirements applying to each class.

Class 1 licensed issuers, which operate stablecoins designed to maintain their value against the naira, are required to maintain a minimum paid-up capital of ₦10 billion.

Class 2 licensed issuers, whose stablecoins are backed by foreign currencies such as the US dollar, must maintain at least ₦15 billion.

The CBN stated that the required capital must be maintained when operators begin their activities and throughout their period of operation. The bank also retains the authority to prescribe higher capital requirements where necessary.

In the circular, the apex bank stated:

“A Class 1 Licensed Issuer shall maintain paid-up capital of ₦10 billion Naira or such higher amount as the Bank may prescribe, on entry and at all times thereafter. Class 2 Licensed Issuer shall maintain minimum paid-up capital of ₦15 billion or such higher amount as the Bank may prescribe, on entry and at all times thereafter.”

The guidelines also require both categories of licensed issuers to comply with the capital deposit, supporting evidence and supplementary requirements contained in Section 17.

CBN Says Foreign-Based Stablecoin Issuers Are Not Exempt

Another important aspect of the new rules concerns companies operating from outside Nigeria.

The CBN made it clear that foreign-based stablecoin issuers cannot avoid the country’s regulatory requirements simply by maintaining their operations offshore.

According to the bank, both categories of issuers must comply with Nigerian incorporation, licensing and capital requirements.

The circular stated:

“Both classes shall comply with the capital deposit and corresponding evidence and supplementary requirements in Section 17. There is no offshore issuer exemption from incorporation, licensing or capital.”

This provision makes clear that operating from outside Nigeria does not automatically remove an issuer’s obligation to comply with the CBN’s requirements where its activities fall under the Nigerian regulatory framework.

New CBN Guidelines Cover Stablecoins and Other Virtual Assets

Beyond the minimum capital requirements, the CBN’s new framework covers a wider range of digital assets and financial service providers.

The guidelines provide for the licensing, regulation and supervision of companies involved in non-security virtual assets, including stablecoins, Deposit Money Tokens (DMTs) and Virtual Asset Service Providers (VASPs).

They also establish operational requirements covering management structures, financial strength, customer protection, security systems and regulatory reporting.

The framework is intended to guide how companies involved in these activities are licensed and supervised by the apex bank.

By extending the rules beyond stablecoin issuers, the CBN is establishing broader regulatory expectations for businesses involved in digital-asset-related payment and financial transactions.

CBN Introduces New Monitoring Requirements for P2P Crypto Trading

The guidelines also address peer-to-peer (P2P) cryptocurrency trading, a system in which individuals buy, sell or exchange digital assets directly with one another.

Under the new requirements, virtual asset service providers must establish measures to identify customers who regularly engage in P2P transactions as a business.

The CBN directed providers to consider several factors when assessing whether a customer is operating a P2P trading business. These include the volume and frequency of transactions, the number of people involved and whether the customer advertises exchange rates.

Operators are also expected to apply stricter checks and transaction limits to customers identified as conducting P2P trading activities as a business.

In addition, providers must report such customers to the CBN in accordance with the reporting requirements contained in the guidelines.

The measures place greater responsibility on digital-asset platforms to monitor transaction patterns and identify activities that may amount to unlicensed business operations.

Regular P2P Trading Does Not Automatically Grant Permission to Operate

The CBN also clarified that identifying someone as a regular P2P trader does not automatically authorise that person to operate a regulated digital-asset business.

Individuals whose activities fall within the scope of businesses requiring official approval must obtain the appropriate licence, stop the activity or operate as authorised agents of licensed providers, depending on the bank’s directives.

This distinction is important because the new rules focus not only on identifying frequent P2P transactions but also on ensuring that activities requiring regulatory approval are conducted through authorised channels.

The guidelines therefore place responsibility on virtual asset service providers to identify potentially commercial trading activities and take the required compliance steps.

Why the CBN Introduced the New Stablecoin Regulations

The CBN acknowledged that virtual assets and stablecoins could provide benefits to Nigeria’s financial system.

According to the bank, these digital assets have the potential to improve payment services, international money transfers, business transactions and other financial activities.

However, the apex bank also warned that their growing use could create risks for financial stability, monetary policy, consumer protection, foreign-exchange management and efforts to prevent money laundering and terrorism financing.

The new framework forms part of the CBN’s responsibility to maintain monetary and financial stability while regulating Nigeria’s payment system.

By establishing licensing, capital, operational and reporting requirements, the bank intends to strengthen supervision of companies involved in non-security virtual assets.

What the New CBN Rules Could Mean for Nigeria’s Digital-Asset Industry

The new capital requirements introduce significant financial obligations for companies seeking to operate as licensed stablecoin issuers under the CBN framework.

Naira-backed stablecoin issuers must maintain at least ₦10 billion in paid-up capital, while foreign-currency-backed stablecoin issuers face a minimum requirement of ₦15 billion.

The offshore provision also makes clear that foreign-based issuers are not automatically exempt from Nigerian incorporation, licensing and capital requirements.

For virtual asset service providers, the P2P provisions introduce additional responsibilities involving customer identification, transaction monitoring, stricter checks and regulatory reporting.

The broader framework also establishes requirements relating to management, financial strength, customer protection, security and compliance.

Ultimately, the new rules represent a wider regulatory effort by the CBN to strengthen oversight of stablecoins and other virtual-asset activities in Nigeria while addressing potential risks to the financial system.

Frequently asked questions (FAQ)

1. What new capital requirements has the CBN introduced for stablecoin issuers?

The CBN requires Class 1 stablecoin issuers to maintain at least ₦10 billion in paid-up capital, while Class 2 issuers must maintain at least ₦15 billion.

2. What is the difference between Class 1 and Class 2 stablecoins?

Class 1 stablecoins are designed to maintain their value against the naira, while Class 2 stablecoins are backed by foreign currencies, including the US dollar.

3. Are foreign-based stablecoin issuers exempt from the CBN requirements?

No. The CBN says there is no offshore issuer exemption from incorporation, licensing or capital requirements.

4. What does the CBN’s new framework cover?

It covers non-security virtual assets, including stablecoins, Deposit Money Tokens (DMTs) and Virtual Asset Service Providers (VASPs).

5. What are the new requirements for P2P cryptocurrency trading?

Virtual asset providers must identify customers who regularly conduct P2P transactions as a business, assess their transaction activities, apply stricter checks and limits where required, and report them to the CBN.

6. Does being identified as a regular P2P trader automatically grant a licence?

No. The CBN says identification does not automatically authorise someone to operate a regulated business. Activities requiring approval must be appropriately licensed or conducted under an authorised arrangement.

7. Why has the CBN introduced the new stablecoin regulations?

The bank says the framework is intended to support monetary and financial stability, strengthen supervision and address risks involving consumer protection, money laundering, terrorism financing and foreign-exchange management.