Nigeria sets ₦15 billion capital floor for foreign stablecoin issuers

The rules divide stablecoins into two licensing classes: foreign-currency tokens are Class 2, and naira-backed tokens are Class 1. Class 1 issuers must hold at least ₦10 billion in paid-up capital; the CBN can require more based on a company’s activities and risk profile. Other regulated virtual asset service providers face a ₦1 billion minimum. That requirement applies separately to capital required by the Securities and Exchange Commission for firms it licenses.

Foreign-currency issuers must establish a Nigerian-incorporated entity and obtain a Foreign Currency Issuer Licence. A licence from another jurisdiction or an arrangement with a local intermediary is not enough. Issuers also need separate written CBN approval for each token, identifying its reference currency, reserves, name, ticker and supported blockchain networks. The rules cover businesses operating in Nigeria, overseas firms targeting Nigerian customers and services that could affect the payments system or foreign exchange market.

The CBN bars algorithmic stablecoins that rely mainly on supply or demand adjustments rather than adequate reserves. The prohibition also covers tokens tied to fiat currencies but backed mainly by cryptocurrencies, tokens without an enforceable right to redemption at face value, and tokens issued by sanctioned entities or from sanctioned jurisdictions.

Approved issuers must keep eligible assets equal to the full value of outstanding tokens, with continuous one-to-one backing, and hold an additional reserve buffer of at least 2%. They cannot issue tokens before receiving the corresponding reserves and must check reserves against liabilities daily. The rules also require identity checks, sanctions screening, transaction monitoring and compliance with anti-money laundering and counter-terrorist financing requirements, including applicable Travel Rule obligations.

Existing regulated operators have 180 calendar days from commencement to apply for authorization. They must register with the CBN within 30 days and begin supervisory reporting within 60 days, unless told to report sooner. Anti-money laundering rules apply immediately, and firms cannot expand beyond their current scale during the transition without approval. Those that miss the application deadline must stop regulated activities until authorized. Unauthorized activity can draw a minimum ₦100 million fine, plus at least ₦1 million for each day the breach continues. Companies whose activities fall under both the CBN and SEC must obtain approval from each regulator.