The Central Bank of Nigeria (CBN) has introduced a minimum capital requirement of N15 billion for foreign currency-referenced stablecoin issuers seeking to operate in Nigeria, raising the financial and regulatory threshold for businesses issuing digital currencies backed by foreign currencies.
Under its new Regulations for the Operations of Non-Security Virtual Assets in Nigeria, the apex bank requires issuers of foreign currency-referenced stablecoins, classified as Class 2, to maintain minimum paid-up capital of N15 billion upon entry and throughout their operations.
The requirement is higher than the N10 billion minimum capital prescribed for issuers of naira-referenced stablecoins, known as Class 1, while providers of other non-security virtual asset services are required to maintain at least N1 billion in paid-up capital.
The regulations, however, make clear that the capital requirement is not limited to foreign companies seeking to establish a physical presence in Nigeria. Foreign currency-referenced stablecoins offered, marketed, distributed, exchanged, held in custody or redeemed in Nigeria must be issued through a Nigerian-incorporated entity holding a Class 2 licence from the CBN.
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This means that obtaining a licence or regulatory approval in another country, or operating through a Nigerian intermediary, will not exempt a foreign stablecoin issuer from meeting the country’s licensing and capital requirements.
The CBN said there would be no offshore issuer exemption from incorporation, licensing or capital requirements, effectively bringing foreign currency stablecoin issuers targeting Nigerian customers within its domestic regulatory framework.
The new capital threshold is part of the CBN’s broader effort to strengthen oversight of digital assets that increasingly facilitate payments, transfers and the movement of foreign currency value across borders.
Stablecoins are digital assets designed to maintain a relatively stable value by referencing currencies such as the United States dollar or the naira. Their use in cross-border payments, remittances and international transactions has made them an increasingly important part of the digital financial ecosystem.
By imposing higher capital requirements on foreign currency stablecoin issuers, the CBN is seeking to ensure that operators have sufficient financial resources to support their activities and meet their obligations to customers.
The regulations also require prospective issuers to demonstrate their ability to satisfy capital, operational liquidity, reserve management, redemption, technology, payment security and customer protection requirements before receiving final approval.
Under the licensing framework, promoters of proposed stablecoin issuers may apply for approval-in-principle before incorporation. However, the CBN will not grant a final issuer licence until the applicant has been incorporated in Nigeria under the Companies and Allied Matters Act, 2020, and has fulfilled the prescribed requirements.
Applicants must also maintain, or submit arrangements to establish before final licensing, a principal place of business and a staffed physical office in Nigeria from which key management functions will be exercised.
The apex bank further requires issuers to demonstrate the source of their funds and provide evidence of capital deposits and the corresponding transfer through the real-time gross settlement system. The full applicable capital requirement and deposit must be satisfied and evidenced before final licensing.
Beyond the minimum capital requirement, licensed issuers must maintain additional operational liquidity from their own funds, separately from the reserve pool backing their stablecoins.
This liquidity must be sufficient to cover the higher of six months of projected operating expenses or the cost of an orderly wind-down under an approved wind-down plan. The CBN also clarified that the required capital deposit cannot be treated as freely available operating or redemption liquidity.
The distinction is important because the capital requirement is intended to provide a financial buffer for the issuer, while reserve assets must remain available to support the stablecoins in circulation and meet redemption obligations.
The regulations also provide for supervisory intervention where an issuer falls below its prescribed capital requirement. Such an entity must immediately notify the CBN and submit a capital restoration plan within 10 business days.
The apex bank may restrict new issuance, customer onboarding or other activities until the capital shortfall is addressed, and may take further supervisory action.
For other non-security virtual asset service providers, the CBN prescribed a minimum paid-up capital of N1 billion. Where a provider already holds a licence from the Securities and Exchange Commission (SEC), the CBN requirement will be additional to the capital prescribed by the SEC for the relevant service.
The same capital cannot be counted towards both regulatory requirements, meaning affected operators must separately satisfy the applicable capital obligations under each licensing framework.
The regulations also empower the CBN to prescribe higher capital or additional liquidity requirements, depending on the nature, scale and risks of an issuer’s activities.
For stablecoin issuers designated as systemic because of their size or importance to the Nigerian market, the apex bank may impose enhanced supervisory requirements, including continuous real-time reserve reporting, stress testing at least twice a year and approved recovery and resolution plans.
The CBN’s framework therefore raises the financial and operational requirements for stablecoin businesses seeking to serve Nigerian customers, while establishing a clearer distinction between naira-backed and foreign currency-backed digital assets.
Hope Moses-Ashike is an Associate Editor, Banking and Finance, with more than a decade of experience reporting on Nigeria’s financial system and broader economy. She closely tracks market movements, monetary policy decisions, company disclosures, regulatory actions, economic indicators, and global developments, and interprets what they mean for businesses, investors, policymakers, and households. Her reporting helps readers understand complex issues such as inflation trends, foreign exchange market dynamics, interest rate decisions, bank performance, and investment risks. She also covers major international events and periodically travels to Washington, D.C., to report on the World Bank/IMF Spring and Annual Meetings. Her dedication to financial journalism has earned her multiple recognitions and invitations to high-level professional development programmes. She is an alumna of the International Visitors Leadership Programme (IVLP) in the United States and holds an Advanced Financial Journalism Certificate from the Press Association Training in London, UK. Her other notable achievements include completing the Lagos Business School CMC Programme, the Bloomberg Media Africa Initiative Programme, and a Master Class in Journalism at Rhodes University in South Africa.
