CBN sets N15bn capital for foreign stablecoin issuers

The Central Bank of Nigeria (CBN) has published Regulations for the Operations of Non-Security Virtual Assets that put payment tokens on two balance sheets. The text is dated November 2026, and the Bank's circular list carries it as PSP/DIR/PUB/CIR/001/004 of November 5, 2026. Paid-up capital is ₦15 billion for a foreign-currency stablecoin issuer and ₦10 billion for a naira-referenced issuer. Offering, marketing, exchange, custody or redemption of a foreign-currency stablecoin for people in Nigeria runs through a Nigerian-incorporated Class 2 licensee, and through that route alone.

The Payments System Policy Department left securities with the Securities and Exchange Commission (SEC) and took issuance, custody, redemption and settlement of Non-Security Virtual Assets for the Bank. A central bank digital currency the Bank issues sits outside the guidelines. The introduction says these instruments present "significant opportunities for innovation in payments, remittances, settlement, and digital commerce," paired with foreign-exchange and stability risks.

Two issuer licences, one domestic gate

Class 1 is a naira stablecoin, referenced one-to-one and issued in Nigeria against naira reserve assets. Class 2 references a foreign currency, including for cross-border payments and remittances. Section 15.3 puts incorporation, licensing and capital on an offshore sponsor as well as on a local firm. A foreign parent may own the Nigerian Class 2 issuer, the Nigerian company keeps the compliance duty, and a foreign licence supplements the CBN requirements. Eligible capital is cash at the Bank or lien-backed Federal Government securities. Custody, wallets and other non-issuance services carry a separate ₦1 billion paid-up capital floor, on top of any capital the SEC already requires.

Related:Uranium Digital sells ownership records of physical metal

Full reserves and a 2% buffer

Every licensed issuer keeps reserves at least equal to the par value of stablecoins outstanding. Section 24.4 adds overcollateralisation of at least 2% of par, held inside the segregated pool and released after the Bank approves. A Class 1 issuer places at least 20% of the pool in non-interest-bearing cash at the Bank, keeps a further 40% in cash or high-quality liquid assets, and uses at least three deposit money banks, with any one bank capped at 30% of the pool. A Class 2 issuer meets the same par-plus-2% test in the reference currency, with operational liquidity held apart from capital and reserves. Holders redeem at par by the end of the next business day. Section 13.3 prohibits interest or yield for holding the coin, and Section 2.2 bans algorithmic stablecoins.

Deposit tokens stay on the bank book

A deposit money token is a direct claim on a licensed deposit money bank, matched to an existing naira deposit, and the bank needs prior written approval to issue it. Deposit insurance follows the law and Nigeria Deposit Insurance Corporation (NDIC) arrangements, while Class 1 and Class 2 stablecoins are barred from being presented as bank deposits or as NDIC-insured. Interbank transfers settle in central bank money on the real-time gross settlement system, at par. Japan's tokenised-deposit test put a stablecoin on the interbank leg, and US banks drawing up tokenised deposits want a bank liability beside a payment stablecoin. Abuja has fixed that split in the licence map. The same domestic-vehicle problem shows up in the bind for foreign issuers under the GENIUS Act, and here the vehicle is a Class 2 issuer funded with ₦15 billion of paid-up capital.

Existing operators and the FX clock

A cross-border token payment is treated as a foreign-exchange transaction, so a Class 2 import needs a valid Form M and export proceeds count as repatriated once redeemed or converted and credited to the exporter's domiciliary account. A balance left on-chain falls short of that test. A Bank for International Settlements result on stablecoin flows and capital controls describes the same split, a new rail carrying a foreign-exchange payment. Peer-to-peer platforms need express approval inside an existing services licence, rather than a category of their own.

An existing operator registers within 30 days of commencement, starts supervisory reporting within 60 days and files its application within 180 days. During that window the firm continues at its existing scale under interim conditions, and a missed filing means the activity ceases until a licence is obtained. Circulation above ₦500 billion on each of 30 consecutive days, or use by more than five million people in Nigeria, designates a stablecoin as systemic and leaves the capital floor in place. A sponsor already serving Nigerian users has to fund a domestic Class 2 issuer, with full reserves plus the 2% buffer, while a bank that wants tokenised naira uses the deposit-token route.

This article is informational analysis only and is not financial, investment, or trading advice. Cryptocurrencies are highly volatile and can lose substantial value rapidly. Past performance and historical patterns do not guarantee future results. Do your own research and consult a regulated financial adviser before making any investment decision.