Dollar stablecoin operators face CBN N15bn capital threshold

The Central Bank of Nigeria (CBN) has introduced a N15bn minimum capital requirement for companies issuing stablecoins backed by foreign currencies, including the United States dollar, as part of measures to tighten regulation of the country's virtual asset industry.

The new threshold is contained in the apex bank's Regulations for the Operations of Non-Security Virtual Assets in Nigeria, which establish fresh licensing, capital adequacy and operational standards for virtual asset service providers.

The regulations, released on Friday, followed a circular dated November 5, 2026, and signed by the Director of the Payments System Policy Department, Musa Jimoh.

According to the provisions, foreign currency-backed stablecoin issuers, categorised as Class 2 operators, must maintain paid-up capital of at least N15bn upon commencement of operations and throughout their existence.

Section 15.2 of the document states that a Class 2 licensed issuer “shall maintain minimum paid-up capital of fifteen billion Naira (N15,000,000,000), or such higher amount as the Bank may prescribe, on entry and at all times thereafter.”

The requirement is higher than the N10bn minimum capital prescribed for Class 1 issuers, which are companies issuing stablecoins referenced to the naira.

Other businesses providing non-security virtual asset services are required to maintain a minimum paid-up capital of N1bn.

The CBN further clarified that the N1bn capital requirement for these service providers must be independent of capital committed to licences obtained from the Securities and Exchange Commission or other regulatory bodies.

The regulator said the different capital thresholds were informed by the varying risks associated with the activities of stablecoin issuers and other virtual asset operators.

It also empowered itself to impose higher capital requirements on individual operators based on their transaction volumes, market relevance, redemption obligations, technology exposure and potential implications for the wider financial system.

The framework makes clear that regulatory capital cannot be counted as part of funds set aside for other obligations.

“Capital shall be separate from and additional to issuer reserves, the CBN reserve deposit, customer funds and assets and operational liquidity,” the document stated.

It also requires operators to hold eligible capital in cash deposited in designated CBN accounts or in approved Federal Government securities subject to the apex bank's control.

Where an operator's capital falls below the prescribed minimum, it must immediately notify the regulator and submit a plan to restore compliance within 10 business days.

The CBN may subsequently restrict the issuance of new tokens or the onboarding of additional customers until the operator meets the required capital threshold.

In addition to the capital requirements, the new regulations impose stringent conditions on the reserves backing stablecoins.

Issuers are required to maintain eligible reserve assets covering 100 per cent of their outstanding obligations, alongside an additional two per cent buffer to absorb potential losses.

The regulations also prohibit the creation of new stablecoin tokens unless equivalent reserve assets have been received and secured.

The CBN stated that no licensed issuer could mint new tokens without first ensuring that equivalent eligible reserve assets were available in its reserve pool.

Stablecoin operators are also required to allow holders to redeem their tokens at face value, with valid requests generally processed no later than the next business day. Standard redemption transactions must be free of charges.

The apex bank also outlawed algorithmic stablecoins that depend largely on changes in token supply to maintain their value without adequate reserve backing. Tokens linked to fiat currencies but backed predominantly by other cryptocurrencies are equally prohibited.

The regulatory framework provides for additional oversight of stablecoins with significant market penetration or potential systemic implications.

Under the provisions, stablecoins with circulating values exceeding N500bn for 30 consecutive days, or those used by more than five million people in Nigeria, will be designated systemically important and subjected to enhanced supervision.

The scope of the regulations extends to cryptocurrency exchanges, digital wallet providers, payment gateways, remittance operators, digital asset custodians and platforms facilitating peer-to-peer transactions.

These businesses must comply with requirements covering anti-money laundering, counter-terrorism financing, customer identification, transaction monitoring, cybersecurity, consumer protection and regulatory disclosures.

The CBN said the rules apply to both domestic and foreign operators offering regulated services to Nigerians, whether or not they maintain physical offices in the country.

However, the apex bank maintained that virtual assets classified as securities would remain under the jurisdiction of the SEC, with both regulators expected to collaborate where their supervisory responsibilities overlap.

The CBN said the framework was designed to “promote responsible innovation, strengthen the integrity of the Nigerian financial system and provide an appropriate regulatory framework for emerging digital payment instruments.”

The regulations took effect on November 5, 2026, introducing a more comprehensive licensing and supervisory regime for Nigeria's growing virtual asset and digital payment market.

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