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Nigeria's digital-money regime is bifurcated. E-money/payment digital balances sit under the CBN (MMO/PSB framework and the eNaira CBDC), while crypto and stablecoins fall to the SEC under the Investments and Securities Act (ISA) 2025, enacted 31 March 2025, which classifies virtual/digital assets as securities and makes the SEC the apex regulator for VASPs. Stablecoins are treated as securities where they represent investment interests, with issuer licensing, reserve backing and AML/KYC obligations; the SEC's Accelerated Regulatory Incubation Program (ARIP) is the sandbox/onboarding route. This reverses the CBN's 2021 banking ban, lifted via the December 2023 VASP account guidelines.
On the payment-use side, on 22 December 2023 the CBN issued VASP Account Guidelines permitting banks to operate accounts for and service SEC-licensed crypto firms under strict compliance conditions, reversing the February 2021 ban on crypto transactions by financial institutions. Bank account access for SEC-licensed VASPs is the operational precondition for compliant crypto and stablecoin payment flows, and the December 2023 reversal re-opened banking rails closed since 2021. The combined picture is a CBN/SEC division of labour: the CBN governs payment-use e-money and CBDC; the SEC governs security-use stablecoins and virtual assets.
A note on dates: research records the ISA 2025 enactment as 31 March 2025, but multiple sources confirm the signing date as 25 March 2025. The substantive security-classification position is unaffected by this discrepancy. No standalone fiat-backed national stablecoin instrument is yet in force; stablecoins are regulated by function.
Outlook
The stablecoin framework is escalating. Formal stablecoin definitions remain emerging, and the regulated-stablecoin cross-border settlement corridors contemplated under Vision 2028 (see W9) are the principal forward vector.
no periodic updates on record for this sub-brief
Sources and findings (5)
- T1Investments and Securities Act 2025 (signed 29 Mar 2025); SEC Nigeria as digital-asset regulator (sec.gov.ng)
- T1SEC Nigeria — Amended Digital Assets Rules (publ. 16 Dec 2024, eff. 30 Jun 2025) (sec.gov.ng)
- T1SEC Nigeria — ARIP Framework for onboarding VASPs (12-month AIP) (sec.gov.ng)
- T3https://practiceguides.chambers.com/practice-guides/fintech-2026/nigeria/trends-and-developments [CAVEAT: Tier 3 secondary source — Assessed; verify vs primary pre-publication]
- T1https://www.cbn.gov.ng/AboutCBN/Reforms.htmlretrieved