Nigeria: Financial Services

On 16th January 2026, the Securities and Exchange Commission (the “SEC”) released Circular Number 26-1 on the revision of Minimum Capital (MC) applicable to all categories of regulated capital market entities and this Circular seeks to strengthen market resilience, enhance investor protection, align capital adequacy with the evolving risk profile of market activities, and ensure that regulated entities possess sufficient financial capacity to discharge their obligations in a sustainable manner.

Nigeria's open banking framework promises to transform digital lending through secure, consent-driven financial data sharing. As the phased rollout approaches mid-2026, lenders face both opportunity and obligation: faster credit decisions, better risk assessment, and new product possibilities, alongside stricter compliance requirements and infrastructure dependencies that will reshape competitive dynamics across the sector.

Nigeria cedes $4-5 billion annually in marine liability insurance premiums to foreign institutions, creating a legally mandated market opportunity with no domestic competitor. Development finance institutions and blended capital structures could establish the country's first Protection and Indemnity club, capturing a revenue stream that currently flows entirely offshore while building critical local capacity in underwriting, claims management, and maritime risk assessment.

Nigeria's capital market is undergoing a fundamental transformation driven by the Investments and Securities Act 2025 and the Nigerian Capital Market Strategy 2026.

Digital lending in Nigeria has revolutionized access to finance through mobile platforms offering instant unsecured loans, but this rapid growth has sparked intense debate over pricing practices and consumer protection. As regulators scrutinize high interest rates, hidden fees, and complex terms, lenders defend their models as necessary responses to elevated credit risk and operational costs. The central question remains: how can Nigeria balance innovation-driven financial inclusion with meaningful safeguar

On 16 May 2026, the Central Bank of Nigeria launched the 2026 FX Manual, marking the first comprehensive review of Nigeria's foreign exchange regulatory framework in nearly a decade.

Nigeria's Securities and Exchange Commission has introduced new capital adequacy rules for fund managers and private capital participants, establishing tiered minimum capital requirements based on assets under management. The guidelines clarify what constitutes qualifying capital, outline compliance pathways including cash injection and securities transfer, and set a June 2027 deadline for full implementation.

The Central Bank of Nigeria has issued an Exposure Draft of Revised Guidelines for Financial Holding Companies, marking the first comprehensive review since 2014. This regulatory update introduces significant changes to governance requirements, capital adequacy standards, ownership structures, and consolidated supervision frameworks.

As financial technology reshapes how consumers and businesses manage money, a century-old banking duty is gaining new relevance. The Quincecare duty requires financial institutions to pause suspicious payment instructions—but how does this obligation apply when traditional banks serve merely as infrastructure beneath fintech platforms? This analysis explores the duty's evolution from English case law through its modern application in layered payment systems.