NIGERIA Law and Practice Contributed by: Omoruyi Edoigiawerie, Adebomi Adekeye and Habeeb Eyinade, EandC Legal
EandC Legal 78A, Isale Eko Avenue Dolphin Estate, Ikoyi Lagos State Nigeria Tel: +234 9016606374 Email: hello@uyilaw.com Web: www.eandclegal.africa
1. Overview of Blockchain and Crypto- Assets 1.1 Blockchain 1.1.1 Evolution of Uses of Blockchain The Past 12 Months Over the past 12 months, the Nigerian blockchain ecosystem has pivoted from a retail-centric crypto- hub to a foundational layer for institutional finance. Following the landmark Investments and Securities Act (ISA) 2025, digital assets have been formally reclas- sified as securities. This has ended years of regula- tory ambiguity, enabling Tier 1 banks to engage with SEC-licensed virtual asset service providers (VASPs) for the first time. While stablecoins remain a primary hedge against nai- ra volatility, the use case has matured from P2P retail trades to corporate treasury management. Large- scale SMEs now utilise digital liquidity pools for real- time cross-border settlements, bypassing traditional correspondent banking delays. The market has moved beyond currency into real- world asset tokenisation. High-level integration has been seen in the agricultural sector, where tokenised warehouse receipts are being used as digital collateral in formal credit markets, bridging the gap between decentralised finance and traditional commercial banking. The Next 12 Months The next 12 months will be defined by capital-driven consolidation and supervisory rigour.
Capitalisation as a filter The recent shift in Nigeria’s blockchain landscape is underpinned by the SEC’s 2026 Recapitalization Directive (Circular No 26-1). This regulatory interven- tion significantly raised the barrier to entry, signalling a move towards a high-fidelity, institutional-grade market. Under the new framework, digital assets exchanges (DAX) and digital assets custodians saw their minimum capital requirements quadrupled, increasing from NGN500 million to NGN2 billion. The SEC’s NGN2 billion minimum capital requirement is functioning as a deliberate market filter. The authors expect significant M&A activity as smaller start-ups merge or exit, leaving a landscape dominated by a few highly capitalised, institutional-grade operators. The supervisory shift The CBN’s 2026 Pilot Supervision Program signifies a move towards regtech integration. Regulators now expect Travel Rule compliance and real-time AML/ CFT monitoring, placing a premium on firms that can navigate these complex, infrastructure-heavy compli- ance mandates. Fiscal integration With the Nigerian Tax Administration Act (NTAA) 2025 now operational, blockchain businesses are integrat- ing with the Nigeria Revenue Service (NRS). This shift marks the final step in the legitimatisation of the asset class within the national fiscal framework. The interaction between blockchain and intellectual property (IP) has moved from theoretical to functional integration.
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