NIGERIA Law and Practice Contributed by: Omoruyi Edoigiawerie, Adebomi Adekeye and Habeeb Eyinade, EandC Legal
The March 2026 Pilot Scheme This is a strictly supervisory learning phase involving select VASPs and major payment gateways. Strategic focus Unlike a traditional sandbox geared toward “viability”, this pilot focuses on the Travel Rule (FATF Recom- mendations 15/16) and the technical interoperability between blockchain rails and traditional banking infra- structure. It is a “test-then-codify” approach intended to refine the CBN’s real-time monitoring capabilities for cross-border digital flows. The National Blockchain Policy Roadmap Underpinning these sandboxes is the National Block- chain Policy (2023/2026 updates) managed by NIT- DA. This policy serves as the jurisdictional North Star, mandating that all regulatory sandboxes prioritise: • interoperability – ensuring that “Nigereum” (the proposed national blockchain infrastructure) can communicate with private chains; and • data sovereignty – testing how on-chain data aligns with the Nigeria Data Protection Act 2023. 1.1.3 Regulation of Blockchain Technology Government Attitude: Strategic De-Risking and Economic Resilience The Nigerian government has transitioned from a stance of cautious skepticism to one of strategic integration. The prevailing attitude is no longer about stopping blockchain but about anchoring it within national security and fiscal frameworks. From prohibition to pragmatism The pivot was catalysed by Nigeria’s successful exit from the FATF Grey List in October 2025. Regulators now view blockchain as a tool for economic resilience rather than a threat to monetary stability. Encouraged or restricted use cases Encouraged The government actively promotes utility blockchain, specifically real-world asset (RWA) tokenisation, and blockchain-enabled supply chain transparency for exports. Beyond financial services, the government is exploring blockchain for sovereign data integrity. Under the National Blockchain Policy (updated 2026),
• Blockchain is now being utilised as an immutable “digital notary” to augment the Copyright Act 2022. It provides the primary evidence layer for author- ship and “first-to-file” claims in the creative and tech sectors. • Smart contract licensing: there has been an increase in self-executing licensing agreements. While Nigerian IP law remains technologically neutral, the judiciary is increasingly receptive to blockchain-based records as “electronic evidence” under the amended Evidence Act, particularly in high-stakes commercial disputes involving digital rights management. 1.1.2 Regulatory Sandbox Nigeria does not operate a single blockchain sandbox but rather a co-ordinated multi-agency testing eco- system. This framework allows for the phased integra- tion of disruptive technologies into the formal financial system under controlled parameters. The SEC’s Dual-Track Incubation Framework The Securities and Exchange Commission (SEC) has moved beyond basic testing to a structured onboard- ing funnel for digital asset operators. The Regulatory Incubation (RI) Programme This is designed for unclassified innovations. It is a classic sandbox environment for fintechs whose business models do not fit existing rules. It allows for the testing of novel blockchain applications, such as decentralised identity (DeID) and cross-border settle- ment protocols, with limited regulatory waivers. The Accelerated Regulatory Incubation Programme (ARIP) Launched as a strategic response to the ISA 2025, ARIP is a fast-track window. It was specifically designed to onboard established VASPs into the regu- latory fold. Unlike a standard sandbox, ARIP is a pre- licensing bridge where firms demonstrate compliance with high-level capital and AML requirements before being granted full operational licences. The CBN’s AML/CFT/CPF Supervision Pilot (2026) The Central Bank of Nigeria (CBN) recently pivoted from product testing to systemic risk testing.
432 CHAMBERS.COM
Powered by FlippingBook