NIGERIA Trends and Developments Contributed by: Moe Odele, Inikpi Sule, Dumebi Onyetube and Inemesit Eton, Vazi Legal
Digital assets: from regulatory uncertainty to a structured market The Investments and Securities Act 2025 marked a major shift in Nigeria’s digital asset landscape, transforming regulatory ambiguity into a rules‑based framework. Digital assets and cryptocurrencies are now formally recognised as securities, placing issuance, trading, and intermediation under the Securities and Exchange Commission (SEC). Key developments included: • Formal Regulation of VASPs – exchanges, custodi - ans, token issuers, and related intermediaries now fall squarely under SEC oversight. • Expansion of the SEC’s Accelerated Regulatory Incubation Programme (ARIP) – the ARIP now offers provisional licensing with clear expectations on governance, capital adequacy, and risk man - agement. • Approvals for Exchanges – Busha and Quidax received SEC approvals‑in‑principle, demonstrat - ing that compliant operators can achieve full authorisation. • Growing Market Adoption – stablecoin usage grew, driven by remittances and currency volatility hedg - ing among individuals and SMEs. • Corporate Restructuring – late 2025 saw crypto firms enhance governance, board independence, capital reserves, and internal controls to meet SEC standards – raising costs but setting the stage for Regulatory frameworks shifted from advisory guide - lines to active enforcement in 2025, making compli - ance a competitive differentiator and a key driver of market structure. Digital lending and credit technology The FCCPC introduced the Digital, Electronic, Online and Non‑Traditional (DEON) Consumer Lending Regu - lations 2025 in response to complaints about preda - tory practices. Key changes included: institutional investment. Credit and compliance
Mono enhanced its payments infrastructure, while Paystack acquired Ladder Microfinance Bank to expand into regulated banking. • Mid‑Tier Consolidation – fintechs with prod - uct‑market fit but limited capital will either merge with stronger players or exit entirely. • Cross‑Border Expansion – Nigerian fintechs will increasingly acquire companies across Africa and beyond to accelerate international growth. Global expansion of Nigerian tech companies Despite global funding constraints, Nigerian-found - ed fintechs remained the continent’s most active cross‑border expanders in 2025. Nigerian compa - nies accounted for a substantial portion of Africa’s 54 documented start-up expansions, reinforcing Nige - ria’s position as the most outward‑facing fintech eco - system on the continent. Fintech led all sectors in funding (USD1.37 billion), infrastructure readiness, and regulatory engagement. Key drivers of internationalisation included payments, remittances, SME banking, and mobility finance – often targeting markets with similarities to Nigeria, such as large diasporas, underserved banking sys - tems, and sizeable informal populations. Examples include: • LemFi expanded into Europe by acquiring the Irish exchange platform Buttercrane, and strengthened its UK presence through earlier acquisitions of RightCard and Pillar. • Moove entered Latin America through its acquisi - tion of Brazilian mobility startup Kovi. • Flutterwave, Paystack, Moniepoint, OPay, and Interswitch continued scaling across Africa, Europe, and North America. • Kuda Bank broadened product offerings and planned expansion into Tanzania and Canada, transitioning from a Nigeria‑focused challenger bank into a multi‑market financial platform. Collectively, these moves reflect Nigerian fintechs’ increasing use of regulatory arbitrage, licensing port - ability, and infrastructure partnerships as tools for building global reach.
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