The year 2025 represented a period of regulatory consolidation for digital assets in Nigeria, rather than a comprehensive restructuring of the legal framework. Regulatory developments during the year were characterised by incremental statutory adjustments, selective enforcement actions, and continued reliance on existing financial and capital markets laws to accommodate digital and virtual assets. Rather than establishing a stand-alone digital asset regime, regulators focused on adapting established legal instruments to address emerging risks and market activity.
Digital Assets Under the Investment and Securities Act 2025
A defining development was the coming into force of the Investment and Securities Act (ISA) 2025, which extends the scope of securities regulation to cover digital and virtual assets and grants oversight to the Securities and Exchange Commission. The Act adopts an inclusionary approach by specifically classifying all digital assets as securities, therefore extending the reach of traditional securities law to the digital assets.
This approach provides legal recognition but does not amount to full legalisation of digital assets as a distinct asset class. Questions around classification, regulatory perimeter boundaries, and the treatment of non-investment digital asset activities remained unresolved.
Virtual Asset Service Providers and Transitional Oversight
Nigeria’s SEC continued to rely on the Accelerated Regulatory Incubation Programme (ARIP) as a transitional onboarding framework for digital investment platforms and virtual asset service providers. The programme prescribes the requirements, documentation, governance standards, and compliance obligations for onboarding these entities into Nigeria’s regulated market. While ARIP enabled limited regulatory engagement, it did not constitute an automatic full licensing regime.
The addendum guidelines to the ARIP rules came into force in June, 2025 intending to refine market intermediaries in the ecosystem. It establishes different categories for VASPs including: Digital Asset Custodians, Digital Asset Offering Platforms, Digital Asset Intermediaries, Digital Asset Exchanges, and provides guidelines on financial requirements, advertising and promotional control, etc.
Enforcement and Reactive Regulation
Regulatory enforcement during the year was shaped by high-profile market failures, most notably the CBEX collapse. The Securities and Exchange Commission’s subsequent actions, including public warnings, illegal operator alerts, and asset-freeze proceedings, underscored the reactive nature of enforcement.
These events highlighted persistent weaknesses in early detection, inter-agency coordination, and technical capacity to trace and restrain digital asset flows across blockchains and jurisdictions.
Stablecoins and Functional Adoption
Stablecoin activity continued to expand in Nigeria during 2025, largely outside formal payment and commercial infrastructure. Available indicators suggest that usage remains concentrated in peer-to-peer transfers, remittances, and informal settlements rather than regulated merchant payments or trade finance.
A notable development during the year was the launch of CNGN, described as Nigeria’s first regulated stablecoin. CNGN was introduced within a supervised framework and positioned as a naira-referenced digital settlement instrument. Its creation marked an attempt to bring stablecoin activity within a regulated perimeter and align it with domestic financial oversight.
However, the emergence of CNGN did not immediately alter the broader functional pattern of stablecoin use in Nigeria. Adoption remained limited when compared with foreign-currency-denominated stablecoins used in peer-to-peer and cross-border contexts. Concerns were also raised around liquidity depth, interoperability with existing digital asset platforms, and the extent to which a domestically referenced stablecoin could address demand driven by foreign exchange constraints.
In addition, questions persisted regarding market confidence, reserve transparency, and the practical use cases available to users beyond controlled pilot or institutional environments. As a result, while CNGN represents a regulatory milestone, it has yet to translate into widespread commercial or payment-system integration.
Overall, stablecoins in Nigeria continued to function primarily as informal value-transfer tools rather than regulated payment instruments, with the gap between regulatory intent and market adoption remaining evident.
Inter-Agency Coordination and Regulatory Fragmentation
Digital asset oversight in 2025 remained fragmented across multiple institutions, including the Securities and Exchange Commission, the Central Bank of Nigeria, tax authorities, and enforcement agencies. While each exercised elements of jurisdiction, coordination challenges persisted, particularly in relation to supervision, enforcement timing, and data sharing.
During the year, the SEC launched the Regulatory Hub, a coordination platform intended to improve information-sharing and supervisory alignment among financial and capital market regulators. The initiative represents a formal attempt to address longstanding silos within Nigeria’s regulatory architecture and to enhance inter-agency collaboration.
However, the practical impact of the Regulatory Hub on digital asset oversight remains in an early stage. There is limited available evidence that the platform has yet been translated into real-time early-warning systems, integrated transaction monitoring, or coordinated enforcement actions across agencies. As a result, regulatory fragmentation continued to affect oversight outcomes in cases involving cross-border platforms, peer-to-peer activity, and mixed financial services.
Digital Asset Taxation and Fiscal Enforcement
Digital asset taxation emerged more clearly in 2025, although it remained conceptually and operationally unsettled. The Nigeria Tax Administration Act (NTAA) has provided a basis for digital asset taxation, Its Fifth Schedule outlines taxable digital asset activities and establishes reporting, compliance for Virtual Asset Service Providers (VASPs), and filing obligations for taxpayers. Tax authorities focused on identifying taxable events linked to gains from digital asset transactions, including disposals, trading activity, and income derived from digital asset-related services.
While the NTAA outlines the basis for digital asset taxation, operational details such as valuation mechanics, cross-border reporting, treatment of losses across tax years, and compliance expectations for non-resident exchanges remain subject to further clarification.
Ongoing Legislative Oversight Efforts
The National Assembly constituted an Ad Hoc Committee on Cryptocurrency and Point-of-Sale (POS) to examine emerging risks associated with digital asset transactions and gaps in institutional coordination. The committee’s work reflects ongoing legislative interest in consumer protection and market integrity, and is expected to usher in future amendments to existing digital asset frameworks
Comparative Regional Developments
Nigeria’s regulatory posture in 2025 contrasted with developments in Ghana, which advanced toward a stand-alone virtual asset framework supported by coordinated institutional oversight and public education initiatives. Nigeria, by contrast, continued to adapt existing capital markets and tax laws to digital assets.
Conclusion
Nigeria’s digital asset regulatory landscape in 2025 reflected legal recognition without comprehensive structural reform. Progress was made in statutory coverage, enforcement visibility, and fiscal attention, but significant gaps remained in licensing, classification, taxation clarity, inter-agency coordination, and technical capacity.
The regulatory direction remained cautious and incremental, leaving open the question of whether Nigeria will move toward a dedicated digital asset framework or continue extending existing financial and tax laws to accommodate the sector.