Nigeria

The most consequential development for this module is institutional rather than substantive: a July 2026 Presidential Executive Order established a CBN-chaired Virtual Asset Council, with SEC Nigeria and the Nigeria Revenue Service as vice-chairs and the Nigerian Financial Intelligence Unit and the Office of the National Security Adviser as members, tasked with harmonising regulation of Nigeria's virtual-assets ecosystem (CLM-NG-d84f1c6a). This is the first primary-source signal that Abuja intends to coordinate, rather than merely tolerate, the coexistence of SEC's securities-law licensing track and CBN's banking-access track. The Council's creation does not itself alter either underlying instrument, and its operating procedures, decision rights, and interaction with existing SEC registration and CBN account-designation processes are not yet defined in any primary source reviewed this cycle.

Outlook

The module's traffic-light status remains amber: core registration obligations are in force and enforced through the ARIP incubation mechanism, but the governing rulebook is mid-amendment, the great majority of licensed entities hold only provisional status, and the new coordination council has not yet been operationalised in public rulemaking. Three confirmations would materially change this picture: whether the Investments and Securities Act, 2025 has commenced and on what date; whether SEC's exposure-draft Rules have been finalised, and if so whether they supersede or supplement the 2022 Rules; and how the Virtual Asset Council's mandate interacts with SEC's and CBN's existing statutory powers. Until these are resolved, market participants face a licensing environment where the applicable rulebook, its date of full effect, and its coordinating institutional structure are all simultaneously in motion.

Beyond this default presumption, classification treatment for specific asset types remains substantially unsettled. No primary Nigerian source confirms a settled classification treatment for utility tokens or NFTs distinct from the general rebuttable presumption that crypto assets are securities (CLM-NG-010) -- a sourced negative finding rather than an assumption of silence. Stablecoins occupy a similarly unsettled position: SEC's exposure-draft Rules introduce a 'Recognised Foreign-issued Stablecoin' classification, to be assessed via the issuer's regulatory status, its reserve arrangement, redemption framework, custody arrangement and other risk factors (CLM-NG-009), but this remains draft, non-normative language rather than a commenced rule. A Challenger-review annotation on this module notes that the module's primary-framework citation should also reference the Investments and Securities Act 2025's statutory recognition of digital and virtual assets as securities; this annotation has been carried into the module's rationale without mutating any underlying claim, pending fuller confirmation of the Act's scope and commencement.

Outlook

The module's amber rating reflects a clear default rule for the general case -- token-as-security absent proof otherwise -- against genuine gaps for utility tokens, NFTs and stablecoins, all of which remain either unaddressed or confined to draft language. The two live questions are whether the Investments and Securities Act, 2025 supplies any express statutory definition of 'digital asset' or 'virtual asset' distinct from the 2007 Act, and whether SEC's exposure-draft foreign-stablecoin recognition criteria are finalised and brought into force. Neither has been confirmed from a primary source this cycle.

The only forward-looking signal in this module comes from SEC's still-draft exposure Rules on Digital and Virtual Assets Operations, Custody and Markets. That draft extends applicability to tokenisation, lifecycle management, and hybrid digital-asset arrangements constituting investments or securities business, whether operated in Nigeria or targeting Nigerian investors (CLM-NG-011), and separately empowers the Commission to impose additional controls -- limits, escrow, custody, dispute-resolution and reporting requirements -- on AMM/liquidity-pool and other off-order-book settlement models, which signals an anticipated but not-yet-realised extension of SEC oversight into DeFi/DEX-adjacent activity (CLM-NG-012). Both provisions remain non-normative pending confirmation that the draft has been finalised and commenced.

Outlook

This module's red rating reflects a genuine absence of in-force, activity-specific rules across the full range of on-chain activities reviewed -- staking, mining, node/validator operation, and DeFi/DEX settlement models -- rather than a gap in research coverage; each finding traces to a direct review of the relevant primary rulebook. The determinative development to watch is whether SEC's exposure-draft Rules, which alone touch tokenisation and AMM/liquidity-pool settlement, are finalised and brought into force, and whether that finalisation extends coverage to staking, mining or validator activity that the current draft does not yet address.

Outlook

The module's red rating is consistent with the underlying evidence: every stablecoin-specific provision identified is either a domestic-framework absence or draft, non-normative language pending SEC finalisation. The key confirmatory question is whether SEC's exposure-draft Rules are finalised and, if so, whether the foreign-issued-stablecoin recognition criteria -- including the anticipated redemption-right requirement -- are brought into force as drafted or materially revised. A secondary question, not yet addressed by any primary source reviewed, is whether CBN intends to establish any domestic reserve or issuance framework for a Naira-referenced stablecoin distinct from its existing VASP banking-access guidelines.

Outlook

The module's amber rating reflects multiple partial, in-force consumer-protection measures spread across two regulators, without a single consolidated crypto consumer-protection rulebook tying them together. The most consequential open item is the reported January 2026 SEC capital circular, which -- if confirmed -- would raise minimum-capital requirements for exchanges, custodians and offering platforms; this has been held for regulator or primary-source confirmation this cycle rather than folded into the baseline, given its exclusively Tier-4 sourcing. A secondary item to track is whether SEC's exposure-draft non-custodial-wallet disclosure requirement is finalised and brought into force.

Outlook

The module's red rating reflects the absence of any confirmed, in-force, crypto-specific tax charging provision from a primary source, even as the responsible authority's name and statutory basis have themselves changed. The single highest-priority confirmatory task is to locate and review the Nigeria Tax Act / Nigeria Tax Administration Act 2025 and any NRS guidance on virtual-asset taxation directly, since Tier-4 reporting alone is insufficient under the module's insert-authority gate to displace the current 'legislative intent only' framing. Until that confirmation occurs, taxpayers and platforms operating in Nigeria face genuine uncertainty as to whether a crypto-specific charging regime is now in force.

Outlook

The module's amber rating reflects a genuinely binding, in-force settlement-currency restriction on the regulated banking channel, set against the absence of any crypto-specific cross-border reporting or travel-rule instrument outside the general AML/CFT regime. The principal item to track is whether SEC's or CBN's evolving rulemaking -- including the exposure-draft Rules and the newly established Virtual Asset Council -- introduces any crypto-specific cross-border reporting threshold distinct from the existing Naira-only banking-channel restriction and the general AML/CFT framework owned by Financial Integrity Monitor's subscribed module.