Investing in Nigeria 2026: A Strategic Legal Roadmap for Foreign Businesses

Banking and Finance Law, Business Advisory, Business, Entrepreneurs, Business, Small Business, Capital Markets, Corporate & Commercial, Financial Services, Financial Technology (FinTech), Investment LawBy Shola Adekunle September 4, 2026

As of 2026, Nigeria’s regulatory landscape has undergone its most significant transformation in over two decades. With the enactment of the Nigeria Tax Act (“NTA”) 2025 and the Nigeria Tax Administration Act (“NTAA”) 2025 which took effect on 1 January 2026, companies can no longer easily exploit legal loopholes. For foreign investors, the message is clear: success in the Nigerian market now requires compliance-by-design rather than addressed only when regulatory issues arise. The new architecture, anchored by the NTA, NTAA and the Investments and Securities Act (“ISA”) 2025, moves Nigeria toward a unified and digitally integrated regulatory strategy. This article highlights six important legal considerations every foreign business should understand before establishing or expanding operations in Nigeria in 2026.

What The Virtual Assets Coordination Order Means For Digital Assets Operators

The coming into force of the Investments and Securities Act 2025, which repealed the Investments and Securities Act 2007, marked significant changes to the regulatory framework applicable to virtual and digital assets in Nigeria. Virtual and digital assets are now recognized as securities, and the businesses involved in activities relating to such assets falls within the regulatory purview of the Securities and Exchange Commission (SEC). The implications of this reclassification for issuers, exchanges and the wider public have been discussed in previous articles. It has, however, become clear that this is only one aspect of the evolving regulatory framework applicable to digital-asset businesses in Nigeria. Three separate regulatory tracks, an executive coordination order, an increase in the capital requirements prescribed by the SEC, and a bill currently before the Senate have, over the past eighteen months, further shaped the regulatory framework applicable to digital asset businesses in Nigeria.

After The Extension: A Data Protection Playbook For Banks & Fintechs

Banking and Finance Law, Business Advisory, Business, Entrepreneurs, Business, Small Business, Corporate & Commercial, Financial Services, Financial Technology (FinTech)By Shola Adekunle August 17, 2026

The extended deadline for the 2025 Compliance Audit Return has passed. For banks and FinTechs, the question is no longer simply whether a return was filed, but whether the data protection programme behind that filing can withstand regulatory scrutiny. Data protection compliance in Nigeria has moved beyond simply having a privacy policy or obtaining consent from customers. The Nigeria Data Protection Act 2023 (NDPA) established the Nigeria Data Protection Commission (NDPC) and created a comprehensive statutory framework for the protection of personal data. The General Application and Implementation Directive 2025 (“GAID” or “Directive”), which took effect on 19 September 2025, turned this Act into the documented, auditable programme that now governs every Data Controller and Processor of Major Importance in the country. For banks and FinTechs, data protection compliance is therefore not simply another legal or IT issue. It is a governance, operational and reputational issue that should be receiving attention across all leadership cadres.

What the Investment & Securities Act 2025 Will Mean for Your Business

Banking and Finance Law, Business Advisory, Business, Entrepreneurs, Capital Markets, Corporate & Commercial, Investment LawBy Colin Egemonye July 15, 2026

The Investment and Securities Act 2025 (ISA 2025), signed into law by President Bola Ahmed Tinubu in March 2025 is the most comprehensive reform of Nigeria’s capital market legislation in nearly two decades. It repealed the Investment and Securities Act 2007 and provides for a new restructured framework to accommodate new asset classes and to significantly expand the enforcement powers of the Securities and Exchange Commission (SEC) so as to align Nigeria’s capital markets with world standards. This article highlights six changes that are important to public companies, issuers, capital market operators including virtual/digital assets businesses in Nigeria.

What the CBN’s Financial Holding Company Rules Mean for Banking Groups Banking and Finance Practice

Banking and Finance Law, Business Advisory, Capital Markets, Corporate & Commercial, Corporate Restructuring and Insolvency, Financial Technology (FinTech)By Colin Egemonye July 6, 2026

On 10 June 2026, the CBN published an Exposure Draft of Revised Guidelines for the Licensing and Regulation of Financial Holding Companies in Nigeria. The Exposure Draft’s public consultation window ends on 9 July 2026. Among the most significant changes to the holding company framework in the draft is the move from three-pillar structures to four-pillar structures. If approved, the proposed framework would be the most significant revamp of the holding company framework since the guidelines were issued for Nigerian banking groups during restructuring away from universal banking into holding companies structures in 2014.

Nigerian Open Banking: The Legal Framework All Banks and FinTechs Need to Know

Banking and Finance Law, Business Advisory, Corporate & Commercial, Financial Technology (FinTech), Innovation and Technology, Startups and MSME LawBy Colin Egemonye June 10, 2026

The Central Bank of Nigeria (CBN) framework on open banking has now transitioned from a policy document to a phased implementation. Nigeria has a comprehensive history of open banking; with the Central Bank issuing Africa’s first Open Banking Regulatory framework in February 2021, followed by the Operational Guidelines in March 2023. In April 2025, the CBN provided August 2025 as the launch date for an operation that would have seen Nigeria emerge as the first African country to launch national open banking. However, the initial launch date was deferred as the CBN stressed that a wholly automated system that offers robust data protection and stringent consumer protection mechanisms should first be in place.

Nigerian Lending – Perfection. Banks and Borrowers Keep Making These 5 Mistakes

Banking and Finance Law, Business Advisory, Business, Careers, Business, Small Business, Corporate & Commercial, Corporate Restructuring and Insolvency, Financial Services, Financial Technology (FinTech), Project Finance, Public-Private Partnerships (PPP), Startups and MSME LawBy Colin Egemonye April 15, 2026

There is no loan facility stronger than the security that underlies it. Any bank that doesn’t properly secure its assets is not a secured creditor. And a borrower that does not understand its perfection obligations might find that its representations to its lender were false. These are five security perfection mistakes we see often and every party involved in a Nigerian credit transaction needs to know about them.

Goldsmiths Solicitors – Legal Recap for the Year 2025

Banking and Finance Law, Business Advisory, Business, Entrepreneurs, Business, Sales, Capital Markets, Corporate & Commercial, Financial Services, Financial Technology (FinTech), Innovation and Technology, Intellectual Property, Public Sector, Startups and MSME Law, TelecommunicationsBy Colin Egemonye December 19, 2025

2025 was a very exciting year and saw significant changes in Nigeria’s legal and regulatory landscape. Series of laws were enacted by the National Assembly and regulatory guidelines were also issued by regulators including the Central Bank of Nigeria, Federal Competition and Consumer Protection Commission, the Nigerian Communications Commission, etc. There were also some important judicial decisions from the courts in Nigeria which shaped the legal and regulatory space in the country. This recap is divided into four parts representing the four quarters of the year, highlighting what we think are the most impactful laws and regulations, reforms, and judicial decisions in 2025.

New Rules for Agent Banking in Nigeria

Banking and Finance Law, Business Advisory, Business, Advertising, Business, Entrepreneurs, Business, Sales, Business, Small Business, Capital Markets, Corporate & Commercial, Financial Services, Financial Technology (FinTech), InsightsBy Colin Egemonye October 24, 2025

On 6 October 2025, The Central Bank of Nigeria (CBN) issued the Guidelines for the Operations of Agent Banking in Nigeria (the “Guidelines”). The purpose of the Guidelines is the…

How Virtual Assets Service Providers (VASPs) Can Obtain Licenses in Nigeria

Banking and Finance Law, Business Advisory, Financial Services, Financial Technology (FinTech), Insights, Startups and MSME LawBy Colin Egemonye August 26, 2025

With the enactment of the Investment and Securities Act (ISA) 2025, virtual assets/digital assets including cryptocurrencies, Non-Fungible Tokens (NFTs), etc. can now be legally traded and transacted in Nigeria subject to satisfying applicable legal requirements. Prior to the enactment of the ISA, the legality of trading or transacting in virtual/digital assets was uncertain especially following the Central Bank of Nigeria (CBN) circular of 2021 which directed all financial institutions to identify persons and entities transacting or operating cryptocurrency exchanges in Nigeria and ensure that their bank accounts are closed.