The Nigeria Startup Act

Business Advisory, Business, Entrepreneurs, Business, Small Business, Financial Services, Financial Technology (FinTech), Innovation and Technology, Intellectual Property, Investment Law, Startups and MSME LawBy Shola Adekunle September 21, 2026

The Nigeria Startup Act 2022, signed into law in October 2022, was co-created by the government and the technology ecosystem specifically to give startups regulatory certainty, incentives and an enabling institutional framework. Assessments marking its second anniversary generally concluded that the architecture was sound but implementation uneven. What is notable, three and a half years in, is that the same conversation is still happening in public. This article looks at why that gap has persisted, at a further complication that has emerged from the tax reform, and what founders and investors should realistically plan around.

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The coming into force of the Investments and Securities Act 2025, which repealed the Investments and Securities Act 2007, marked significant changes to the regulatory framework applicable to virtual and digital assets in Nigeria.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.

Data Localisation: What the New Payments Circular Means for Banks & Fintechs

Business Advisory, Business, Entrepreneurs, Corporate & Commercial, Financial Services, Financial Technology (FinTech), Innovation and Technology, Startups and MSME LawBy Colin Egemonye July 20, 2026

Nigeria’s digital payments sector grew faster than the regulatory architecture that has been built around it. Electronic transaction volumes have increased, mobile money adoption has grown and a few switching, processing and payment solutions providers are at the center of how money moves around the country. The Central Bank of Nigeria concluded that this growth created risks that its rules were not designed to deal with and in June 2026, issued a new circular focusing on data localisation, market concentration & ownership transparency in the payments sector titled “Introduction of Market Structure Requirements, Data Localisation, Ultimate Beneficial Ownership Disclosure, and Systemic Oversight Measures in the Nigeria Payments System” (the “Circular”).

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.

DFI Lending in Nigeria: What Every Borrower Must Know Before Signing

Business Advisory, Corporate & Commercial, Financial Services, Financial Technology (FinTech), Project Finance, Startups and MSME LawBy Kingsley Anyiam May 18, 2026

Lending from development finance institutions such as the International Finance Corporation, African Development Bank, Proparco, and German Development Finance Institution, DEG, and other multilateral and bilateral development finance institutions is becoming more accessible to Nigerian businesses across sectors. There may be longer tenors, attractive pricing, or even a strategic partnership that adds credibility and capital. However, borrowers should be aware that DFI loans are not commercial bank loans. They come with conditions, obligations and consequences that many Nigerian borrowers are not prepared for when they enter the facility agreement. In this article, we identify the five most critical areas where DFI lending most often cause problems for Nigerian borrowers and what every borrower should know before signing.

Embedded Finance in Nigeria – What Every Bank-Fintech Partnership Needs

Corporate & Commercial, Financial Services, Financial Technology (FinTech), Project FinanceBy Emmanuel Amadi May 13, 2026

By integrating financial services products into non-financial platforms and business models, embedded finance is changing the Nigerian financial services landscape faster than the regulatory and legal frameworks that govern it. Several banks are distributing financial products through digital channels using FinTech. The fintechs are leveraging bank APIs to deliver services that were once available only to licensed financial houses. Retailers, logistics companies and software companies are integrating payments, lending and insurance into their customer experiences.
This has huge commercial potential. Legal risks are also real and not adequately managed in most bank-finance partnership arrangements we review. Five key legal requirements that every embedded finance partnership in Nigeria must meet before the arrangement goes live are laid out in this article.

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.