When the Central Bank of Nigeria (CBN) published its Regulations for the Operations of Non-Security Virtual Assets on 5 November, the resulting document ran to 167 pages and reached into nearly every corner of the country's digital asset industry. What the sweeping new crypto rulebook could not settle on paper is now being settled in public reaction.

The founders and operators who must live under these rules are broadly glad they exist, yet their first responses circle the same two anxieties familiar to every player in the Nigerian crypto ecosystem: where the Securities and Exchange Commission's (SEC) authority ends and the Central Bank of Nigeria's begins, and whether the licences will arrive in the order the market actually needs them. On paper, the division of labour is definitional — the CBN's rulebook governs virtual assets that are not securities, the category into which naira-referenced stablecoins fall, while the SEC runs its own registration regime for digital asset operators. In practice, though, the same products and infrastructure sit close enough to both mandates that operators describe the boundary as hard to read.

Charles Okaformbah, co-founder of cNGN, Nigeria's naira-pegged stablecoin, and of Convexity, the technology company behind it, speaks as an issuer who already answers to one regulator and must now answer to two. Wrapped CBDC, the company that issues cNGN, sits inside the SEC's incubation programme, while the token itself falls under the CBN's Class 1 licence for Naira-referenced issuers. His response to the new policy, shared with Technext, is welcoming — but the welcome comes with a request attached.

“Obviously, it is a welcome development, as it provides clarity to an industry that has been growing without the requisite regulatory guidance. But a bit of clarity is needed between what is applicable for players from the two primary regulators, CBN and SEC, who are closely knit. The same infrastructure underpins the products borne from the technology both government agencies are regulating, so it can be confusing if a clear distinction is not provided to players in the space.”

The document gives that concern a financial edge, because the two regimes do not merge their demands. A Class 1 issuer must maintain ₦10 billion in paid-up capital at all times — five times the ₦2 billion the SEC's revised rules set for exchanges — and the guidelines state plainly, in Sections 16.2 and 17.3, that capital presented to the SEC cannot be counted a second time towards the CBN requirement. The separation runs through the entire rulebook: reserves, the capital deposit and the liquid assets covering six months of operating expenses must each stand apart from the others. Section 53.2 promises coordination with other authorities — precisely the inter-regulator alignment Okaformbah called for — yet an existing licence does not remove the need for express CBN approval.

Rume Ophi, co-convener of Decentralised Nigeria and Lead for Programs and Communication at VASPA, the Virtual Asset Service Provider Association, pushes the argument further down the chain — from the companies issuing stablecoins to the platforms placing them in users' hands.

“But here's the question nobody is asking. No crypto exchange in Nigeria holds a full SEC licence today. So will we have licensed stablecoin issuers, with no fully licensed exchanges to distribute them? The rules allow CBN-licensed distributors. The gap is timing. Whoever secures CBN and SEC approval first controls the market.”

On the facts, he is right. The SEC confirmed on 29 October 2026 that no digital asset operator yet holds final registration. Fourteen firms — among them Busha, Quidax and Wrapped CBDC itself — operate with an Approval-in-Principle inside the incubation programme, a provisional status the Commission insists is not a licence. The CBN's rules are strict about the distribution shelf: a stablecoin may be distributed only through persons the Bank has licensed or authorised, no distributor may perform an activity requiring its own licence without holding it, and Section 26.21.3 obliges an issuer to drop any distributor that is unlicensed where licensing is required.

What softens the gap is the transition; what sharpens it is the calendar. Section 54.1 allows existing operators to keep running at their current scale while they convert, provided they register with the Bank within thirty days, begin supervisory reporting within sixty and file a complete application within one hundred and eighty days. Counted from the 5 November commencement, that places registration in early December 2026 and full applications around 4 May 2027 — weeks before the SEC's own deadline of 30 June 2027 for exchanges to meet its revised ₦2 billion capital requirement. Two regulators, two clocks, and one set of companies trying to satisfy both at once. Those dates now double as the industry's first measurable checkpoints of whether the two regimes are converging.

The test of this framework, then, is not whether the industry accepts it — on the evidence of these first reactions, it does. The test is sequencing. If the CBN and the SEC can align their approvals so that issuers and the platforms distributing their tokens are licensed in step, the rulebook will have delivered the clarity Okaformbah asked for. If they cannot, Nigeria may find itself with fully licensed stablecoins and nowhere fully licensed to sell them — precisely the market Ophi is warning about.