Nigeria treats digital assets as securities under its 2025 law, and a July 2026 order puts a council under the central bank

Nigeria’s Investments and Securities Act 2025 treats virtual and digital assets as securities, and the SEC regulates activities involving securities. A July 2026 executive order created a Virtual Asset Council chaired by the central bank. Banks may open designated accounts only for SEC-licensed providers. No text reviewed mentions crypto ATMs.

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17 Jul 2026
Date the Presidential Executive Order on Virtual Assets Coordination was signed (as reported)
24 Oct 2025
Date the FATF removed Nigeria from its increased monitoring list
0
Mentions of crypto ATMs in the legal texts reviewed

Nigeria's Investments and Securities Act 2025 treats virtual and digital assets as securities, and the SEC regulates activities involving securities.1,2,13 A July 2026 executive order created a Virtual Asset Council chaired by the central bank.6,13 Banks may open designated accounts only for SEC-licensed providers.8 No text reviewed mentions crypto ATMs.

Last updated: October 2026

Regulatory Framework

The Investments and Securities Act 2025 is reported as Act No. 2 of 2025, published in Official Gazette No. 19 on 2 May 2025, with 25 March 2025 given as its enactment and commencement date. Section 357 is reported to define securities to include virtual and digital assets, and section 355 to let the SEC make rules on digital and virtual asset services.1,2 Both reports are secondary, and the Act itself was not read.

The SEC rules on issuance, offering platforms and custody of digital assets set separate registration categories. They define a digital asset exchange as an electronic platform that facilitates the trading of a virtual or digital asset, and list a minimum paid-up capital of ₦500 million for exchanges and offering platforms and a registration fee of ₦30 million. The text carries no date.3 Later reports put the exchange minimum at ₦2 billion, citing SEC Circular No. 26-1 of January 2026 in one case and the proposed rules in another, so the current figure should be checked with the SEC.5,7

The SEC document titled Rules on Digital and Virtual Assets Operations, Custody and Markets defines a virtual asset service provider as a person who, as a business and for or on behalf of another person, exchanges virtual assets and fiat currency, exchanges one form of virtual asset for another, or transfers virtual assets. The excerpt reviewed cuts the list off after those three activities. Section 2(1)(b) requires incorporation in Nigeria unless the SEC approves otherwise, a registered office in Nigeria and a resident chief executive. The excerpt shows no effective date and does not say whether the rules are final.4 The Meridian reported them as published for public comment on 20 August 2026, and says they would replace the 2022 Digital Asset Rules.5

Executive Order of July 2026

The Presidential Executive Order on Virtual Assets Coordination, 2026, was signed by President Bola Ahmed Tinubu on 17 July 2026 and took effect immediately, according to two reports. It creates a Virtual Asset Council chaired by the Central Bank of Nigeria, with a secretariat within the CBN, to coordinate regulators. Vanguard reports that the Nigeria Revenue Service and the SEC are vice-chairs, that the financial intelligence unit and the Office of the National Security Adviser are members, and that the Presidency said the order creates no new regulator and shifts no powers.13 The same report says activities relating to securities fall under the SEC, and that payment, settlement and custody services for non-security virtual assets are registered with the CBN.13 Goldsmiths LLP says the order adds no licensing requirement beyond the Investments and Securities Act 2025 and SEC rules.7 The council had 30 days to produce a Harmonised Implementation Framework, according to Vanguard, and none was found.13 The text of the order was not read, and none of the reports mentions crypto ATMs.

Date What happened
22 Dec 2023 The CBN issues guidelines on bank accounts for virtual asset service providers, with designated accounts only for SEC-licensed entities8
29 Aug 2024 Quidax is reported as the first SEC-licensed crypto exchange, holding a provisional operating licence (as reported)11
25 Mar 2025 Date given for the enactment and commencement of the Investments and Securities Act 2025 (as reported)1
24 Oct 2025 The FATF removes Nigeria from the increased monitoring list it joined on 24 February 20239,10
17 Jul 2026 The executive order on virtual assets coordination is signed (as reported)6,7
20 Aug 2026 The SEC proposed rules on digital and virtual asset operations are reported as published for comment (as reported)5

Banking Access

The CBN guidelines of 22 December 2023 apply to banks and other financial institutions. The cover letter says they are still prohibited from holding, trading or transacting in virtual currencies on their own account. Designated accounts for virtual and digital asset business require evidence of a valid SEC licence (paragraph 7.3(a)) and may be used only for virtual or digital asset transactions (paragraphs 7.1 and 7.4(i)). Paragraph 7.4(ii) states that no cash withdrawal is allowed from the account, and paragraph 7.4(iv) allows withdrawals only by manager's cheque or transfer. The guidelines do not address cash deposits directly.8

FATF Listing

The FATF states that Nigeria was added to increased monitoring on 24 February 2023. Its statement of 24 October 2025 says Burkina Faso, Mozambique, Nigeria and South Africa are no longer subject to increased monitoring after completing their action plans within the agreed timeframes. Nigeria continues to work with its regional body, GIABA.9,10

Crypto ATMs

None of the legal texts reviewed mentions crypto ATMs, including the SEC rules, the CBN guidelines and the reports on the executive order.3,4,6,7,8,13 The VASP definition in the SEC document covers exchange between virtual assets and fiat currency for others, and no text says whether a machine operator falls under it.4 No separate licence for a machine operator was found.

Nairametrics reported on 2 April 2020 that Blockstale BTM installed a bitcoin ATM at Dazey Lounge and Bar in Lagos and planned more than 30 terminals across Nigeria. Its chief executive referred to legal uncertainties about cryptocurrencies in Nigeria.12 No later report on the machines was found, and whether any machine operates today was not verified.

What Is Not Known

No text reviewed says whether a cash-for-crypto machine operator needs SEC registration as a virtual asset service provider. The CBN guidelines bar cash withdrawals from designated accounts, and they do not say how cash taken at a machine would be banked. The status of the SEC proposed rules and the current minimum capital figures for each category were not confirmed, because the sources differ. The executive order and the Investments and Securities Act 2025 were read only through secondary reports, and the reports differ on whether the CBN or the SEC registers each type of service. The number of working machines was not found. Nigerian counsel and the SEC would need to confirm how a machine operator is classified.


Sources and references

1. CryptoSlate, Nigeria Investments and Securities Act 2025: Virtual and Digital Assets (SECONDARY, accessed 16 October 2026) | cryptoslate.com
2. Legal issue brief on crypto-currency, June 2025, hosted by the NILDS repository (SECONDARY, accessed 16 October 2026) | ir.nilds.gov.ng
3. Securities and Exchange Commission, Nigeria, Rules on Issuance, Offering Platforms and Custody of Digital Assets (PRIMARY, undated, accessed 16 October 2026) | sec.gov.ng
4. Securities and Exchange Commission, Nigeria, Rules on Digital and Virtual Assets Operations, Custody and Markets, Sections 1 and 2 (PRIMARY, excerpt, accessed 16 October 2026) | sec.gov.ng
5. The Meridian 50, SEC proposed digital asset rules, 27 September 2026 (SECONDARY, date taken from the URL, accessed 16 October 2026) | themeridian50.com
6. Techpoint Africa, President Tinubu signs executive order to unify Nigeria's virtual assets regulation, 17 July 2026 (SECONDARY, accessed 16 October 2026) | techpoint.africa
7. Goldsmiths LLP, What the Virtual Assets Coordination Order means for digital assets operators (SECONDARY, accessed 16 October 2026) | goldsmithsllp.com
8. Central Bank of Nigeria, Guidelines on Operations of Bank Accounts for Virtual Asset Service Providers, 22 December 2023 (PRIMARY, accessed 16 October 2026) | cbn.gov.ng
9. FATF, Nigeria country page (PRIMARY, accessed 16 October 2026) | fatf-gafi.org
10. FATF, Outcomes of the Plenary, 22-24 October 2025 (PRIMARY, accessed 16 October 2026) | fatf-gafi.org
11. Cointelegraph, Nigeria's SEC issues first license to local crypto exchange, 29 August 2024 (SECONDARY, accessed 16 October 2026) | cointelegraph.com
12. Nairametrics, Nigeria welcomes its first Bitcoin ATM, 2 April 2020 (SECONDARY, accessed 16 October 2026) | nairametrics.com
13. Vanguard, Tinubu signs executive order to harmonise virtual assets regulation, establishes council, 17 July 2026 (SECONDARY, accessed 16 October 2026) | vanguardngr.com

Legal Disclaimer: This article by GENERAL BYTES is for informational purposes only and does not constitute formal legal, financial, or investment advice. Rules may change; always consult specialised local legal counsel and confirm the current position with the Securities and Exchange Commission and the Central Bank of Nigeria before considering market entry.