Here are the summary for quick read:

Three token categories stand out:

📌1. Class 1 – Naira Stablecoins

📍Application fee: ₦10m.

📍Minimum paid-up capital: ₦10bn.

📍Fully backed by eligible Naira-denominated reserves.

📍Permitted for payments, settlement and treasury management.

📍No interest or yield for simply holding tokens.

📌2. Class 2 – Foreign Currency Stablecoins

E.g USDT, USDC ETC (illustrative, mentioned in guideline).

📍Application fee: ₦10m.

📍Minimum paid-up capital: ₦15bn.

📍Foreign currency-denominated reserve backing in a Nigerian Bank.

📍Permitted for cross-border payments, remittances and international trade settlement.

📍Domestic Naira obligations and Naira conversion remain subject to FX controls.

📌3. Deposit Money Tokens (DMTs)

E.g: Tokenised Naira deposits issued by commercial banks.

📍Exclusively issued by CBN-licensed banks with prior approval.

📍Subject to existing banking capital requirements.

📍Every token must represent an actual deposit liability.

📍Interbank transfers through CBN-approved settlement infrastructure, potentially RTGS.

📍The issuing bank remains liable for the underlying deposit.

📌4. Other Services – VASP Licence/Authorisation

📍Minimum paid-up capital: ₦1bn. Application fees are separately prescribed by the CBN.

Covered services include:

📍Custodial and non-custodial wallet services.

📍Crypto custody and private-key administration.

📍Fiat-to-crypto and crypto-to-crypto exchange/conversion.

📍Naira and foreign currency on/off-ramp services.

📍Domestic and cross-border transfers and remittances.

📍Token distribution and market access.

📍Payment gateways and merchant acceptance.

📍Virtual asset stored-value facilities.

📍Platform-facilitated P2P services (subject to specific approval).

Financial institutions can apply for approval to extend their existing permitted activities, while SEC-regulated entities require the relevant CBN authorisation for non-security services. The additional ₦1bn capital requirement applies to these routes as well.

My biggest takeaway is that the framework is sound on it merit as it sets a clear distinction between privately issued stablecoins and tokenised commercial bank deposits, while bringing Foreign issued stablecoin are brought under a new regulatory regime in Nigeria.

But i see a lacuna around the paid-up capital requirements for a fully-reserved stablecoin is factually a duplication of prudence. issuers dont lend out stablecoin reserves, no fractional banking considerations is involved, and strict reserve composition already expected and regulated. An additional N10 Billion paid up capital looks like an overkill for a non existing local Naira stablecoin industry as it serves no purpose like we have with fractional bank deposits