Banking & Finance, Corporate Commercial Practice Group, Insights

Status Update on CBN’s Banking Sector Recapitalization

In March 2024, the Central Bank of Nigeria (CBN) released the Banking Sector Recapitalization Programme (FPR/DIR/PUB/CIR/002/009), requiring all commercial, merchant, and non-interest banks to significantly increase their minimum paid-in capital. The new requirements represented a substantial increase across board. International commercial banks had to grow their capital from N50 billion to N500 billion, while national commercial banks moved from N25 billion to N200 billion, and regional commercial banks from N10 billion to N50 billion. National merchant banks moved from N15 billion to N50 billion. For non-interest banks, national licence holders went from N10 billion to N20 billion, while regional licence holders moved from N5 billion to N10 billion. The directive gave banks a 24 – month window to comply, with a deadline of 31 March 2026.

 

The Programme aims to strengthen Nigerian banks against economic shocks, enhance the stability of the financial system, and position the sector to support the achievement of a US$1 trillion economy by 2030. The last time Nigeria undertook a similar exercise was in 2004/2005, when the then CBN Governor Charles Soludo announced an increase in the minimum capital requirement for banks from N2 billion to N25 billion, with full compliance required by end of December 2005. That reform, driven by mergers and acquisitions, reduced the number of banks from 89 to 25.

 

Where Things Stand Today

In a press statement released by the CBN on April 1, 2026, the CBN confirmed that 33 banks had met the revised capital requirements. CBN Governor Olayemi Cardoso noted that the exercise had significantly strengthened the resilience and capacity of the Nigerian banking system. The capital raised reflects strong investor confidence, in fact, Nigerian banks collectively raised N4.65 trillion in new capital during the programme, with 72.55% sourced domestically and 27.45% from international markets. The recapitalisation has also strengthened capital adequacy ratios (CAR) across the sector, which remain above international Basel benchmarks. Minimum CAR thresholds continue at 10% for regional and national banks and 15% for banks with international authorisation.

 

What Happens Next

The CBN is yet to issue a formal post-deadline directive on next steps for non-compliant institutions, though one is anticipated in the coming days. Drawing from the 2004/2005 precedent, options are likely to include: a short additional grace period, a licence downgrade, or, in the most extreme case, licence revocation. We await a definitive position.

 

What This Means for You

The CBN indicated that the programme was implemented alongside an orderly exit from regulatory forbearance, improving asset quality and reinforcing balance-sheet transparency. Additionally, the CBN was clear on the point that recapitalisation does not affect customer accounts, and banking services continue normally before and after the March 31st, 2026, deadline. The recapitalised banking sector is expected to be better positioned to support lending, mobilise savings, and withstand domestic and global shocks. So, do not act on social media rumours about account freezes or bank closures; the CBN has dismissed these as false.

 

Conclusion

The bigger picture is encouraging. A recapitalised banking sector means larger balance sheets, greater capacity to fund significant transactions, and stronger institutions better placed to absorb economic shocks. Banks that have met the new capital requirements now have more money to lend, can take on bigger transactions, and are better placed to weather economic pressures. For everyday customers and businesses, this translates to stronger, more stable banks.

Further guidance from the CBN is anticipated shortly. We will keep you informed as developments arise.

To read the full article, kindly download the PDF

Ifeoma Ezeribe

Partner

Philip Francis

Senior Associate

Excellent Epelle

Associate

Roqeebat Sulaimon

Associate

Oluwanifemi Alade

Trainee Associate

Practice Key Contacts

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