Nigeria’s regulatory landscape has shifted materially in 2025 and entered full implementation in January 2026. The new Tax Act, insurance reforms, banking recapitalisation, and its removal from the Financial Action Task Force (“FATF”) grey list represent the most significant restructuring of our financial framework in decades.

For infrastructure and project finance, the implications are tangible. With 19-22 banks now recapitalised (as of January 2026), financial institutions can now underwrite significantly larger transactions can now underwrite larger transactions. Nigeria’s removal from the FATF grey list on October 24, 2025 and from the EU’s high-risk list effective January 29, 2026, is easing foreign lender concerns and restoring correspondent banking relationships. We are seeing Development Finance Institutions (DFIs) and commercial banks reengage on transactions that stalled over the past two years. The Infrastructure Concession Regulatory Commission (ICRC) framework, combined with clearer tax treatment and stronger counterparties, should accelerate bankable PPP deals in 2026.

The transition will not be seamless. New capital thresholds in the financial sector and consolidated tax rules will require structural adjustments. Some of these changes will be costly. But the direction is clear: a more predictable environment for serious capital deployment.

In the pages that follow, our team provides a detailed analysis of what these reforms mean operationally from the mechanics of the new tax regime to the infrastructure financing window now opening, the banking and insurance consolidation underway, and the formalisation of digital asset markets. This is not commentary for commentary’s sake. These are the issues that will shape your business decisions in 2026.

If any of these reforms affect your plans for this new year, we should discuss sooner rather than later.