Highlights Of The Guidelines Letters Circulars And Notifications Issued In December 2025

The Central Bank of Nigeria ('CBN'), the Nigerian Immigration Service ('NIS'), the Nigerian Communications Commission ('NCC'), the Financial Reporting Council of Nigeria ('FRCN') and the Securities and Exchange Commission ('SEC') issued a series of Press Releases, Circulars, Directives, Public Notices and Guidelines in December 2025, containing information and directives for the Financial Services, Immigration, Telecommunication, and the general public. We hope that you find the information useful in your operations.

CBN ISSUES CIRCULAR TO ALL BANKS, OTHER FINANCIAL INSTITUTIONS AND THE GENERAL PUBLIC ON REVISED CASH-RELATED POLICIES

The CBN issued a circular directing all financial institutions to remove all charges and limits on cash deposits while setting weekly withdrawal limits of ₦500,000 for individuals and ₦5 million for corporate bodies across all channels. Under the new regime, which is effective from 1st January 2026, withdrawals exceeding these thresholds will attract fees of 3% and 5% for individuals and corporate customers respectively, on the excess amount withdrawn. Daily ATM withdrawals are now limited to ₦100,000 per customer. The CBN has also withdrawn previous exemptions for diplomatic missions and scrapped special authorisations for large-scale cash access. The limit on over-the-counter encashment of 3rd party cheques was retained at ₦100,000. By mandating banks to stock all denominations in ATMs, the Policy encourages digital transactions and reduces the high costs associated with physical cash handling. This strategic shift aims to foster a cashless economy, improve security, and curb financial crimes like money laundering through stricter monitoring.

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CBN ISSUES CIRCULAR MANDATING DUAL CONNECTIVITY TO THE PAYMENT TERMINAL SERVICE AGGREGATORS

The CBN issued a circular directing all Payment Acquirers, Processors, and Payment Terminal Service Providers ('PTSPs') to maintain active connectivity to both the Nigeria Inter-Bank Settlement System and Unified Payment Services Limited to eliminate single points of failure. The directive seeks to enforce automatic failover configurations for seamless transaction routing and mandates that aggregators provide real-time downtime notifications and incident reports to Banks and the Director, Payments System Supervision Department of the CBN within 24 hours of its occurrence. The directive aims to rebuild consumer confidence in digital payments. Stakeholders are required to comply with the directive within one (1) month from the date of the circular.

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CBN ISSUES GUIDELINES FOR SEAMLESS FOREIGN CARD USAGE AND MERCHANT SETTLEMENT

The CBN issued a circular mandating that all banks and non-bank acquirers of value ensure uninterrupted Naira withdrawals and payments for foreign cardholders across all Automated Teller Machines, Point of Sale operators, and web-based platforms. Under the directive, operators must implement multi-factor authentication for transactions exceeding $200 daily, $500 weekly, or $1,000 monthly, while maintaining full compliance with global card scheme standards. Crucially, all such transactions must now be settled for the merchant in local currency (Naira). The applicable exchange rate must be market-driven and based on the prevailing official rate, and it must be clearly communicated to the user before the transaction is finalised. This directive aims to eliminate unofficial surcharges and dynamic currency conversion practices that have previously discouraged the use of foreign cards in Nigeria. Furthermore, banks are required to maintain sufficient liquidity to settle these transactions and to recalibrate their fraud-monitoring systems to minimise false declines on legitimate foreign transactions. Tourists and Nigerian returnees from the diaspora who experience difficulties using their foreign-issued payment cards are advised to report such incidents promptly to the CBN.

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CBN ISSUES ITS MACROECONOMIC OUTLOOK FOR NIGERIA 2026

The CBN issued the Macroeconomic Outlook for Nigeria and projects the country's GDP growth to accelerate in 2026, driven by non-oil sector expansion and improved oil production. Following the combined impact of easing of food and energy prices as well as the effects of the CBN's monetary policy tightening cycle, inflation is forecasted to drop closer to single digits as exchange rate stability and fiscal-monetary coordination take hold. Some of the anchors for 2026 include the Nigeria Tax Act 2025 and ongoing banking recapitalisation, aimed at boosting revenue and enhancing credit intermediation for sustainable growth. While the outlook is cautiously optimistic, the report emphasises the need for sustained reform commitment to mitigate global uncertainties and potential domestic inflationary risks.

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CBN CONFIRMS FULL LICENSING OF 82 BUREAU DE CHANGE (BDCs) UNDER STRENGTHENED REGULATORY FRAMEWORK

The CBN confirmed that it has granted final licenses to 82 Bureau De Change ('BDC') operators who successfully met the rigorous new capital and operational requirements. This milestone follows a significant recapitalisation drive requiring Tier-1 BDCs and Tier-2 BDCs to meet a capital requirement of ₦2 billion and ₦500 million respectively, leading to the revocation of licenses for legacy BDCs that failed to meet the minimum capital requirement. The apex bank emphasised that only licensed operators are authorised to conduct retail foreign exchange business, warning that unlicensed operations are punishable under the Banks and Other Financial Institutions Act (BOFIA) 2020. A list of the valid licensees is accessible on the CBN website for public verification.

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NCC UNVEILS DRAFT FIVE-YEAR SPECTRUM ROADMAP AND DRAFT GUIDELINES FOR THE USE OF 60 GHZ LICENSE EXEMPT BAND FOR MULTI-GIGABIT WIRELESS SYSTEMS

The NCC unveiled its Five-Year Spectrum Roadmap (2025–2030). The roadmap prioritises the commercialisation of Direct-to-Device ('D2D') technology and Non- Terrestrial Networks ('NTN') to eliminate "signal blackspots" in rural and riverine regions. The roadmap prioritises Direct-to-Device (D2D) satellite technology and spectrum sharing to eliminate signal dead zones and achieve 100% broadband coverage by 2030. Operators and equipment providers must ensure all hardware is NCC Type Approved and commercial deployments are registered via the Commission's portal. Stakeholders are invited to review these strategic frameworks and submit formal comments to the NCC by 16th January 2026.

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NIS ANNOUNCES NIGERIA'S RE-ELECTION INTO THE ICAO-PKD BOARD

Nigeria was re-elected to the International Civil Aviation Organisation ('ICAO') Public Key Directory (PKD) Board on 11th December 2025 for a sixth consecutive term. Nigeria is one of only 15 board members representing 107 participating states, reflecting its long-standing influence in the organisation since 2009. The re-election acknowledges Nigeria's expertise in Public Key Infrastructure (PKI) and electronic Machine- Readable Travel Document ('eMRTD') verification. The NIS reaffirmed its commitment to digital identity harmonisation and upholding international standards for travel document integrity.

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FRCN's UPDATED POSITION ON THE APPLICATION OF THE INTERNATIONAL ACCOUNTING STANDARD ('IAS') 29 FOR 2025 FINANCIAL REPORTING PERIODS.

The FRCN has issued an updated position affirming that Nigeria does not meet the criteria for classification as a hyperinflationary economy under IAS 29. Based on its assessment of inflation data up to 31st October 2025, qualitative economic indicators, stakeholder consultations, and IMF projections, the FRCN concluded that IAS 29 is not required to be applied to financial statements for reporting periods ending in 2025.

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SEC ISSUES WARNING AGAINST GLORIOUS WEALTH FUND ('GWF')

SEC has issued a public warning against an online investment platform operating as Glorious Wealth Fund ('GWF'). The SEC clarified that GWF is not registered or licensed to operate in the Nigerian capital market, and any claims of SEC supervision or approval are false and misleading. SEC received investor complaints regarding inability to withdraw funds, indicating characteristics of an illegal investment scheme. The public is advised to refrain from engaging with GWF and to verify the registration status of investment entities via the SEC's verification portal before transacting.

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SEC LAUNCHES THE REGULATORY HUB

SEC has launched the Regulatory Hub, a centralized digital platform designed to foster collaboration, strengthen oversight, and enhance transparency across Nigeria's financial and capital market ecosystems. The Hub enables secure real-time exchange of regulatory information among participating agencies, including the office of the National Security Adviser (NSA), Central Bank of Nigeria (CBN), Economic and Financial Crimes Commission (EFCC), Federal Inland Revenue Service (FIRS), and Corporate Affairs Commission (CAC) and others. Stakeholders are encouraged to initiate interest by emailing the SEC at eportal@sec.gov.ng. Once registered, participants will be able to access the Hub and take advantage of its features via: https://hub.sec.gov.ng/

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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.