With the Investments and Securities Act 2025 (ISA 2025) now fully in force, operating a cryptocurrency exchange, custody service, or digital asset platform in Nigeria without SEC registration is illegal, regardless of where your company is incorporated.
If Nigerian users are using your service, you need SEC authorisation. The enforcement risk for unlicensed activity is rising significantly in 2026.
Norebase helps crypto and blockchain companies navigate the SEC licensing process from initial eligibility through to full VASP registration.
Who Needs a Crypto Licence in Nigeria?
- Cryptocurrency exchange: platforms where users buy, sell, or swap crypto
- Digital asset custody providers: companies holding private keys or managing digital wallets
- Digital Asset Offering Platforms (DAOPs): platforms for ICOs and token sales
- Crypto payment processors: businesses using virtual assets to process payments
- Staking and yield platforms: offering returns on digital asset holdings
- Mining infrastructure companies: providing or operating mining hardware at scale
- Foreign exchanges with Nigerian users: geo-blocking must be implemented without a licence
The 4 SEC Licence Categories
| Field | Details |
|---|---|
| DAX (Digital Asset Exchange) | For crypto trading platforms. Minimum capital: ₦2 billion |
| DAOP (Digital Asset Offering Provider) | For ICO/token offering platforms. Minimum capital: ₦1 billion |
| DAC (Digital Asset Custodian) | For crypto wallet and custody services. Minimum capital: ₦2 billion |
| VASP (Virtual Asset Service Provider) | Broader category covering exchanges of crypto for fiat and other virtual asset services |
The Two Routes to SEC Licensing
Route 1 — Full SEC Registration
Direct application under SEC Nigeria’s capital market operator framework. For companies with the capital, infrastructure, and operational readiness to apply directly.
Route 2 — ARIP (Accelerated Regulatory Incubation Program)
ARIP is a structured regulatory entry pathway, not a loophole. It allows exchanges to obtain Approval-in-Principle (AIP) while transitioning toward full registration. It lasts up to 12 months with quarterly reporting and a 10-month regulatory guidance review. For many global operators, ARIP is the more practical entry point.
Prerequisites Before Applying
- Company must be fully registered with the CAC in Nigeria, certificate of incorporation required
- Minimum paid-up capital must be in place, fully traceable source of funds. CBN conducts thorough due diligence
- Physical office in Nigeria required
- CEO or Managing Director must be resident in Nigeria
- Properly constituted board with experience in financial services, technology, and regulatory compliance
Step-by-Step Process
- CAC incorporation — register your Nigerian entity with Norebase. 3–5 business days
- Assess eligibility — determine whether full registration or ARIP is the right route for your stage
- Prepare capital — demonstrate minimum paid-up capital with fully traceable documentation
- Build compliance infrastructure — KYC/AML system meeting the 2026 CBN Baseline Standards, real-time transaction monitoring, suspicious activity reporting capability
- Prepare application documentation — business plan, compliance policies, board CVs, IT security certifications
- Submit to SEC — SEC evaluates operational readiness, compliance capacity, and capital adequacy
- ARIP participation (if applicable) — up to 12 months, with quarterly reporting
- Full VASP registration — upon successful completion of ARIP or direct application
2026 Ongoing Compliance Requirements
- Real-time KYC validation against NIN and BVN government databases
- Mandatory biometric checks and advanced liveness detection
- Continuous AML transaction monitoring, no periodic batch checking
- Suspicious transaction reporting to NFIU in real time
- No insider trading, no margin lending, no crypto credit lines
- Every new token listing requires prior SEC approval before going live
- Capital gains tax compliance under Nigeria Tax Administration Act (NTAA) 2025
- Customer records retained for minimum 7 years
| Field | Details |
|---|---|
| CAC registration | 3–5 business days with Norebase |
| Licence route | Norebase advises on full registration vs ARIP based on your stage |
| Pricing | Contact Norebase for a quote, no hidden fees |
| Timeline | ARIP: up to 12 months. Full registration: varies |
| Key risk | Operating without licence, fines, account freezing, prosecution |
Planning to operate in Nigeria’s crypto market? Comment below and we’ll reach out to you
Ensure your digital asset platform stays fully compliant. Navigate complex SEC regulations and licensing with our expert legal ops team. Contact our Crypto Compliance Team.