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A trader in Lagos clearing generator sets, an agro-dealer in Kano buying packaging film, a freight forwarder in Apapa who has fielded the question from four clients this month: the supplier in Guangzhou will take USDT, it settles the same afternoon, and the bank wants a week and a Form M. Is that allowed?
Until this week nobody could answer with a document in hand. On 5 November 2026 the Central Bank of Nigeria published the Regulations for the Operations of Non-Security Virtual Assets in Nigeria. Settling an import in a dollar stablecoin, it turns out, is not an alternative to Nigeria’s foreign-exchange regime. Under these rules it is a foreign-exchange transaction — same purpose codes, same documentation, same reporting — and it must run through a licensed intermediary that, for most importers, does not exist yet.
What is happening?
The regulations carry circular reference PSP/DIR/PUB/CIR/001/004, signed by the Director of Payments System Policy, Musa Jimoh, and took effect on the day of publication (BusinessDay, 6 November 2026; Vanguard, 7 November 2026).
They cover Regulated Tokens: naira-referenced stablecoins (Class 1), foreign-currency-referenced stablecoins (Class 2 — a dollar token such as USDT or USDC sits here), bank-issued deposit money tokens, and anything else the Bank designates. The regulated activities include “transfer, payment, payment gateway and merchant-acceptance, stored-value, remittance, clearing and settlement services”, and section 2.1.1 bars anyone from conducting one without the licence the regulations require.
Two provisions decide the importer’s question. Section 9.13 provides that no person shall facilitate the use of a stablecoin for payment, settlement, remittance or merchant-acceptance purposes unless the token is an Approved Virtual Asset Payment Instrument and the person holds the relevant licence. Approval comes only from the Bank; nothing is grandfathered in by being widely used.
Section 11.10.2 settles the documentation. A cross-border virtual asset transaction is treated, for foreign-exchange purposes, as a transaction of “the corresponding current-account or capital-account category”, “subject to the same eligibility, documentation, reporting and settlement requirements as the equivalent transaction in foreign currency” — and section 11.10.3 adds that a licensee may not carry one out on lighter documentation than an Authorised Dealer would require.
Section 11.10.5 gives the specifics. A payment for imported goods in a Class 2 stablecoin “shall be supported by a valid Form M”; imported services need the documentation the FX Regulations require; the licensee records the reference and may pay only the foreign supplier or its virtual asset service provider. Where export proceeds arrive in a Class 2 stablecoin, the relevant Form NXP must be referenced, and they count as repatriated only once redeemed or converted and credited to the exporter’s export-proceeds domiciliary account with an Authorised Dealer. Holding them on-chain, the text says, “in Nigeria or elsewhere, shall not constitute repatriation” (corroborated in Leadership, 7 November 2026).
Two things remain uncertain. The published text still carries bracketed passages — the reporting deadline reads “[one Business Day]”, the rate benchmark “[the Nigerian Foreign Exchange Market reference rate]” — so some parameters look unfinished. And the exclusions — central bank digital currency, securities, e-money, certain bank liabilities, closed-loop loyalty points — say nothing about a business that merely receives a token in payment for its own goods.
Why it matters economically
Nigeria imported ₦14.42 trillion of goods in the second quarter of 2026, China the largest single source (National Bureau of Statistics, Foreign Trade in Goods Statistics Q2 2026, reported 7 September 2026). For many of those importers the binding constraint is not the exchange rate but the calendar: the time between placing an order and the supplier seeing value.
That is what the stablecoin offer sells. Not a better rate — a shorter wait. An importer who settles on Tuesday instead of the following Monday ships a week earlier and turns working capital more often.
The regulations do not remove that benefit. They price it correctly. Speed is now available inside the documentation chain and not around it, and the chain is where most of the cost always sat. An importer comparing “bank, slow, with a Form M” against “wallet, fast, no Form M” was comparing the wrong two things. The real comparison is against “licensed provider, faster, same Form M, plus a reporting trail” — and that exists only once somebody holds the licence.
The capital requirements indicate how many will. Minimum paid-up capital is ₦10bn for a Class 1 issuer, ₦15bn for a Class 2 issuer and ₦1bn for other service providers — the category a payment gateway or merchant-acceptance provider falls into. A ₦1bn floor is not a barrier a small crypto payments desk clears.
What it means for African businesses
This is a Nigerian instrument, applying to Nigerian residents and to services directed at them. It changes nothing about what a Ghanaian or Kenyan importer may do. The pattern, though, is one importers in other markets should expect: where a central bank already runs a foreign-exchange documentation regime, a token payment is likely to be assimilated into it rather than exempted from it.
Within Nigeria, the position for an importer or freight forwarder is this. The section 11.10 obligations are drafted onto licensees, Authorised Dealers, money transfer operators and licensed payment service providers — not onto the importer directly. But two provisions reach everybody. Section 10.6.3 states that using a token does not alter the regulatory treatment of the underlying transaction, or permit through a virtual asset something impermissible through conventional channels. Sections 10.6.4 and 11.10.15 bar any person from structuring, splitting, routing or using a transaction — including through an affiliate, an offshore entity or an unhosted wallet — to avoid those requirements.
So the quiet wallet-to-wallet settlement is not merely unlicensed at the other end. Done to get around the Form M, it is the conduct the anti-circumvention clauses name.
The supply side narrows too. Section 11.10.17 lets the Bank recognise a foreign-currency stablecoin issued outside Nigeria, but a recognised foreign stablecoin may be used only by an Authorised Dealer or an expressly approved licensee, only to settle wholesale cross-border transactions, and only if it is not offered to retail customers in Nigeria. The offshore dollar token is being routed towards the banks, not the trader’s own wallet.
Technology and AI implications
There is no system to buy here, and AI is close to irrelevant. A model cannot create a licence, approve a token or make a Form M unnecessary. Anyone selling an “AI compliance layer” for this is selling the wrong thing.
What the regulations create is an ordinary records requirement. Section 11.10.12 has the licensee report each cross-border transaction stating the purpose code and the Form M, Form NXP or Certificate of Capital Importation reference; section 11.10.5(c) has it pass the Authorised Dealer the details needed to close that record. Those references come from the importer. If the link between a purchase order, its Form M number, the payment that discharged it and the consignment that arrived lives in four places — a bank portal, a WhatsApp thread with the clearing agent, a spreadsheet and a supplier’s invoice PDF — somebody assembles it by hand under a deadline.
One useful piece of automation is available. Section 11.10.11 requires a licensee to disclose, before each transaction, the total cost including fees, the rate and its margin over the reference rate, and the expected delivery time. Captured per payment against the consignment it settles, that becomes a comparison you can run — which route, at what all-in cost, for which supplier — rather than an impression that one channel feels cheaper.
Practical business implications
Six questions, answerable this month.
- Is the provider licensed for this activity? Ask for the licence and the activity it names. A general crypto registration, or an SEC-side approval, does not authorise payment use: section 4.10 says listing a token does not authorise paying with it.
- Is the token approved? Ask which Approved Virtual Asset Payment Instrument the provider may use. A brand name is not an answer.
- Who opens the Form M? Still the Authorised Dealer, and the reference has to reach the provider. Decide who owns that handoff before the first payment.
- Where does the payment appear in your records? One line carrying the Form M number, the purpose, the rate and margin disclosed, the provider, and the consignment it belongs to.
- If you export, where do the proceeds land? Proceeds in a wallet are not repatriated. They are repatriated on conversion and credit to the export-proceeds domiciliary account inside the prescribed period.
- What is the fallback? Where no licensed route exists for your corridor, the bank route is the route. Price the delay into supplier terms rather than solving it off the books.
A provider operating before 5 November is not automatically shut. Section 54.1 gives existing operators 180 calendar days to apply, registration with the Bank within 30 days, supervisory reporting within 60, and continuation only at existing scale under interim conditions — with cessation required if no complete application is filed in time. So a provider may be trading lawfully today and unable to serve you in six months. Ask where it sits in that window.
RevenueStack perspective
Our view is that this is the clearest regulatory statement yet of something African businesses keep paying to learn: a faster instrument does not relieve you of the documentation attached to the underlying transaction. The same logic ran through the renminbi settlement route, where importers asked about the rate and the answer was the documentation their bank and their supplier each needed.
Read through Strategic Economics, the instructive line is section 10.6.3: the token does not change the treatment of the trade. Payment rails across African markets are being rebuilt quickly — instant rails, interoperable wallets, now tokens — and each is sold on speed. None changes the evidence a transaction must carry. So the durable advantage does not sit with the business that adopts each new rail first. It sits with the business whose purchase file already holds the order, the Form M reference, the payment and the consignment in one place: that business can take a new rail the week it becomes lawful, and the one keeping four partial records cannot take it at all.
That is an unglamorous order and purchasing system question rather than a payments question — and the one that decides who gets the week of cycle time when a licensed route opens.
Conclusion
Nigeria’s virtual asset regulations took effect on 5 November 2026, and for importers they close a grey area rather than open a door. A stablecoin payment for imported goods is a foreign-exchange transaction: it needs a valid Form M, it must run through a provider licensed for that activity using a token the CBN has approved, and routing around those requirements is named as circumvention. Export proceeds are not repatriated until converted and credited to a domiciliary account. The work this month is not to pick a wallet. It is to establish whether any provider in your corridor is actually licensed, and to make sure your own records can produce a Form M reference against a payment and a consignment on request — because the day a lawful fast route opens, that is the only thing standing between you and using it.
Sources
- Regulations for the Operations of Non-Security Virtual Assets in Nigeria (Circular PSP/DIR/PUB/CIR/001/004) — Central Bank of Nigeria, 2026-11-05
- Explainer: What CBN's new crypto rules mean for your wallet, P2P trades and stablecoins — BusinessDay, 2026-11-06
- CBN updates guidelines for stablecoins operation — Vanguard, 2026-11-07
- CBN Bans Interest On Stablecoins, Demands Form M For Import Payments — Leadership, 2026-11-07
- Nigeria's Trade Surplus Widens to N12.6trn on Higher Exports — Business Post (reporting NBS, Foreign Trade in Goods Statistics Q2 2026), 2026-09-07