January 19, 2026/CSL Update

The Securities and Exchange Commission (SEC) has granted capital market operators an 18-month window to recapitalise following the revision of minimum capital requirements, which replaces the previous framework introduced in 2015. The regulator cautioned that non-compliance could result in the suspension or withdrawal of licences, although transitional arrangements may be considered on a case-by-case basis.

Under the new capital framework, core regulated functions will see substantial increases in minimum capital requirements: brokers handling client execution must now maintain a capital base of ₦600 million, up from ₦200 million; dealers engaged in proprietary trading are required to hold ₦1 billion, up from ₦100 million; broker-dealers, which provide combined services (including client execution, proprietary trading, margin/securities lending, and advisory), must now have ₦2 billion, compared with ₦300 million previously; and inter-dealer brokers are now required to hold ₦2 billion, up from ₦50 million.

For non-core regulated functions, the minimum capital for issuing houses that provide non-underwriting services has increased from ₦200 million to ₦2 billion, while issuing houses offering full underwriting services must now maintain ₦7 billion. Standalone underwriters are required to hold ₦5 billion in capital, up from ₦200 million. For portfolio managers, the revised requirements introduce a tiered structure: Tier 1 portfolio managers (full scope) must raise their capital from ₦150 million to ₦5 billion, and Tier 2 managers (limited scope) must increase from ₦150 million to ₦2 billion.

We note that the sharp increase in minimum capital requirements, rising by more than 30x for some market participants, is intended to strengthen the resilience of the capital market and is consistent with broader recapitalisation efforts across the financial system, including banking, insurance, and pensions. While the directive was largely anticipated, the magnitude of the increase is likely to drive industry consolidation through mergers, acquisitions, or licence downgrades, particularly among smaller operators, while larger players are expected to be better positioned to meet the new thresholds.

Click here to download full report:​ CSL Nigeria Daily-19 January 2026- Capital markets.pdf​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​