CBN Recapitalisation: What Every Nigerian Bank Must Do by 2026
The CBN's sweeping bank recapitalisation directive sets minimum capital floors that will reshape the competitive landscape of Nigeria's entire banking sector.
By Ngozi Eze, Regulatory Affairs Editor · · 7 min read
When the Central Bank of Nigeria issued its March 2024 recapitalisation circular, it set in motion what analysts describe as the most consequential restructuring of the country's banking sector since the consolidation exercise of 2005 under Governor Charles Soludo. The new minimum capital requirements — ₦500 billion for international commercial banks, ₦200 billion for national commercial banks, and ₦50 billion for regional commercial banks — are between five and ten times the previous thresholds and carry a compliance deadline of March 2026.
The directive has triggered a flurry of corporate activity. Several mid-tier banks have entered merger discussions: Unity Bank and Providus Bank announced a merger agreement in early 2024, and Keystone Bank is reportedly in advanced talks with two smaller regional lenders. The CBN has encouraged consolidation as a preferred route, viewing larger, better-capitalised institutions as more resilient to external shocks and better positioned to fund Nigeria's infrastructure deficit.
For Tier-1 banks — Access, Zenith, GTCO, UBA and First Bank — the challenge is significant but manageable. All five launched public offers or rights issues in 2024 to raise fresh equity, collectively targeting over ₦1.5 trillion from capital markets. Market appetite was robust: Access Holdings' ₦351 billion offer was oversubscribed by domestic institutional investors, pension funds and diaspora retail participants.
Smaller banks face a starker choice. Regional banks with existing capital well below the new floors must either raise fresh equity (difficult given thin capital markets outside Lagos), merge with stronger partners, or downgrade their licence category — a move that limits geographic reach but reduces the capital requirement to ₦20 billion for state-licensed microfinance banks.
The exercise will almost certainly reduce the number of CBN-licensed commercial banks from 26 to somewhere between 15 and 18, according to projections from FSDH Merchant Bank. What remains less certain is the fate of the country's 900+ microfinance banks, where capital shortfalls are endemic, regulatory infractions are common, and the CBN has signalled that its patience for non-compliance is exhausted. A sweeping audit of microfinance institutions is expected to trigger further licence revocations through 2025.