Highlights Of The Guidelines Letters Circulars And Notifications Issued In January 2026

Dear Esteemed Client,

The Nigerian Communications Commission ('NCC'), the National Pension Commission ('PenCom'), the Nigeria Revenue Service ('NRS'), the Financial Reporting Council of Nigeria ('FRCN'), the Securities and Exchange Commission ('SEC'), the Central Bank of Nigeria ('CBN'), The National Insurance Commission ('NAICOM'), the Federal Competition and Consumer Protection Commission ('FCCPC') and the Federal Government of Nigeria ('FGN') issued a series of Press Releases, Circulars, Directives, and Guidelines in January, 2026 containing information and directives for various sectors and the general public. We hope that you find the information useful in your operations.

NCC AND CBN TO IMPLEMENT REFUND FRAMEWORK FOR FAILED AIRTIME AND DATA TRANSACTIONS

The NCC and CBN have jointly developed a framework to address consumer complaints arising from failed airtime and data transactions, when subscribers are debited without receiving value. The framework, created after extensive consultations with Mobile Network Operators, Value Added Service providers, Deposit Money Banks, and other stakeholders, establishes enforceable Service Level Agreements ('SLAs'), requires refunds within 30 seconds, or up to 24 hours for pending transactions. It mandates SMS notifications for all transactions, and introduces a jointly hosted Central Monitoring Dashboard to track failures, refunds, and SLA breaches. Implementation is expected to commence on 1st March 2026, subject to final regulatory approvals and technical integration

For more information, please refer here.

FRCN REITERATES FILING REQUIREMENTS FOR PUBLIC SECTOR ENTITIES

On the 5th of January 2026, the FRCN issued a public notice reiterating statutory filing requirements for public sector and public interest entities under the FRCN Act (as amended). Public sector and public interest entities are required to file annual reports and financial statements with the FRCN within 60 days of Board approval while auditors are required to submit qualified reports to the FRCN within 30 days from the date of qualification. The FRCN also warned that noncompliant entities and their officers will be publicly listed and sanctioned.

For more information, please refer here

PENCOM TO ENFORCE APPOINTMENT OF AUDITORS AND ACTUARIES FOR APPROVED EXISTING SCHEMES ('AES') AND ADDITIONAL BENEFITS SCHEMES ('ABS')

PenCom has issued a circular to address persistent noncompliance by Trustees and Sponsor Companies of Approved Existing Schemes ('AES') and Additional Benefits Schemes ('ABS') with statutory requirements under the Pension Reform Act ('PRA') 2014 for the appointment of external auditors and actuaries, following supervisory oversight findings that revealed the Scheme's widespread failure to conduct annual audits and actuarial valuations.

The circular directs Pension Fund Administrators ('PFAs') to notify Trustees/Sponsors of a Scheme at least two (2) months before the end of each financial year to appoint an external auditor and an actuary as applicable, for the conduct of the Scheme's audit and actuarial valuation respectively, issue reminder notices where appointments are not made within 21 days from the receipt of the PFA's letter, and with PenCom's approval, appoint an external auditor and an actuary on behalf of defaulting Schemes, with approved fees charged to the Schemes if no official response is received from the Scheme after 5 days of issuance of the reminder notice. The directive takes immediate effect and is aimed at strengthening governance, ensuring regulatory compliance, and safeguarding the long-term viability of pension obligations

For more information, please refer here

NCC COMMENCES PUBLIC CONSULTATION ON SATELLITE DIRECT-TO-DEVICE ('D2D') CONNECTIVITY

The NCC is seeking stakeholder input to better understand the potential opportunities, risks and public-interest considerations related to Satellite Direct-to-Device ('D2D') connectivity in Nigeria. The consultation is an initial engagement aimed at informing the Commission's understanding of Satellite D2D connectivity in Nigeria before any formal rule-making process is initiated under the Nigerian Communications Act, 2003.

The NCC clarified that the consultation does not constitute a regulatory decision, licensing process, or spectrum allocation, nor does it predetermine any policy outcome. Feedback will guide any future, proportionate, and marketresponsive regulatory framework. Stakeholders are invited to review the Consultation Paper and submit their responses via the prescribed online form on or before 23rd February, 2026. For more information, please refer here.

NRS CLARIFIES THAT VAT ON BANKING FEES WAS NOT INTRODUCED BY THE NIGERIA TAX ACT, 2026

The NRS by a press release dated 15th January 2026 clarified that VAT has always been applied to fees for services rendered by banks and other financial institutions under Nigeria's existing VAT regime, and that the Nigeria Tax Act did not introduce any new VAT obligations on bank charges. The NRS urged the public and stakeholders to disregard any misinformation and rely solely on official communications for accurate and authoritative information on tax.

For more information, please refer here

SEC ISSUES CIRCULAR ON REVISED MINIMUM CAPITAL REQUIREMENTS

Pursuant to the Investments and Securities Act 2025, SEC issued a circular dated 16th January 2026, revising the minimum capital requirements for all regulated capital market entities in Nigeria. The revision is aimed at strengthening market resilience, enhancing investor protection, and aligning capital adequacy with the evolving risk profile of capital market activities.

The revised requirements apply across all categories of SEC-regulated entities, including capital market operators, market infrastructure institutions, FinTechs, virtual asset service providers, and commodity market intermediaries. The circular introduces updated capital thresholds and supersedes the 2015 minimum capital requirements where applicable.

Affected entities are required to comply on or before 30th June 2027, with transitional arrangements to be considered on a case-by-case basis. The circular takes effect from the date of its publication

For more information, please refer here

FCCPC COMMENCES ENFORCEMENT OF DIGITAL LENDING REGULATIONS

The FCCPC has begun enforcing the 2025 Digital, Electronic, Online and NonTraditional Consumer Lending (DEON Regulations), against digital money lenders that failed to regularise their status by 5th January, 2026. The enforcement actions, undertaken in line with the Commission's statutory mandate, include the withdrawal of conditional approvals, removal of non-compliant operators from the FCCPC's published register of approved digital lenders, and structured engagements with application hosting platforms and payment service providers to support compliance monitoring.

Operators provisionally eligible under transitional arrangements have until April 2026 to comply or face further regulatory action. The DEON is designed to ensure regulatory certainty, strengthen market discipline and transparency, boost consumer confidence, protect consumers from abusive or unlawful practices, and shield compliant operators from unfair competition in Nigeria's digital lending market.

For more information, please refer here.

CBN GRANTS TEMPORARY DISPENSATION FOR USE OF EXPIRED NAFDAC LICENCES IN FORM M PROCESSING

The CBN has approved a two-month temporary dispensation, permitting the use of the National Agency for Food and Drug Administration and Control ('NAFDAC') licences that expired on 31st December 2025 for the processing of Form M on the CBN Single Window. This applies to importers of goods denominated in foreign currency and is valid until 28th February, 2026.

The dispensation addresses challenges caused by the transition from the Nigeria Integrated Customs Information System II (NICIS II) and difficulties in renewing or validating licences on B'Odogwu. During this period, Authorised Dealer Banks are to continue accepting the expired licences to ensure uninterrupted trade while NAFDAC completes its integration with the National Single Window

For more information, please refer here.

NAICOM ISSUES NEW GUIDELINES ON LICENSING AND RENEWAL OF INSURANCE INSTITUTIONS

The NAICOM has issued revised Guidelines on the Licensing and Renewal of Insurance Institutions' Licences in Nigeria, setting out clear requirements for licensing, renewal, and ongoing compliance across the insurance industry. The Guidelines apply to insurance and reinsurance companies, brokers, agents, insurtech firms, and related operators, and establish minimum standards for capitalisation, governance, operational readiness, and consumer protection, along with defined processes and timelines for applications and renewals. The Guidelines take effect from January 2026 and intends to promote regulatory certainty, market discipline, and consumer confidence in Nigeria's insurance sector.

For more information, please refer here.

NIGERIA REMOVED FROM EU LIST OF HIGH-RISK THIRD COUNTRIES FOR MONEY LAUNDERING AND TERRORISM FINANCING

The European Union ('EU') has removed Nigeria from its list of high-risk third countries for money laundering and terrorism financing. This development follows Nigeria's removal from the Financial Action Task Force ('FATF') grey list in 2025 and reflects the EU's alignment with recent FATF determinations. According to the European Commission, the update reflects decisions taken at the FATF's June and October 2025 plenary meetings, during which several countries were removed from the list of "Jurisdictions under Increased Monitoring."

The European Commission confirmed that Nigeria has substantially enhanced the effectiveness of its AML/CFT framework and has adequately remedied the technical and strategic deficiencies identified by the FATF. The development is expected to enhance Nigeria's global financial credibility, ease enhanced due diligence requirements for transactions with European counterparts, improve investor confidence, and further integrate Nigeria into the international financial system, while reaffirming the country's commitment to sustaining AML/CFT reforms in line with global best practices.

For more information, please refer here.

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.