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The Collapse of FTX

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By Oluseyi Akindeinde

FTX recently valued at $32 billion dollars, has filed for Chapter 11 bankruptcy protection in the US. The filing in Delaware federal court on Friday 11th November, 2022 included the main FTX international exchange, FTX US a US crypto marketplace, Sam Bankman-Fried’s proprietary trading group Alameda Research and about 130 affiliated companies.

In this piece I try to dissect what went wrong at FTX, and discuss possible ramifications for the crypto industry.

The Players

  • Sam Bankman-Fried aka SBF (The self proclaimed Crypto White Knight and member of the inner caucus. Darling of Washington DC).
  • Caroline Ellison aka CE (His Girlfriend).
  • Changpeng Zhao aka CZ (The Outcast Dark Crypto Lord).

The Entities

  • Alameda Research (AR). The Trading company founded and OWNED by SBF but managed by CE. Revenue earned through market making (ie providing liquidity to crypto exchanges) as well as trading/speculating on cryptocurrency futures using a high degree of leverage.

– FTX (FTX.com). Cryptocurrency

Futures Exchange (brokerage and derivatives platform) OWNED and CONTROLLED by SBF. Revenue earned through customer transaction fees who trade and speculate on cryptocurrency futures and derivatives(day traders). The trading platform was called FTXPro.

–  Binance. A rival crypto Exchange OWNED & CONTROLLED by CZ. The Biggest cryptocurrency spot exchange in the world by volume.

Quick Summary

  • AR and FTX were meant to be separate entities even though they were founded by the same person SBF.

–             FTX had a market-cap (networth) of $32 billion having raised funding from well known

VCs in Silicon Valley including Sequoia Capital.

  • AR allegedly owed FTX $8 billion after taking loans apparently funded by deposits of FTX customers.
  • AR used these borrowed funds to trade cryptocurrencies with leverage and also to bail out struggling crypto companies (Voyager and BlockFI) who had liquidity issues.

–            FTX declared bankruptcy with loads of customer funds gone with it.

How Money Disappeared – Summary

–             SBF founded AR and FTX.

–             FTX also issued FTT tokens which they gave to early investors that included AR.

–             As an exchange, customers deposited their funds on FTX to trade with.

–             SBF basically gave these customer deposits to AR as loans to be used for their trading activities and in return accepted FTT tokens (originally issued by FTX) as collateral for the loan.

–  A report then came out that pointed out that AR’s balance sheet was basically made up largely of FTT tokens issued by FTX.

– CZ (who once bought a stake in FTX but later divested because he had a bone to pick with SBF) upon getting wind of this development announced he would de-risk his entire $500M of FTT position.

  • On the back of this, other customers also started to dump their FTT tokens and immediately started withdrawing their funds on FTX. It led to a bank run.
  • AR then started selling assets presumably on other exchanges to send back to FTX to shore up capital in order to meet the customer shortfall.
  • When SBF realized the liquidity squeeze, he then reached out to CZ for a bail out of FTX wherein CZ accepted the offer of bail out subject to corporate due diligence.
  • CZ later pulled out of the deal because his due diligence on FTX had come up short.
  • FTT price tanked as FTX had no liquidity in reserve to meet customer withdrawal obligations and subsequently paused withdrawals.

–             From being illiquid, FTX became insolvent since the value of the collateral held (FTT) had fallen below the value of their liabilities.

  • SBF basically thought he could print money (FTT) out of thin-air using FTX as the mechanism and use it as collateral against real assets.
  • FTX, AR and SBF filed for bankruptcy protection post- haste.

How Money Disappeared – Details

Background

  • SBF, an MIT physics graduate and a former Wall Street futures trader made a lot of money trading crypto arbitrage. He founded AR but gave CE the reins of power when he founded FTX a crypto futures and derivates trading company.
  • FTX as part of its operations issued a token called FTT. It is like airline miles or reward points as you don’t get any ownership stake in FTX itself.
  • FTT token allowed the holder to obtain discounts on trading fees when they trade on FTXPro. It could also be pledged as collateral for futures trading on FTXPro.
  • FTX used a portion of profits (trading fees) generated to buy back and burn a portion of FTT in circulation.
  • So indirectly FTT token was tied to the profitability of FTX – that is the more profitable FTX was, the more FTT tokens FTX would buy back leading to an increase in the price of the FTT tokens (the reverse was also the case if FTX wasn’t profitable).

–             Burning FTT would also lead to reducing its supply which further increases its price. This also made FTT behave somewhat like a company stock. But it wasn’t legally a stock.

–             There were over 400,000 holders of FTT at the last count.

–             Word got out about AR’s balance sheet which had $14.6 billion but it’s biggest asset was

$3.7bn worth of “unlocked FTT” and its other biggest asset was

$2.2bn worth of FTT that were pledged as collateral. Basically nearly half of AR’s balance sheet was made up of FTT tokens – an asset created by FTX.

  • AR’s balance sheet liability also carried $7.4bn worth of liabilities (loans).
  • From purely a risk management point of view, this was rather bad because AR was using it’s own equity as collateral for borrowed money. If the company became unprofitable, this would be bad in itself but if the collateral (FTT tokens) backing those loans were to fall in value, this would become a disaster for AR.

Relationship Between FTX and AR

  • SBF founded both companies. FTX being the exchange. AR was the trading company using FTX to conduct its trading activities.
  • FTX and AR claimed they were completely separate entities. Speculation however started to spread on social media that the two companies were one and the same and customer funds on FTX were finding their way to AR behind the scenes.

–  It was later gathered that FTT token’s price was being propped up by AR. Not only that, AR was further using FTT it got issued by FTX as collateral to the same FTX to fund its own operations.

– It was bad enough that AR carried a lot of illiquid assets on their books (FTT), it became even worse when FTX started giving a huge portion of their customer funds to AR as loans which were collateralised and secured by the very same FTT tokens issued by FTX.

–  Remember that FTX issued FTT tokens in the first place. So, they were getting back what they issued as collateral. Like plugging an extension plug into itself. Simply means if the price of FTT went down, FTX would be seriously impacted.

Crisis Brewing

  • FTX’s primarily business was being a broker dealer. They were listing and selling

perpetual crypto futures and allowing AR and other traders/ speculators to trade crypto derivatives often with huge leverage.

  • As a result, they needed a reserve of money to lend to AR and speculators.
  • And because FTX and AR were one and the same, customer funds deposited on FTX were diverted to AR for leveraged trading operations.
  • Once suspicion started to filter

through that FTX didn’t have enough crypto on hand to honour all customer withdrawals, customers started demanding for their funds and FTX started having liquidity issues as there wasn’t enough reserve on hand to meet up with customer’s withdrawals.

  • AR in turn started withdrawing funds (stable coins and crypto)

they had on other exchanges to send to FTX. This served to further confirm that FTX was really facing a liquidity crisis.

Denials

  • SBF denied the liquidity crisis and basically said everything was fine and customer funds were intact. He even claimed it was all the work of competitors trying to spook them.
  • At the same time CE (who ran AR) took to twitter to say that AR had $10bn in liquidity not reported on the balance sheet.

Enter CZ

  • CZ who was a former investor in FTX had over $500M worth of FTT. It was paid in part as

settlement when CZ divested from FTX in 2021.

  • Actually SBF bought back CZ’s stake in FTX and paid him $2.1bn in BUSD and FTT tokens.
  • When CZ got wind of the report of AR’s balance sheet and its asset makeup, he made a public declaration to offload his entire $500M worth of FTT in what he called a “de-risking” process.
  • This piece of public declaration naturally spooked the markets as speculators who held FTT tokens started de-risking (selling) as well.

 

The Death Spiral

  • With speculators selling, FTT price began to plummet.
  • It was made worse when CE incredibly made a public offer to CZ that AR were willing to buy Binance’s entire FTT stake at $22 each over-the-counter.
  • This further fuelled the fire that AR and FTX were using FTT as collateral for crypto loans and feared getting liquidated.
  • This caused hundreds of millions of dollars in FTT liquidations on FTX and because

of low liquidity it further crashed the price. AR and FTX also started selling off the other crypto assets they held to prevent FTX from collapsing.

This caused other cryptocurrency prices to tank. A ripple effect.

  • Traders also started rushing to pull their funds off FTX exchange for fear that the exchange would collapse. This essentially led to a bank run.

The Aborted Rescue Mission

  • People just couldn’t believe that FTX, a company that had raised a combined $1.8bn in VC money could be facing insolvency.
  • The unthinkable then happened – SBF publicly reached out to CZ and asked to be bailed out.
  • CZ accepted by signing a non- binding letter of intent (LoI) to buy FTX pending due diligence.

This served to further confirm that FTX was indeed neck deep in trouble.

  • The following day, however, CZ through Binance made it known that they wouldn’t be taking up the offer of buying FTX as the issues were simply too many.

FTX had failed their process of corporate due diligence.

Binance also cited risks related to pending regulatory investigations on FTX and reports of internal FTX funds mismanagement.

  • FTX then paused withdrawals of customer funds. There was already an $8bn shortfall.
  • SBF attempted a last ditch effort at raising funds but no offer of a bail-out was forthcoming.

Bankruptcy Filing

  • FTX and AR are now insolvent and SBF has filed for Chapter 11 bankruptcy protection.
  • They imploded in a wave of scuttlebutt and were brought down in truly exceptional circumstances.
  • The fallout of this is still unravelling and will most likely take a few months to sort out. Until then there will still be blood on the crypto streets so tread with caution. Brace yourselves for more bloodbath.
  • A lot of people lost loads of money on FTX. Here’s a Never leave your funds on an Exchange. Get a non-custodial wallet and move your funds there. Exchanges are centralized entities.

Wrap up

Naturally people will be more skeptical of crypto but this, in fact isn’t crypto problem.

This was caused by a few self- absorbed, irresponsible and incompetent individuals like SBF and CE running centralised entities engaging in blackbox-like business practices, mis-using customer funds to run opaque financial institutions under a cloak of invincibility with no oversight regulation.

These guys basically ran a huge fraudulent operation which could have gone undetected for a long time.

The system needs sanitization. Some regulation needs to be enforced to bring a semblance of order to the industry.

A lot of Nigerians lost money in this debacle and I truly sympathize with you if you did. These are truly extraordinary times.

At the end of the day nothing is wrong with crypto. It’s just a medium and a tool in the hands of nefarious individuals. Going forward though, always remember: Not your keys. Not your coins.

I round off with these words from CZ

Oluseyi Akindeinde is the Chief Technology Officer, Digital Encode.


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E-Financial

GTCO Secures Regulatory Approvals to Raise N10bn in Private Placement

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Guaranty Trust Holding Company Plc (“GTCO) has obtained the approvals of both the Central Bank of Nigeria (CBN) and the Securities and Exchange Commission (SEC) to undertake a private placement of its ordinary shares, subject to the fulfilment of the applicable conditions precedent and regulatory requirements.

The Financial Holding Company had earlier on August 29, 2025 announced that its banking subsidiary (Guaranty Trust Bank Limited) had satisfied and surpassed the new CBN minimum capital requirement for commercial banks with international authorisation, having already increased its capital to N504.037 billion.

The Company has entered into an arrangement, in connection with a best efforts private placement for gross proceeds of up to N10 billion from the sale of up to 125,000,000 of the ordinary shares of the Company at N80 per share”.

This private placement in the sum of N10billion is being raised pursuant to Section 7.1 of the Guidelines for Licensing and Regulation of Financial Holding Companies (FHCs) in Nigeria regarding the computation of the capital of FHCs.

According to a statement signed by the company’s Group General Counsel/Company Secretary, Erhi Obebeduo, the proposed private placement is being undertaken pursuant to the company’s shareholders’ resolution passed at its Annual General Meeting held on 9 May 2024 which authorised the Board to establish a capital raising programme of up to $750,000,000 or its equivalent through the issuance of ordinary shares, preference shares, convertible and/or non-convertible bonds or any other instruments, whether by way of a public offering, private placement, rights issue, book building process or any other method or combination of methods in such tranches, and at such dates and upon terms and conditions as may be determined by the Board.

The statement further read that, “As a result of this, the Board has authorised the Company to embark on a private placement to raise N10,000,000,000.00 (Ten Billion Naira only), by the allotment of 125,000,000 (one hundred and twenty-five million) ordinary shares of 50 Kobo each (the “Private Placement”).

The Offering is scheduled to close on December 31, 2025 (the Closing Date) and is subject to certain conditions, including, but not limited to, receipt of all necessary approvals.

 


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Nigeria’s N58.18trn Budget and Rising Cost of Deficit Governance

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By Blaise Udunze

When President Bola Tinubu presented the N58.18 trillion 2026 Appropriation Bill to the National Assembly, unbeknownst to some, it opened with a contradiction that should unsettle even its most optimistic readers. It is an irony that a budget promises consolidation, renewed resilience, and shared prosperity, at the same time, it is built on a deficit of N23.85 trillion, as the largest budget in the nation’s history, equivalent to 4.28 percent of GDP, financed largely through borrowing, and debt servicing alone will consume N15.52 trillion, nearly half of the projected revenue.

Nigeria’s N58.18trn Budget and Rising Cost of Deficit Governance

President Tinubu

What a contradiction! The reality today is that Nigeria is borrowing not primarily to expand productive capacity or unlock long-term growth, but to keep the machinery of the state running. Salaries, overheads, inherited liabilities, and interest payments increasingly define the purpose of new debt. Capital formation, though loudly advertised, struggles to keep pace with fiscal reality. This raises a fundamental and unavoidable question. How sustainable is a fiscal model where debt service crowds out development spending year after year? Until this question is convincingly answered, no amount of reform rhetoric can restore confidence in Nigeria’s budgeting process.

A Nation Drowning in Deficits and Debt

The problem with the deficit is that it is not a number by itself. It shows that there are problems with the way things are set up. By the middle of 2025, Nigeria owed a lot of money, N152.4 trillion, which represented about a 348.6 percent increase following the assumption of President Bola Tinubu into office in 2023. Before he assumed office, the country owed N33.3 trillion, and this is a country that was already having trouble paying for basic things it needed to.

Reflecting on Nigeria’s predicament, it mirrors a wider African crisis. Reviewing the occurrences across the continent of Africa, external debt now surpassed $1.3 trillion, while the debt servicing costs are estimated at $89 billion this year alone. Nigeria’s case is unique not because of the amount of debt, but because of its poor productive return. The lingering challenge is that Nigeria’s borrowing has skyrocketed, yet the economy remains conspicuously faced with fragile infrastructure. The fiscal irony is stark that Nigeria is borrowing to survive, not to thrive.

A Deficit-Fuelled Budget and the Rising Cost of Survival

Deficits can be useful tools when deployed strategically. But Nigeria’s deficits have become structural, persistent, and increasingly divorced from growth outcomes. The N23.85 trillion deficit in the 2026 budget represents a dramatic escalation from the N11-N12 trillion range of recent years. Analysts warn that this is no longer a counter-cyclical policy; it is a sign of fiscal stress. Tilewa Adebajo, Chief Executive Officer of CFG Advisory, describes Nigeria’s fiscal space as “the biggest threat to our economic recovery.” According to him, the country continues to expand its budget despite failing to meet revenue targets. “We cannot have a N23 trillion deficit, that’s not sustainable,” he warned, noting that deficits have doubled in just a few years. More troubling is what the deficit implies. With N15.52 trillion earmarked for debt servicing, nearly half of the projected revenue is already spoken for before development spending begins. Some estimates suggest that over 25 percent of Nigeria’s annual revenue now goes directly into debt servicing, and in certain months, the ratio rises far higher. Experts warn that when over 90 percent of revenue is consumed by old debts, governance becomes an exercise in survival rather than progress. This is the fiscal corner Nigeria is steadily backing itself into.

Borrowing to Run Government, Not to Build the Economy

Between July and October 2025 alone, Nigeria secured over $24.79 billion in new borrowings, alongside €4 billion, ¥15 billion, N757 billion, $500 million in sukuk, and other facilities, most justified as “development financing.” Yet the real sector continues to wait for a tangible impact. The African Democratic Congress (ADC) argues that a budget planning to generate N34 trillion in revenue while borrowing nearly N24 trillion amounts to an admission of fiscal insolvency. A deficit-to-revenue ratio approaching 70 percent, it insists, would be unacceptable in any functional fiscal system. While opposition language is often sharp, the underlying concern is valid. Borrowing makes economic sense only when it finances self-liquidating projects like investments that generate revenue to repay the loans. Instead, Nigeria increasingly borrows to service past debts and plug recurrent expenditure gaps. Uche Uwaleke, Professor of Finance and Capital Markets at Nasarawa State University, underscores the danger: “Nigeria’s debt service ratio is inimical to economic development, chiefly because what could have been used to build infrastructure and invest in human capital is used to service debt. The opportunity cost for the country is high.” In effect, debt has shifted from a development instrument to a fiscal life support system.

Revenue Projections Caught Between Reform Ambition and Structural Limits

The Nigerian government projected N34.33 trillion in revenue for 2026, which is squarely anchored on improved oil output, non-oil tax reforms, and digitised revenue mobilisation across Government-Owned Enterprises (GOEs). To actualize its target, President Tinubu vowed to clamp down on leakages, enforce performance targets, and deploy real-time monitoring systems. Though these reforms are necessary. The question is whether they are sufficient and timely. Recent performance suggests caution. As at Q3 2025, only 61 percent of revenue targets had been achieved. Capital releases lagged sharply, and comprehensive implementation reports have not been published. Ayokunle Olubunmi, Head of Financial Institutions Ratings at Agusto & Co., expressed doubts about the credibility of the projections, citing weak performance in 2024 and 2025. “We don’t even know how many budgets we are implementing now,” Olubunmi observed, pointing to overlapping cycles and missing reports. The ADC goes further, describing revenue projections as detached from reality, while noting that revenue growth in 2024 was largely driven by currency devaluation, not structural expansion, before being doubled for 2025 and increased again for 2026. Nominal gains, it argues, are being mistaken for real fiscal strength. Without deep structural reforms, reliable power, export diversification, and productivity growth, revenue expansion risks remaining inflationary and fragile, unable to support the scale of spending proposed.

Budget Execution and the Credibility Gap

President Tinubu has declared 2026 a turning point. He promised an end to overlapping budgets, abandoned projects, and perpetual rollovers. All prior capital liabilities, he said, will be closed by March 31, 2026, ushering in a single budget cycle. Yet Nigeria’s execution record invites skepticism. The Coalition of United Opposition Political Parties (CUPP) points out that no comprehensive 2025 budget implementation report has been published, the first such lapse in 15 years. Quarterly performance reports, once routine, have been withheld, violating fiscal responsibility norms. “How can a new budget be proposed when the performance of the current one remains unknown?” CUPP asked. Execution failure is not cosmetic; it is costly. Projects stall, costs balloon, and borrowed funds yield no returns. Without transparency and enforcement, discipline risks becoming a slogan rather than a system.

Capital Spending vs the Persistent Cost of Governance

The N26.08 trillion allocated to capital expenditure is one of the budget’s most advertised strengths, with infrastructure, agriculture, education, and health featuring prominently. Yet Nigeria’s history cautions against equating allocations with outcomes. Recurrent non-debt expenditure remains high at N15.25 trillion, reflecting a governance structure that consumes significant resources. Ministries, departments, agencies, and political overheads continue to limit fiscal space. Mr. Idakolo Gbolade of SD&D Capital Management acknowledges the budget’s ambition but warns that over 70 percent of capital expenditure may be carried over into 2026. This suggests that implementation bottlenecks remain unresolved. Borrowing to fund capital projects that are delayed or abandoned compounds fiscal inefficiency. Nigeria risks paying interest on infrastructure that exists only on paper. Until the cost of governance is structurally reduced, capital spending will struggle to deliver transformative impact, regardless of headline figures.

Security Spending at Scale, But Lacking Clarity

Security receives the largest sectoral allocation, N5.41 trillion, alongside a new national counterterrorism doctrine targeting all armed non-state actors. The administration argues, correctly, that without security, investment cannot thrive. On the contrary, Nigeria’s experience shows that security spending does not automatically translate into security outcomes. Over the years, allocations have risen while insecurity persists across multiple regions. The challenge is not merely funding, but accountability, coordination, and effectiveness. Without transparency in procurement and deployment, security budgets risk becoming opaque sinks for public funds, undermining the very growth assumptions embedded in the budget.

Shared Prosperity Under Pressure

Though the budget promises shared prosperity, citing allocations of N3.52 trillion for education and N2.48 trillion for health, alongside agricultural and infrastructure investments, and with the National Bureau of Statistics announcement that inflation has moderated, and growth has improved modestly. Yet for ordinary Nigerians, relief remains elusive. Food prices are high, transport costs elevated, and real incomes squeezed. Social sector spending still struggles to keep pace with population growth. Shared prosperity cannot remain an aspiration deferred to the future. It must translate into jobs, affordable food, functioning schools, accessible healthcare, and rising real incomes.

Borrowing Without Beneficiaries

At the 2025 IMF and World Bank Annual Meetings in Washington, D.C., global leaders again pledged to address developing countries’ debt burdens. But as Nigeria continues to issue Eurobonds, sukuk, and bilateral loans, a simple question demands attention: who benefits from all this borrowing? If the answer is not citizens, businesses, and future generations, then the debt is not development finance; it is deferred hardship.

When Deficits Become Destiny

The 2026 budget reflects an administration aware of Nigeria’s fiscal dysfunctions and eager to correct them. The language of discipline, digitisation, and delivery signals intent. But credibility is not declared; it is earned. A deficit-driven budget that leans heavily on borrowing, struggles with revenue realism, and carries unresolved execution gaps places Nigeria on a narrow fiscal path. If borrowing is decisively tied to self-liquidating projects, transparency restored, and governance costs reduced, the budget could mark a turning point. If not, it risks confirming a grim truth as Nigeria is financing today by mortgaging tomorrow. Until debt stops crowding out development and revenue begins to fund governance rather than merely service it, deficits will no longer be temporary tools. They will become destiny.

Blaise, a journalist and PR professional, writes from Lagos and can be reached via: [email protected]


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Banks quietly move to enforce new ₦50 transfer levy from Jan. 1

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A new ₦50 charge on electronic money transfers above ₦10,000 is to take effect from Jan. 1, 2026, following preliminary system adjustments observed across several banking platforms ahead of the New Year.

Banks quietly move to enforce new ₦50 transfer levy from Jan. 1

CBN

The levy, tied to government stamp duty regulations, is separate from and in addition to regular bank transfer fees already borne by customers.

Industry sources told the News Agency of Nigeria (NAN) on Friday in Lagos that while existing bank charges would remain unchanged, customers initiating qualifying transfers would now pay both their normal transfer fees and the extra ₦50 stamp duty per transaction.

In a major shift to the current practice, the ₦50 levy which was previously borne by receivers of funds will now be paid by senders.

This implies that for every electronic transfer above ₦10,000, the sender will bear the full cost of the stamp duty alongside the standard transaction fees charged by their bank.

According to the emerging charge structure sighted on some banking platforms, the new levy applies only to transactions above ₦10,000 and will be deducted on a per-transaction basis.

Transfers below ₦10,000 remain exempt, while movements of funds between accounts owned by the same individual within the same bank are also not affected.

Analysts, however, warn that for millions of Nigerians who rely on frequent small-value transfers to meet daily needs, the additional government charge, layered on existing banking costs, could deepen financial strain for households already operating on thin margins.

Customers have in recent weeks raised concern over what they describe as a steady rise in transaction-related deductions, noting that the quiet rollout of the new ₦50 levy has heightened anxiety.

They observed that January is traditionally one of the most financially challenging months for households, driven by school fees, rent renewals, food inflation and post-holiday obligations, and questioned the timing and limited public communication around a change that directly affects routine financial activity.

Digital transfers have become central to everyday life in Nigeria, underpinning business settlements, informal trade, family remittances and emergency support.

With more than 70 per cent of transfers estimated to fall below ₦20,000, financial experts say the cumulative impact of a ₦50 charge on each qualifying transaction, when combined with existing bank fees, will significantly raise monthly transaction costs for individuals and micro and small enterprises.

For many Nigerians, the concern extends beyond the levy itself to the broader pattern of rising financial pressure that has eroded household resilience over time.

They point to the combined weight of escalating food prices, high transportation costs, stagnant incomes and a range of service charges that, in their view, “pile up quietly in the background”.

Stakeholders fear that introducing an additional government-backed charge at the start of the year, and doing so with minimal public sensitisation, may reinforce perceptions that more cost-heavy policies could be introduced in 2026 without adequate engagement or clarity.

“Why is such a significant cost being quietly introduced at the start of the year? Why was there no widespread announcement or public sensitisation? And what other policy shifts might be coming that Nigerians have not yet been informed about?” one Lagos-based small business owner asked in a chat with NAN.

As Jan. 1 approaches, many households say they are bracing for yet another financial burden in an economy where, for them, every naira already feels stretched beyond its limit.

They called on relevant authorities and regulators to provide clear guidance on the new charge structure, explain its legal basis, and ensure that customers are adequately informed about how it will affect their daily transactions.


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