E-Financial
The Missing Pieces in Nigeria’s Banking Recapitalisation
By Blaise Udunze
Nigeria’s economy will be experiencing yet another round of reform; after the new tax implementation, the banking sector recapitalisation exercise will begin within less than three months until the March 31, 2026, deadline. The Central Bank of Nigeria (CBN) Governor, Olayemi Cardoso, disclosed that 27 banks have tapped the capital market via public offers and rights issues.
The figures show that of 21 the 37 commercial, merchant, and non-interest banks in the country have met or exceeded the revised minimum capital thresholds of N500 billion for internationally authorised banks, N200 billion for national banks, N50 billion for regional banks, and N10-20 billion for non-interest banks. With the developments above, policymakers are betting that stronger balance sheets will help banks withstand macroeconomic shocks, finance growth, and restore confidence in the financial system. On the surface, the logic is sound, capital matters. But history warns us that capital alone is not a cure-all.
Nigeria has been here before, going by the 2004-2005 era of the then-governor of CBN, Charles Soludo, whose banking consolidation dramatically reduced the number of banks from 89 to 25 and created national champions. Yet barely five years later, the system was back in crisis, requiring regulatory intervention, bailouts, and the creation of the Asset Management Corporation of Nigeria (AMCON) to absorb toxic assets. The lesson here is clear, which revealed that recapitalisation that ignores structural weaknesses merely postpones failure.
If the current exercise is to succeed, the CBN must use it not only to raise capital but to repair the deeper fault lines that have long undermined the stability, credibility, and effectiveness of Nigeria’s banking sector.
More Capital isn’t Always Better Capital
The first and most critical issue is the quality of capital being raised. Disclosures made by the banks have shown that the combined capital base of about N5.142 trillion is already locked in by lenders across the different licence categories. Bigger numbers on paper mean little if the capital is not genuinely loss-absorbing. In past recapitalisation cycles, concerns emerged about funds being raised through related parties, short-term borrowings disguised as equity, or complex arrangements that ultimately recycled the same risks back into the system.
This time, the CBN must insist on transparent, verifiable sources of capital. Every naira raised should be traceable, free from conflicts of interest, and capable of absorbing real losses in a downturn. Otherwise, recapitalisation becomes an accounting exercise rather than a resilience-building one.
Why Corporate Governance Remains the Achilles’ Heel
Perhaps the most persistent weakness in Nigeria’s banking sector is corporate governance failure. Many bank crises have not been caused by macroeconomic shocks alone, but by poor board oversight, insider abuse, weak risk culture, and excessive executive power.
Recapitalisation provides a rare regulatory leverage point. The CBN should use it to reset governance standards, not just capital thresholds. Boards must be independent in substance, not just in form. Being one of the critical aspects of the banking challenge, insider lending rules should be enforced without exception. Risk committees in every financial institution must be empowered, not sidelined by dominant executives.
Without the apex bank fixing governance, new capital risks become fresh fuel for old excesses.
The Unresolved Burden of Non-Performing Loans (NPLs)
Data from the CBN’s latest macroeconomic outlook showed that the banking industry’s Non-Performing Loans ratio climbed to an estimated 7 percent, pushing the sector above the prudential ceiling of 5 percent. Nigeria’s banking sector continues to be drowned with high volumes and recurring non-performing loans (NPLs), and this is often concentrated in sectors such as oil and gas, power, and government-linked projects. Though with the trend of events, one may say that regulatory forbearance has helped maintain surface stability in the sector, no doubt it has also masked underlying vulnerabilities.
The truth is that a credible recapitalisation exercise must confront this reality head-on. Loan classification and provisioning standards should reflect economic truth, not regulatory convenience. Banks should not be allowed to carry impaired assets indefinitely while presenting healthy balance sheets to investors and the public.
Transparency around asset quality is not a threat to stability; it is a foundation for it.
How Foreign Exchange Risk Quietly Amplifies Financial Shocks
Few risks have damaged bank balance sheets in recent years as severely as foreign exchange volatility. Many banks continue to carry significant FX mismatches, borrowing short-term in foreign currency while lending long-term to clients with naira revenues.
During periods of FX adjustment, these mismatches can rapidly erode capital, no matter how well-capitalised a bank appears on paper. Recapitalisation must therefore be accompanied by tighter supervision of FX exposure, stronger disclosure requirements, and realistic stress testing that assumes adverse currency scenarios, not best-case outcomes.
Ignoring FX risk is no longer an option in a structurally import-dependent economy.
Concentration Risk and the Narrow Credit Base
Another long-standing weakness is excessive concentration risk. A disproportionate share of bank lending is often tied to a small number of large corporates or government-related exposures. While this may appear safe in the short term, it creates systemic vulnerability when those sectors face stress.
At the same time, the real economy, particularly SMEs and productive sectors, remains underfinanced because, over the years, Nigeria’s banks faced significant concentration risk, particularly in the oil and gas sector and in foreign currency exposure, while grappling with a narrow credit base characterised by limited lending to the private sector. This is due to high credit risk and tight monetary policy. Owing to this trend, recapitalisation should therefore be in alignment with policies that encourage credit diversification, improved credit underwriting, and smarter risk-sharing mechanisms, and not the other way round.
Therefore, it will be right to say that banks that grow larger but remain narrowly exposed do not strengthen the economy; they amplify its fragilities.
Risk Management in a Volatile Economy
The recurring inflation shocks, interest-rate swings, fiscal pressures, and external shocks are frequent features, not rare events, which show that Nigeria is not a low-volatility environment.
Currently, the Nigerian banking sector’s financial performance and investment returns are equally affected by various risks, including credit, liquidity, market, and operational risks.
Today, many banks still operate risk models that assume stability rather than disruption. Time has proven that risk management is essential for mitigating these risks and ensuring stability and profitability.
The apex bank must ensure that the recapitalisation process mandates robust, Nigeria-specific stress testing, and banks must demonstrate resilience under severe but plausible scenarios. This includes sharp currency depreciation, interest-rate spikes and sovereign stress. It must evolve from a compliance function to a strategic discipline.
Transparency and Financial Reporting
Investors, depositors, and analysts must be able to understand banks’ true financial positions without navigating a lack of transparent disclosures or creative accounting. Hence, public trust in the banking sector depends heavily on credible financial reporting.
The CBN should use recapitalisation to strengthen the International Financial Reporting Standard enforcement, disclosure standards, and audit quality. In championing this course, banks’ financial statements should clearly reflect capital adequacy, asset quality, related-party transactions, and off-balance-sheet exposures. Transparency is to enable confidence, not about exposing weakness.
Regulatory Consistency and Credibility
Policy credibility has been one of the greatest challenges for Nigeria’s financial regulators.
Abrupt changes, unclear timelines, and inconsistent enforcement undermine investor confidence and weaken reform outcomes.
Recapitalisation must be governed by clear rules, predictable timelines, and consistent enforcement. Both domestic and foreign investors need assurance that the rules of the game will not change midstream. Regulatory credibility is itself a form of capital.
Consumer Protection and Banking Ethics
While recapitalisation focuses on banks’ balance sheets, the public experiences banking through fees, service quality, dispute resolution, and ethical conduct. Persistent complaints about hidden charges and poor customer treatment erode trust in the system and a stronger banking sector must also be a fairer and more accountable one. It must be noted that strengthening consumer protection frameworks alongside recapitalisation will help rebuild public confidence and reinforce financial inclusion goals.
Too Big to Fail and How to Resolve Failure
Looking at what is obtainable in the system, larger, better-capitalised banks can also become systemically dangerous if failure resolution frameworks are weak. This requires that recapitalisation should therefore be accompanied by credible plans for resolving distressed banks without destabilising the entire system or resorting to taxpayer-funded bailouts, which has been the norm in the Nigerian banking sector today. The cynic might say that recapitalisation simply made big banks bigger and empowered dominant shareholders. However, a more prospective approach invites all stakeholders, including regulators, customers, civil society and bankers themselves, to co-design the next chapter of Nigerian banking; one that balances scale with inclusion, profitability with impact, and stability with innovation.
Clear resolution mechanisms reduce moral hazard and reinforce market discipline.
A Moment That Must Not Be Wasted
Recapitalisation is not merely a financial exercise; it is a governance and trust reset opportunity. If the CBN focuses solely on capital numbers, Nigeria risks repeating a familiar cycle of apparent stability followed by crisis.
The banking sector can lay a solid foundation that truly supports economic transformation if recapitalization is used to address governance failures, asset quality, FX risk, transparency, and regulatory credibility.
Nigeria does not just need bigger banks. It needs better banks, institutions that are resilient, transparent, well-governed, and trusted by the public they serve. Hence, it must be a system that creates a more robust buffer against shocks and positions Nigerian banking as a global competitor capable of funding a $1 trillion economy, as the case may be.
This recapitalisation moment must be about building durability, not just size. The cost of missing that opportunity would be far greater than the cost of getting it right.
Blaise, a journalist and PR professional, writes from Lagos and can be reached via: [email protected]
National Insurance Commission (NAICOM) has declared that it has no plans to extend the 31 July 2026, deadline for the ongoing insurance industry recapitalisation exercise, asserting that the date is firmly rooted in the new Insurance Act.
Speaking at the investiture of Mr Akinjide Oluwarotimi-Orimolade as the 53rd president of the Chartered Insurance Institute of Nigeria (CIIN) in Lagos, Olusegun Omosehin, commissioner for Insurance, emphasised that the exercise remained central to building a resilient market.
With less than two weeks left before the window closes, the regulator commended operators making steady progress but stressed that the timeline must be treated with absolute urgency.
Omosehin said, “A stronger capital base must translate into stronger service delivery, prompt claims settlement, improved consumer protection, and a market that Nigerians can trust.
“The industry’s future will be determined by the quality of leadership, depth of competence, and discipline in serving the public interest.”
The ongoing exercise follows the historic signing of the Nigeria Insurance Industry Reform Act by President Bola Tinubu, which effectively repealed the outdated 2003 Insurance Act. Under the new framework, the sector is transitioning from a static baseline model to a dynamic risk-based capital structure. This regulatory shift aims to fortify operators against systemic economic shocks and better position the industry to contribute significantly to the Federal Government’s target of a $1tn economy.
Consequently, the exercise requires a massive capital lift across the board, pushing life underwriters from N2bn to N10bn, non-life operators from N3bn to N15bn, and reinsurers from N10bn to N35bn.
The push comes amid strong legislative alignment, with the National Assembly pledging its full backing to ensure these reforms translate into deeper market penetration.
Also speaking at the event, Ahmadu Jaha, chairman of the House of Representatives Committee on Insurance and Actuarial Matters, reaffirmed the parliament’s dedication to providing the necessary legal frameworks to drive sector growth.
Jaha said, “As Chairman of the House Committee on Insurance and Actuarial Matters, I wish to reaffirm the unwavering commitment of the House of Representatives to supporting legislative initiatives that will strengthen the insurance industry, improve regulatory effectiveness, enhance consumer protection and promote wider insurance penetration across Nigeria.
“The National Assembly recognises the critical role of the insurance industry in mobilising long-term capital, financing infrastructure development, protecting businesses and households against unforeseen risks, promoting financial stability and driving sustainable economic growth.”
Responding to the charge, the newly inaugurated Orimolade, president, CIIN, stated that his administration would aggressively protect the public interest by advancing the core mandates of the institute.
Orimolade promised “to build on the programmes of my predecessors while evolving new ideas that can further increase insurance education, awareness and acceptance across the country.”
Federal Competition and Consumer Protection Commission (FCCPC) has resumed implementation of the Digital, Electronic, Online or Non-Traditional Consumer Lending Regulations, 2025 (DEON Regulations).
This follows the judgment delivered yesterday by Justice A.L. Allagoa of the Federal High Court, Lagos, in Suit No. FHC/L/CS/760/2026 instituted by the Wireless Application Service Providers Association of Nigeria Ltd/Gte (WASPAN).
In the ruling, the Court dismissed the Plaintiff’s Originating Summons in its entirety, declined all the reliefs sought, and upheld the validity of the DEON Regulations, holding that they were made pursuant to the FCCPC’s statutory and constitutional powers and are therefore intra vires the Commission.
The Court also upheld the validity of the specific provisions of the Regulations challenged in the suit and consequently discharged the interim ex parte order that had restrained implementation and enforcement of the Regulations.
Accordingly, the legal impediment that had necessitated the Commission’s temporary suspension of implementation and enforcement of the DEON Regulations has been removed, and the Regulations are once again fully operational and enforceable.
WASPAN had challenged the Commission’s authority to issue and implement the DEON Regulations. Upon being served with the Court’s interim order in April 2026, the FCCPC immediately suspended implementation and enforcement of the Regulations in full compliance with the Court’s directive, consistent with its commitment to the rule of law and respect for judicial authority.
Meanwhile, the FCCPC has welcomed the judgement.
Reacting, Ondaje ljagwu, director of Corporate Affairs, FCCPC, said: “The Commission has always maintained that the rule of law is fundamental to effective regulation and good governance. When the Court issued its interim order, we immediately suspended implementation of the Regulations in full compliance with the Court’s directive. Now that the Court has affirmed the validity of the DEON Regulations and delivered judgment in favour of the Commission, we will continue to discharge our statutory responsibilities faithfully, professionally and in accordance with the law.
“The DEON Regulations are designed to promote responsible lending, improve regulatory accountability, curb unfair and exploitative practices, and strengthen consumer protection in Nigeria’s digital lending market. Our objective has always been to ensure that innovation and financial inclusion flourish within a transparent, fair and accountable regulatory framework that inspires confidence among consumers, investors and responsible operators alike.
Nigeria Deposit Insurance Corporation (NDIC) has urged youths to shun investment scams and embrace the habit of saving.
NDIC said that for a nation to be prosperous, its citizens must learn to build legitimate wealth through savings and then advance to investment.
Mr Adegbenga Fagbuyi, assistant director, Communication and Corporate Affairs, NDIC, made the remarks while addressing students of Lagelu Grammar School, Ibadan, during the 2026 Financial Literacy Day.
Delivering his speech on “Smart Money,” Fagbuyi highlighted the importance of having basic knowledge of the financial system, making sound financial decisions, understanding the benefits of saving in banks, setting financial goals, maintaining financial discipline, and avoiding Ponzi schemes that promise high returns.
Fagbuyi said youths are among the major targets of the government’s financial inclusion drive, adding that the Financial Literacy Day formed part of activities marking Global Money Week, adopted by the Bankers’ Committee in Nigeria as a platform for mentoring youths on savings and investment.
He said, “The government wants everybody to be participants in the financial sector. But how can you be a participant if you don’t know how to save? How can you be a participant if you cannot convert your savings into an investment? So, most importantly, youths are one of the major targets of the financial inclusion drive of the government.”
Fagbuyi described financial inclusion as bringing everybody into the financial safety net by encouraging participation in banking, insurance, pensions, and the capital market.
He stressed that the government does not want youths to become adults who lack knowledge of safe banking practices, insurance, and the capital market.
“Government does not want them to grow old, to become adults who do not know about savings, safe banking habits, insurance, and the capital market. That is why we go to schools to sensitise students to all these basic financial matters, particularly savings, so that our students can begin to learn to save, learn credible investment habits through which they can be making legitimate income.
“We also educate them about the deposit insurance system administered by NDIC. When you save in banks, the banks are supervised and regulated. And if eventually they fail, you will not lose your money. That is what NDIC does,” Fagbuyi said.
He revealed that the sensitisation programme, which started about 10 years ago and is organised by the Bankers’ Committee, comprising the Central Bank of Nigeria, the Nigeria Deposit Insurance Corporation, and all the deposit money banks in Nigeria, has been held across states nationwide.
He said, “Minimum, every year, we go to 10 states. And we normally sensitise 200 students in each school. So this year, that means we are targeting 2,000 students.”
Fagbuyi, however, said the objective of the programme is not to cover all schools across the country but to set a standard for state governments and schools to replicate.
“But I must emphasise that the objective is not to cover all schools. It is to set a standard for state governments and for schools to replicate. You agree with me that we cannot be everywhere.
“But as a partner, as a key stakeholder in the financial inclusion drive of the federal government, we go to states to showcase what the government’s intention, so that states and schools can replicate. So it is on this note that we always urge states’ Ministries of Education, Science and Technology to replicate and expand these programmes across their respective states.”
In his address, Olusegun Olayiwola, Oyo State Commissioner for Education, Science and Technology, represented by Alhaji Lukuman Kareem, permanent secretary, Education Inspectorate, Ibadan North, commended the NDIC for selecting a school in Ibadan for the financial literacy sensitisation programme.
He noted that such initiatives must go beyond the classroom to shape young minds, adding that children cannot achieve expected outcomes unless they are properly guided.
“That’s why we significantly appreciate the efforts of the Bankers’ Committee, NDIC, the Central Bank of Nigeria, and all other members for this,” he said.
The commissioner charged the students to take the lessons seriously, noting that opportunities lost may not be easily regained. He also advised the NDIC to expand the programme to include students from neighbouring schools in future editions to maximise its impact without additional transportation costs.
Additionally, Olayiwola urged teachers to cascade the training to other students, who should in turn enlighten their siblings at home.
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