A Dynamic Approach To Capitilisation: Understanding The Implications Of Revised Minimum Capital Requirements From The Market Regulators

1. Introduction

The Securities and Exchange Commission (the “SEC”) issued the Revised Minimum Capital for Regulated Capital Market Entities (the “Circular”) on January 16, 2026, to repeal the Minimum Capital Requirement for Capital Market Operators (CMOs), which the SEC had earlier issued in 2023. Subsequently, the Circular was supplemented by an implementation framework, the Guidelines on Revised Minimum Capital for Regulated Capital Market Entities issued on March 18, 2026 (the “Guidelines”). The issuance of the Circular and the Guidelines is rooted in the Federal Government of Nigeria’s broader strategy of strengthening the resilience of financial institutions and markets by promoting robust capital adequacy and effective risk management. In furtherance of this objective, the Circular and the Guidelines introduce a more risk-sensitive minimum capital framework for CMOs, reflecting international regulatory trends that increasingly align capital adequacy requirements with the