SEC’s Guidelines On Revised Minimum Capital Requirements For Capital Market Operators

Background

In our January 2026 update on Circular No. 26- 1 which was issued by the Securities and Exchange Commission (the “SEC” or the “Commission”) on 16th January 2026 (the “January 2026 Circular”), we highlighted the significant revisions to the minimum capital requirements applicable to regulated capital market entities in Nigeria, focusing on fund and portfolio managers, private equity fund managers, and venture capital fund managers. Our previous article update can be found here.

At that time, the SEC had indicated that transitional arrangements might be considered on a case-by-case basis, but detailed guidance had not yet been issued. On 18th March 2026, the SEC published its Guidelines on Revised Minimum Capital for Regulated Entities (the "Guidelines"), providing guidance on what constitutes the minimum capital requirements, and the operational and procedural framework within which all capital market operators ("CMOs") are expected to plan and implement their