The closed-door forum, hosted by B&I, brought together senior partners including Asue Ighodalo, Chinedum Umeche, Akindeji Oyebode, Olamide Oshikoya, Seyi Bella, and Femi Olubanwo, alongside Joseph Tegbe, Chairman of Nigeria's National Tax Policy Implementation Committee.

The meeting was convened in direct response to the Investment and Securities Act 2025 (ISA 2025) and the Nigeria Tax Administration Act 2025 (NTAA 2025), both of which are now operative, with key ISA 2025 capital provisions phasing in through June 2027.

Tegbe's presence at an industry forum rather than a government hearing may signal that regulators are engaging with private-sector compliance questions ahead of broader enforcement. As Chairman of the National Tax Policy Implementation Committee, Tegbe carries direct responsibility for overseeing the NTAA 2025's rollout, making his participation a consequential indicator of the government's approach to implementation.

Why the Scale of Nigeria's Crypto Market Makes This Consequential

The stakes behind these laws are not abstract. According to Chainalysis data covering July 2024 through June 2025, Nigerian users received $92.1 billion in on-chain crypto value during that period. That figure represents roughly 45 percent of all crypto activity across Sub-Saharan Africa, which itself grew 52 percent year over year to $205 billion. Chainalysis ranks Nigeria sixth globally and first on the African continent for crypto adoption. Separately, according to Breet.io, an estimated 22 million Nigerians, approximately 10.3 percent of the population, currently hold some form of digital asset.

Much of that activity runs through peer-to-peer (P2P) channels rather than formal exchanges. Research from TransnetInc and Arristor indicates P2P trading accounts for approximately 68 percent of all Nigerian crypto transactions, compared to a 29 percent global average, and TransferXO estimates daily P2P volume at roughly $48.2 million. That informal layer grew because it operated outside banking infrastructure, particularly after the Central Bank of Nigeria banned banks from servicing crypto traders in 2021. ISA 2025 formally reversed that ban by establishing a statutory coordination framework between the SEC and the CBN, ending years of conflicting regulatory signals between the two bodies. The new laws are now aimed squarely at formalizing that ecosystem.

What the Two Laws Actually Require

The ISA 2025, signed by President Bola Tinubu on March 25, 2025, brings digital assets including Bitcoin, Ethereum, stablecoins, security tokens, NFTs, and tokenized real-world assets under the Securities and Exchange Commission's jurisdiction for the first time at the statutory level. Every crypto exchange, custodian, and offering platform must now register with the SEC, meet fit-and-proper requirements, and comply with anti-money laundering standards aligned with the Financial Action Task Force.

The capital requirements alone are reshaping the competitive landscape. In January 2026, the SEC raised minimum capital thresholds for digital asset exchanges and custodians from 500 million naira to 2 billion naira, roughly $1.4 million at January 2026 exchange rates, a fourfold increase. Digital Asset Offering Platforms face a doubling of their minimum capital requirement, from 500 million naira to 1 billion naira. Robo-advisers face a tenfold increase, from 10 million to 100 million naira. All platforms have until June 30, 2027 to comply.

Timothy Mark-Ugwumba, writing in TechCabal, put the burden plainly: "The Act places nearly the same compliance burden on startups as on banks, despite crypto startups lacking comparable resources."

The NTAA 2025, which took effect January 1, 2026, adds a detailed tax reporting layer. Every user on a regulated Nigerian exchange must now link their Tax Identification Number and National Identification Number to their account. Exchanges must submit monthly transaction reports to the Federal Inland Revenue Service covering asset types, naira valuations, user identities, and transaction dates. Records must be retained for seven years. First-month penalties for non-compliance start at 10 million naira, with license suspension or revocation available for continued violations.

Crypto profits are classified as chargeable income under existing tax bands, reaching up to 25 percent for individuals on earnings treated as ordinary income. A separate levy governs disposals: the Finance Act 2023, which took effect September 1, 2023, imposed a 10 percent capital gains tax on digital asset sales and transfers. These two rates apply to different event types and are not cumulative. The NTAA builds on both prior measures, representing a significant escalation of reporting and enforcement obligations rather than a fresh start.

Legal analyst Omosefe Egharevba captured the shift in posture among Nigerian Web3 operators: "ISA 2025 doesn't intimidate me[;] it actually makes sense to me now." Egharevba also noted the blunter reality: "Anonymity is over."

What This Means Beyond Nigeria

Nigeria's regulatory choices carry weight across the continent. Ghana, Kenya, South Africa, and several East African jurisdictions are each developing their own frameworks for virtual asset service providers, and Nigeria's experience will serve as either a template or a cautionary tale.

The NTAA is also deliberately aligned with the OECD's Crypto-Asset Reporting Framework (CARF), which took effect on the same date, January 1, 2026, and enables cross-border data sharing to address tax evasion. That deliberate synchronisation signals a shift away from the wait-and-see posture many African regulators have maintained, toward active participation in global financial governance.

The unresolved questions the forum was convened to address include how volatile or illiquid assets should be valued for tax purposes, whether foreign blockchain infrastructure used by Nigerian Web3 startups falls under ISA 2025's securities definition, and how P2P trades between individuals rather than registered platforms will be treated in practice, a question researchers have identified as a regulatory grey zone.

With capital requirements tightening and monthly reporting obligations already in effect, the window for operating outside formal compliance structures is closing. The forum's timing, months into the NTAA rollout and a year before the capital deadline, suggests industry players are now working backward from regulatory reality rather than waiting for further guidance.