When the Securities and Exchange Commission of Nigeria published its Digital Assets Rules in May 2022, most market participants treated them as aspirational. Capital requirements existed on paper. The registration portal existed on paper. Enforcement was, in practice, absent. Four years later, the picture is materially different. The Investments and Securities Act 2025 (ISA 2025), signed into law in February 2025, has converted what was once administrative guidance into statutory obligation, and the SEC's Accelerated Regulatory Incubation Programme, better known as ARIP, is now the only lawful route to operating a crypto business in Nigeria.

This guide explains how the ARIP registration process works, who it applies to, what the capital thresholds are, and what it costs an operator to ignore the requirement entirely.

What Exactly Is the ARIP Scheme?

The Accelerated Regulatory Incubation Programme is the SEC Nigeria's structured pathway for digital asset businesses seeking regulatory authorisation. It was introduced as a two-stage mechanism: an initial incubation phase during which an applicant operates under a provisional approval while demonstrating compliance capacity, followed by a full licence once the SEC is satisfied with the operator's governance, technology, and anti-money laundering controls.

The word "accelerated" is significant. The SEC designed ARIP specifically to avoid the years-long licensing timelines common to traditional capital market licences. The target processing window for provisional approval is 90 days from the date of complete application submission, though the SEC's published data shows the median time from filing to provisional grant in 2025 was 118 days across all categories.

ARIP sits within the SEC's broader Virtual Assets Regulatory and Investment Protection framework. The ISA 2025 transformed that framework from a discretionary administrative arrangement into a statutory one: Section 31 of the ISA 2025 explicitly empowers the SEC to prescribe registration requirements for Virtual Asset Service Providers (VASPs), and Section 198 sets out the penalty schedule for unlicensed operation.

The ISA 2025 did not create ARIP, but it turned it from a voluntary gesture into a legal prerequisite — with fines and asset forfeiture waiting on the other side.

What Are the ARIP Licence Categories and Capital Requirements?

The SEC has defined four main registration categories under the ARIP framework. Each carries distinct capital requirements, operational obligations, and scope of permitted activity.

Digital Asset Offering Platform (DAOP)

A DAOP licence covers entities that facilitate the issuance and primary sale of digital tokens to the public. This is the Nigerian equivalent of a primary market authorisation. The minimum paid-up capital requirement is ₦500,000,000 — approximately $316,456 at the prevailing NAFEM rate of ₦1,580 per dollar as at June 2026. DAOP applicants must also maintain a fidelity bond equivalent to 10% of the highest amount of digital assets held on behalf of clients in the preceding 12 months.

Digital Asset Exchange (DAX)

A DAX licence authorises the operation of a secondary trading platform where users can buy, sell, and exchange digital assets. This is the most demanding category. The minimum capital requirement is ₦1,000,000,000. The SEC additionally requires DAX operators to maintain a client asset segregation structure, submit to quarterly third-party technology audits, and appoint a board-level risk committee that includes at least one independent director with financial services experience. Binance's Nigerian registered entity, which came under intense scrutiny following the detention of executive Tigran Gambaryan in early 2024, falls into the DAX category.

VASP Custodian

Custodians hold digital assets on behalf of clients without facilitating trading. The minimum capital is ₦500,000,000. The SEC mandates proof-of-reserve audits on a semi-annual basis, with results filed on the ARIP portal within 30 days of each audit period. Cold storage obligations require that at least 80% of client assets be held in offline wallets at all times. This category covers both standalone custodians and exchange operators that wish to self-custody client funds.

Digital Asset Broker/Dealer

This is the entry-level ARIP category, designed for smaller operators who buy and sell digital assets as principal or agent but do not operate a full exchange. The minimum capital is ₦100,000,000. Broker/dealers are prohibited from holding client assets overnight unless they also hold a concurrent VASP Custodian approval.

All four categories require the same foundational compliance package on application: a documented AML/CFT policy aligned with the Financial Action Task Force's Recommendation 15, a named compliance officer with verifiable financial crime credentials, a technology security assessment prepared by a SEC-recognised firm, and evidence of registered office and key personnel resident in Nigeria.

How Does the Application Process Work?

The ARIP application is filed through the SEC's online portal at sec.gov.ng. The process has three formal stages.

The first stage is pre-application. The SEC holds a mandatory pre-application consultation session for all prospective ARIP applicants. This session, conducted virtually, allows the SEC's Digital Assets team to assess the applicant's readiness and flag any structural issues before the formal filing is made. The consultation must be requested at least 21 days before the intended filing date.

The second stage is the formal application. The applicant submits a complete file including incorporation documents, a business plan covering at least three years, financial projections, AML policy, technology architecture documentation, and a cyber-incident response plan. The filing fee varies by category: ₦2,000,000 for DAOP and DAX applicants, ₦1,000,000 for VASP Custodians, and ₦500,000 for broker/dealers. Filing fees are non-refundable.

The third stage is the incubation period. Following provisional approval, the operator may begin limited commercial activity subject to SEC supervision. Transaction volume caps apply during the incubation period: DAX operators are capped at ₦5,000,000,000 in aggregate monthly volume, while broker/dealers face a ₦500,000,000 monthly cap. At the close of the incubation period, which is nominally 12 months but can be extended, the SEC conducts a compliance review before issuing a full licence.

As at the first quarter of 2026, six entities had received full ARIP approval and a further nine held provisional approvals. The SEC has not publicly identified all approved entities by name, but YellowCard and Quidax have both confirmed full approval status in their own communications. The full register is maintained on the SEC's website.

What Happens to Unregistered Operators?

The ISA 2025 introduced a tiered penalty structure that represents a significant escalation from the previous regime.

An unregistered individual operating a digital asset business faces a fine of up to ₦10,000,000 on first conviction. An unregistered entity — a company or partnership — faces a fine of up to ₦20,000,000 on first conviction. On subsequent conviction, both categories face additional daily fines for every day the violation continues, and the court may order forfeiture of assets derived from the unlicensed activity.

The SEC issued 14 enforcement notices to unregistered virtual asset operators between January and April 2026, according to its quarterly report for Q1 2026. Four of those notices were accompanied by freezing orders on associated bank accounts, obtained through Federal High Court proceedings. This represents the first sustained use of the ISA 2025 enforcement powers in the digital asset space.

Operators that are foreign-incorporated face additional complexity. The ISA 2025 requires any entity directing digital asset services at Nigerian residents — regardless of where the entity is incorporated — to obtain an ARIP registration if its Nigerian user base exceeds a threshold set in subsidiary rules. The SEC has indicated this threshold will be defined in supplementary regulations expected in the third quarter of 2026. In the interim, the SEC has adopted a conduct-based test: if a platform accepts naira, markets in Nigeria, or allows BVN-verified onboarding, it is presumed to be directing services at Nigerian residents.

Ongoing Obligations After Registration

Receiving an ARIP licence is not the end of the compliance obligation. Registered operators must file annual returns with the SEC by 31 March each year covering user numbers, transaction volumes, suspicious activity reports submitted to the Nigerian Financial Intelligence Unit (NFIU), and details of any technology incidents.

The SEC also requires ARIP-registered entities to participate in the Nigerian Investor Protection Fund, contributing 0.5% of annual gross revenue up to a cap of ₦50,000,000 per year. This fund, established under the ISA 2025, provides limited compensation to retail investors in cases of operator default.

From the tax side, the Federal Inland Revenue Service confirmed in August 2024 that ARIP-registered exchanges are required to submit annual transaction summaries for users whose aggregate disposals exceed a reporting threshold. The FIRS had not published the exact threshold figure as at June 2026, but the data-sharing framework between FIRS and the SEC's ARIP registry is operational. Operators that receive a FIRS information request must respond within 14 days under the provisions of the Finance Act 2021.

The CBN layer adds a further obligation: banks servicing ARIP-registered operators must apply enhanced due diligence under the CBN's 2023 VASP AML Guidelines. In practice, this means operators need to maintain consistent documentation with both their SEC compliance file and the due diligence files held at their banking partners to avoid transaction disruptions.

For a broader overview of how the CBN and SEC divide authority over the crypto market, see our full guide on crypto regulation in Nigeria.


Regulatory note: This article references rules and guidance issued by the Securities and Exchange Commission of Nigeria (SEC), the Central Bank of Nigeria (CBN), and the Federal Inland Revenue Service (FIRS) under the Investments and Securities Act 2025 and associated subsidiary legislation. Regulatory frameworks in this area are subject to change; readers should verify current requirements directly with the relevant authority. The Cowrie Report is an independent editorial publication. It does not hold an ARIP registration, a financial services licence, or any other regulatory authorisation from the SEC or CBN, and nothing in this article constitutes legal, financial, investment, or compliance advice.