Feature/OPED
Systemically Weak Banks Put Nigeria’s $1 trillion Ambition at Risk
By Blaise Udunze
Nigeria’s banking sector has just undergone one of its most ambitious recapitalisation exercises in two decades, all thanks to the Central Bank of Nigeria under the leadership of Olayemi Cardoso. About N4.65 trillion ($3.38) has been raised. Balance sheets have been strengthened, at least the improvement could be said to exist in reports or accounting figures. Regulators have drawn a new line in the sand, proposing N500 billion for international banks, N200 billion for national banks, and N50 billion for regional players. This is a bold reset.
Meanwhile, as the dust settles, an uncomfortable question refuses to go away, which has been in the minds of many asking, “Has Nigeria once again solved yesterday’s problem, while tomorrow’s risks gather quietly ahead?”
At a period when banks globally are being tested against tougher buffers, cross-border shocks, and higher regulatory expectations, Nigeria’s revised benchmarks risk falling short of what the global system demands.
In a world where scale, resilience, and competitiveness define banking credibility, capital is not measured in isolation; it is judged relative to peers, risks, and ambition.
Because when placed side by side with a far more unsettling reality, that a single South African bank, Standard Bank Group, rivals or even exceeds the valuation and asset strength of Nigeria’s entire banking sector, the celebration begins to feel premature.
The recapitalisation may be necessary. But is it sufficient? The numbers are not just striking, they are deeply revealing. Standard Bank Group, with a market valuation hovering around $21-22 billion and assets approaching $190 billion, stands as a continental giant. In contrast, the combined market capitalisation of Nigeria’s listed banks, even after recent capital raises, struggles to match that scale.
The combined value of the 13 listed Nigerian banks reached N16.14 trillion (11.9 billion) using N1.367/$1 in early April 2026, following the recapitalisation momentum.
Even more revealing is the contrast at the top. Zenith Bank is valued at N4.7 trillion ($3.44 billion), Guaranty Trust Holding Company, widely admired for efficiency and profitability, is valued at under N4.6 trillion ($3.37 billion), while Access Holdings, despite managing tens of billions in assets, carries a market value below the upper Tier’s N1.4 trillion ($1.02 billion).
This is not merely a gap. It is a structural disconnect. And it raises a critical point, revealing that recapitalisation is not just about meeting regulatory thresholds; it is about closing credibility gaps.
With accounting figures or reports, Nigeria’s new capital thresholds appear formidable. But paper strength is not the same as real strength.
The naira’s persistent depreciation has quietly undermined the meaning of these figures. What looks like N500 billion in nominal terms translates into a much smaller and shrinking figure in dollar terms.
This is the misapprehension at the heart of Nigeria’s banking reform, as we are measuring financial strength in a currency that has been losing strength.
In real terms, some Nigerian banks today may not be significantly stronger than they were years ago, despite meeting much higher nominal thresholds. So while regulators see progress, global investors see vulnerability. Markets are rarely sentimental. They price risk with ruthless clarity.
The valuation gap between Nigerian banks and their South African counterparts is not an accident; it must be made known that it is strategic intentionality. By this, it truly reflects a deeper judgment about currency stability, regulatory predictability, governance standards, and long-term growth prospects. Investors are not just asking how much capital Nigerian banks have. They are asking how durable that capital is.
Even when Nigerian banks post strong profits, much of it has been driven by foreign exchange revaluation gains rather than core lending or operational efficiency. The CBN’s decision to restrict dividend payments from such gains is telling; it acknowledges that not all profits are created equal. True strength lies not in accounting gains, but in economic impact.
Nigeria has travelled this road before. Under Charles Soludo, the 2004-2006 banking consolidation raised minimum capital from N2 billion to N25 billion, reducing the number of banks dramatically and producing industry champions like Zenith Bank and United Bank for Africa. For a time, Nigerian banks expanded across Africa and became formidable competitors.
But the momentum did not last, emanating with lots of economic headwinds. One amongst all that played out was that the global financial crisis exposed weaknesses in governance and risk management, leading to another wave of reforms under Sanusi Lamido Sanusi. The lesson from that era remains clear, which revealed that capital reforms can stabilise a system, but they do not automatically transform it. Without bigger structural changes, the gains fade.
The real weakness of Nigeria’s current approach is not the size of the thresholds; it is their rigidity. Fixed capital requirements do not adjust for inflation, reflect currency depreciation, scale with systemic risk, or capture the complexity of modern banking.
In contrast, global regulatory frameworks are increasingly dynamic and risk-based. This is where Nigeria risks falling behind again. Because while the numbers have changed, the philosophy has not.
Nigeria’s economic aspirations are bold. The country speaks confidently about building a $1 trillion economy, expanding infrastructure, and driving industrialisation, but in dollar terms, many Nigerian banks remain small, too small for the scale of ambition the country now proclaims. Albeit, it must be understood that ambition alone does not finance growth. Banks do.
And here lies the uncomfortable mismatch, which is contradictory in nature because the economy Nigeria wants to build is significantly larger than the banks it currently has.
In South Africa, what Nigerian stakeholders are yet to understand is that large, well-capitalised banks play a central role in financing infrastructure, corporate expansion, and consumer credit. Their scale allows them to absorb risk and deploy capital at levels Nigerian banks struggle to match. Without comparable financial depth, Nigeria’s development ambitions risk being constrained by its own banking system.
At its core, banking is about channelling capital into productive sectors, as this stands as one of its responsibilities if it truly wants to ever catch up to a $1 trillion economy. Yet Nigerian banks have increasingly, in their usual ways, leaned toward safer, short-term returns, particularly government securities. This is not irrational. It is a response to high credit risk, regulatory uncertainty, and macroeconomic instability.
But it comes at a cost. Yes! The fact is that when banks prioritise safety over lending, the real economy suffers. What this tells us is that manufacturing, agriculture, and small businesses remain underfunded, limiting growth and job creation.
Recapitalisation is meant to change this dynamic. Stronger capital buffers should enable banks to take on more risk and finance larger projects. But capital alone will not solve the problem. Confidence will.
One of the most persistent obstacles facing Nigerian banks is currency volatility. Each major devaluation of the naira erodes investor returns and reduces the dollar value of bank capital. This creates a contradiction whereby banks appear profitable in naira terms, but unattractive in global markets.
In contrast, South Africa benefits from a more stable currency environment and deeper capital markets. Without much ado, it is clear that this stability attracts long-term institutional investors that Nigeria struggles to retain. Until this macroeconomic challenge is addressed, recapitalisation alone cannot close the gap because, without making it a priority, even the strongest banks will remain constrained.
In a global competitive financial market, one would agree that capital is necessary, but not sufficient. Beyond the capital, one crucial lesson stakeholders in Nigeria’s banking space must understand is that investors’ confidence is heavily influenced by governance standards and operational efficiency, which mainly guarantee more success and capability. Also, another relevant trait to sustainable banking is transparency, regulatory consistency, and accountability, which matter as much as balance sheet strength.
While Nigerian banks have made progress, lingering concerns remain around insider lending, regulatory unpredictability, and complex ownership structures. If policymakers revisit and reflect on the episodes involving institutions like First Bank of Nigeria and the liquidation of Heritage Bank, this will reinforce the perceptions of systemic risk.
Recapitalisation offers an opportunity to reset governance standards, but only if it is accompanied by stricter enforcement and greater transparency, with the key stakeholders seeing beyond the capital growth.
As if traditional challenges were not enough, Nigerian banks are also facing increasing competition from fintech companies. Nigeria has emerged as a leading fintech hub in Africa, reshaping payments, lending, and digital banking.
To remain relevant, banks must invest heavily in technology, an area that requires not just capital, but smart capital, ensuring that digital innovation becomes a core strength rather than an external add-on. The recapitalisation exercise provides the financial capacity. Whether banks use it effectively is another matter entirely.
So, are Nigeria’s new capital thresholds already outdated? Not yet. But they are already under pressure, pressure from inflation, currency weakness, global competition, and Nigeria’s own economic ambitions.
The truth is that the reforms are a step in the right direction, but they may already be systemically weak in the face of global realities. Whilst the actors keep focusing heavily on capital thresholds without addressing deeper structural issues, the reforms risk creating a system that is compliant, but not competitive, stable but not strong.
The recapitalisation exercise has bought Nigeria time. That is its greatest achievement. But time is only valuable if it is used wisely.
If policymakers treat this reform as a destination, the thresholds will age faster than expected. If they treat it as a foundation, Nigeria has a chance to build a banking system capable of supporting its ambitions.
It can either strengthen its financial foundations to match its economic ambitions or continue to pursue growth on a fragile base.
The warning signs are already visible. Systemic weaknesses, if left unaddressed, will not remain contained; they will surface at the worst possible moment, undermining confidence and limiting progress.
Otherwise, the uncomfortable truth will persist; one well-capitalised bank elsewhere will continue to stand taller than an entire banking system at home. Whilst a $1 trillion economy cannot be built on a weak banking system. The sooner this reality is acknowledged, the better Nigeria’s chances of turning ambition into achievement.
Blaise, a journalist and PR professional, writes from Lagos and can be reached via: [email protected]
Feature/OPED
AI and Cybercrime in Nigeria: Can Weak Laws Support Strong Technology?
By Nafisat Damisa
Introduction
The proliferation of generative AI has transformed Nigeria’s cybercrime landscape, enabling deepfake fraud, automated social engineering, and AI-enhanced phishing at scale. In early 2024, scammers using AI-generated deepfake videos impersonating a company’s CFO defrauded a Hong Kong finance worker of $25.6 million. As similar threats emerge in Nigeria’s fintech sector, this article examines whether the Cybercrimes (Prohibition, Prevention, etc.) Act 2015 (as amended 2024) is legally adequate, or whether Nigeria’s evidentiary and accountability frameworks are too weak to support effective prosecution of AI-driven cybercrime
Current Legal Landscape
Nigeria’s primary legal framework on preventing cybercrime is the Cybercrimes (Prohibition, Prevention, etc.) Act 2015, amended in 2024 to address cryptocurrency transactions, cyberbullying and various forms of digital misconduct. Complementary frameworks include the National Information Technology Development Agency Act 2007, the Nigerian Data Protection Act 2023, and sectoral regulations such as the CBN’s Risk-Based Cybersecurity Framework. However, the majority of these frameworks were issued far before now, and emerging risks like AI-driven threats are not really being addressed. The Act nowhere mentions “artificial intelligence,” “algorithm,” or “autonomous system.” Notably, the National Artificial Intelligence Commission (Establishment) Bill, 2025, is currently pending before the Senate. If passed, it would establish a dedicated commission to coordinate AI strategy, research, and ethical deployment. However, the Bill in its present form focuses primarily on development and innovation promotion, with limited provisions on criminal liability, evidence handling, or enforcement against AI-facilitated cybercrime, leaving the core accountability and evidentiary gaps largely unaddressed.
AI as a Double-Edged Sword
AI paradoxically enables both defence and attack. Nigerian financial institutions deploy AI for real-time fraud detection and pattern recognition. Conversely, cybercriminals exploit generative AI for deepfake creation, automated credential stuffing, and convincing phishing tailored to Nigerian English and Pidgin. The same technology that powers fraud detection systems can be weaponised to evade them. Take justice delivery as an example, the Evidence Act 2011 (as amended 2023) admits computer-generated evidence under Section 84, but remains silent on AI’s capacity to seamlessly generate or alter electronic records, creating “doctored AI-generated evidence”. These and many more issues await Nigeria’s digital space in the coming years.
The Legal Gaps
There are multiple critical gaps that undermine AI governance. For this article, three are considered. First, no framework attributes criminal liability when an autonomous AI commits an offence. The question of whether the developer, user, or owner should bear criminal responsibility for the acts of an autonomous system remains entirely unanswered under Nigerian law, leaving prosecutors without a clear legal theory of culpability.
Second, Section 84 of the Evidence Act 2011 governs computer-generated evidence but does not address AI-generated outputs. The Act’s definition of “computer” excludes AI’s cognitive processing capabilities, creating a statutory blind spot where evidence produced by generative or autonomous systems falls outside the existing admissibility framework.
Third, Nigeria lacks any framework for mandatory AI-generated content labelling, impeding deepfake traceability. Computer-generated evidence under Section 84 of the Evidence Act 2011 remains admissible if unchallenged at trial, a dangerous precedent for AI evidence, as opposing parties may lack the technical capacity to mount any challenge at all.
Comparative Jurisdictions: Rich Laws, Tangible Results
Jurisdictions with advanced AI laws demonstrate clear outcomes. The EU AI Act (Regulation 2024/1689) mandates transparency obligations, requiring synthetic content labelling and informing individuals when interacting with AI systems; non-compliance triggers significant penalties. The US Algorithmic Accountability Act of 2023 is a proposed Act that will require impact assessments for high-risk AI systems in housing, credit, and employment, with FTC enforcement and a public repository. China implemented mandatory measures for the Identification of AI-generated (Synthetic) content. These rules, mandated by the Cyberspace Administration of China (CAC) and others, require explicit (visible labels) and implicit (watermarks/metadata) identification for all AI-generated text, images, audio, video, and virtual scenes to ensure transparency, traceability, and combat disinformation. These laws contribute to measurable results: forensic traceability, expedited prosecution of deepfake fraud, and clear liability chains. Nigeria has none of these.
Hope or Illusion?
Without legislative intervention, AI’s promise against cybercrime remains an illusion. Nigeria requires the following to boost its hope:
- Amendment of the Cybercrimes Act to include AI-specific offences and mandatory content provenance standards;
- Revision of Section 84 of the Evidence Act 2011 to address AI-generated evidence credibility, not merely admissibility;
- Investment in digital forensic capabilities is currently hampered by inadequate enforcement, weak forensic capabilities, and a lack of specialised personnel; and
- A risk-based framework drawing from EU and US models.
- Review of both secondary and tertiary education curricula to address the knowledge gap in AI and prepare the next generation for the AI-driven future.
Conclusion
AI can help curb cybercrime in Nigeria, but only if legal capacity catches up with technical capability. The Cybercrimes Act 2024 amendments were a step forward, but they did not address AI accountability, algorithmic transparency, or evidentiary credibility. The pending National Artificial Intelligence Commission Bill, 2025, signals legislative awareness, but without substantive provisions on liability, evidence, and enforcement, it cannot fill the existing gaps. The effectiveness of existing frameworks remains a question. An optimistic but cautious path exists, but until Nigeria enacts AI-specific legislation, whether through amending the Cybercrimes Act, revising the Evidence Act, or strengthening the pending Bill, weak laws will remain unable to support strong technology.
Nafisat Damisa is a Legal Research Associate in Olives and Candles – Legal Practitioners. For further information, enquiries, or clarification, please contact Nafisat via: [email protected] or [email protected]
Feature/OPED
Before Oil Hits $150: A Warning Nigeria Cannot Ignore
By Isah Kamisu Madachi
As of April 30, 2026, the crude price is said to have reached $125 in the global market. The all-time high price per barrel was recorded in 2008, when it surged to $147. It is obvious that the price is heading in that direction or even towards what experts have predicted — crude reaching a new all-time high of $150 in the near future if crude passages remain closed in the Middle East, which would ultimately come with several disproportionate challenges for businesses and households.
In Nigeria, what began as a mild adjustment in the price of gasoline and other refined crude products has not stopped anywhere until it reached N1,400 per litre of petrol at filling stations. When the price was surging, experts in energy, economics, marketing, business and other relevant fields tried to come up with explanations for how Nigeria, despite housing the largest petrochemicals refinery in Africa and being one of the largest oil-exporting countries on the continent, would continue to absorb this shock.
Despite our advantages, Nigeria recorded the world’s second-highest surge in petrol prices following the escalating geopolitical tension in the Middle East. In Africa, Nigeria has the highest spike, with many sources citing it at 39.5% and above. Even non-oil-producing countries in Africa, and countries that do not refine a drop of oil, did not experience this surge. Also, African countries like South Africa at 1%, Morocco at 2.1%, and Tanzania at 2.7% experienced far smaller increases that are nowhere near Nigeria’s.
To put it in context, South Korea, Japan, and China are among the foremost dependents on the Strait of Hormuz, whose closure escalated the crude price, but none of these countries has recorded even a 20% increase in their petrol prices. Nigeria does not import its crude through the Strait of Hormuz. Yet, as an oil-exporting nation, we have suffered some of the sharpest petrol price increases in Africa.
What went wrong in Nigeria to warrant this surge is not the primary focus of this piece. What lies ahead is. As a result of the increase in petrol prices, Nigerians have been disproportionately affected. Life has become unbearably difficult, with sharp increases in transportation costs, rising food prices, and higher costs of goods and services. Even charging points that used to collect N150 for charging a phone or battery now charge N300 or more.
As it stands, the gap between the current crude price and the predicted new all-time high is about $25. This means that if the passages continue to remain closed, we are not far from another historic price peak. It is even said that reopening the passages may not immediately stabilise prices, as crude tankers would still take time to reach their destinations.
What this means for Nigeria is another sharp increase in refined petroleum product prices, which could trigger another wave of stagflation. Already struggling, Nigerians do not deserve this. They are only just adapting to the post-subsidy era, yet are being hit again by another round of global geopolitical tensions. Many are already in deep energy poverty, with businesses struggling due to unstable electricity supply.
Therefore, as crude oil prices hover above $125 per barrel and threaten to reach the predicted $150 if disruptions in the Strait of Hormuz persist, Nigeria must act decisively to shield its citizens. The Dangote Refinery exists. Nigeria refines oil. What the federal government owes Nigerians at this point is a deliberate policy decision to make that the refinery serve domestic needs first, with pricing that does not mirror whatever is happening in the global market. That is not complicated; other oil-producing countries do exactly this.
The NMDPRA has the authority to act on this. The question is whether there is a political will to act before another price wave hits and Nigerians are once again left to absorb what their counterparts elsewhere never have to.
Sub-national governments also have something to do. Commercial motorcyclists and small business owners are the people who feel every petrol price increase the hardest and the fastest. Pushing CNG and LPG adoption among this group beyond the FCT and Lagos, with genuine support, would cushion a significant part of the next shock. Expanding solar access in underserved communities would do the same. A shop owner running on solar is not at the mercy of the next diesel price spike.
These solutions are quite feasible. Nigeria has attempted versions of them before. Where we often seem to get it wrong is in execution, and Nigeria has to treat this with the same urgency and seriousness as given to elections, for the well-being of its citizens. The only thing that has never matched the problem is the seriousness of the response.
Isah Kamisu Madachi is a policy analyst and development practitioner. He writes via [email protected]
Feature/OPED
A Simple Guide to Obtaining Pension Clearance Certificate in Nigeria
By Gbolahan Oluyemi
In 2025, the National Pension Commission (PenCom) directed all Licensed Pension Fund Operators (LPFOs) to demand a Pension Clearance Certificate (PCC) from service providers before engaging their services. This new policy typically affects various types of entities, including small and medium-scale enterprises, most of which are not usually compliance-driven. Following this directive, the PCC has become an essential compliance document for both large, medium and small-scale firms. This article provides a guide on what a PCC is, why it matters, and how it can be obtained.
What is a Pension Clearance Certificate (PCC)?
A Pension Clearance Certificate (PCC) is an official document issued by PenCom confirming that an organisation has complied with the provisions of the Pension Reform Act. It is an annual document that must be renewed every year at no cost. The yearly renewal is intended to ensure that organisations treat compliance as a continuous activity rather than a one-off act.
Why is a PCC Important?
The PCC is important because it demonstrates that an organisation is compliant with the provisions of the Pension Reform Act, especially as it relates to employee pension contributions under Section 4 (1) of the Pension Reform Act and subscription to group life insurance under Section 4 (5) of the Pension Reform Act. It is also required for certain transactions, such as government contracts and engagements with compliance-sensitive partners. In essence, a PCC assures investors, partners, and clients that your business is properly structured and compliant with regulatory requirements.
Who Needs a Pension Clearance Certificate?
Under Nigerian law, companies with three or more employees are required to participate in the Contributory Pension Scheme (CPS). If your organisation employs at least three staff members and provides or intends to provide services to Licensed Pension Fund Operators (LPFOs) or other regulated entities, you are expected to obtain a PCC annually.
How Do I Obtain a PCC?
PenCom issues the PCC electronically and at no cost through its web portal: https://pcc.pencom.gov.ng/. Please note that Applicants who are just beginning compliance and remitting employees’ pensions are required to first obtain an employer code from a Pension Fund Administrator (PFA). This code is necessary to initiate the PCC application on the PenCom portal.
Upon logging into the portal, you will be required to complete your company profile by providing your date of incorporation, contact details, and website (if applicable), as well as uploading your CAC documents.
Next, you will upload an Excel schedule (using the template provided on the website) containing your employee list. After this, you will be required to upload Excel sheets detailing pension contributions. You will also need to upload your organisation’s group life insurance documentation and payment instrument.
Finally, you will review your application and submit it for further processing by PenCom. Before commencing an application, ensure you have the following:
- Certificate of Incorporation (CAC documents)
- Group Life Insurance Policy for employees
- Evidence of Pension Fund Administrator (PFA) registration for employees
- Three years’ proof of monthly pension remittances, including penalties for any defaults (where applicable). For companies less than three years old, provide proof of remittances from the date of incorporation
- A valid Tax Identification Number (TIN)
- An employee schedule showing staff details and contributions (usually in Excel format) Templates are available on the PenCom portal
Also note that for the portal to accept employee details and remittance records, employees must have completed their data capture with their respective Pension Fund Administrator and updated their records to reflect their current employer.
Conclusion
Obtaining a Pension Clearance Certificate in Nigeria may seem technical at first, but once proper processes are established, it becomes routine. The key is consistency in remittance, maintenance of accurate records and prioritisation of compliance in overall operations.
For many Nigerian businesses, the PCC is more than a regulatory requirement; it is a mark of credibility. In a competitive environment, that credibility can make all the difference.
Gbolahan Oluyemi is a Legal Practitioner and currently leads Olives and Candles – Legal Practitioners. For further information, enquiries, or clarification, please contact Gbolahan via: [email protected] or [email protected]
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