Introduction
The third quarter of 2026 (“Q3 2026”) was marked by significant regulatory and commercial developments across Nigeria’s capital markets, corporate sector, digital economy, financial services, insurance, infrastructure and energy sectors. The period witnessed heightened regulatory enforcement, expanded compliance obligations and new frameworks targeting emerging areas of economic activity, alongside measures designed to support investment and infrastructure development.
Key developments include the Dangote Refinery initial public offering, the Corporate Affairs Commission’s (“CAC”) renewed enforcement of corporate filing and disclosure requirements, the Securities and Exchange Commission’s (“SEC”) proposed framework for digital and virtual assets, the Nigeria Revenue Service’s (“NRS”) guidelines on the taxation of virtual assets and the introduction of the National Digital Cloud Policy.
The quarter also saw the conclusion of the insurance sector recapitalisation exercise, a new economic regulatory framework for the ports sector, technical audit requirements for the electricity transmission network and tighter controls on the participation of Bureau De Change (“BDC”) operators in the foreign exchange market. Later in the quarter, the Central Bank of Nigeria (“CBN”) delivered a significant cut to the Monetary Policy Rate, the Nigerian Upstream Petroleum Regulatory Commission (“NUPRC”) moved against non-performing oil licences and the Federal High Court ruled on the grant of petroleum product import licences, while the NRS operationalised mandatory e-invoicing for large taxpayers. These developments have practical implications for businesses in areas including capital raising, financing costs, corporate compliance, market entry, taxation, digital assets, data management and sector-specific operations.
This Report examines these developments and their key legal and commercial implications for businesses operating in, or investing into, Nigeria.





