ABUJA, NIGERIA — August 31, 2026 — The Virtual Asset Service Providers Association of Nigeria (VASPA) today made a formal submission addressed to the Payments System Management Department of the Central Bank of Nigeria (CBN) bordering on the CBN Regulatory Sandbox which is scheduled to close today, August 31, 2026.
The submission formally commends the CBN for launching Cohort 2 of the Regulatory Sandbox Programme on August 11, 2026, marking a landmark moment for Nigeria’s digital economy. However, in the interest of fostering a robust, inclusive, and highly competitive inaugural cohort, VASPA is urgently requesting an extension of the application window and offering eight key structural recommendations.
The Case for an Extension: Aligning Timelines with Compliance Realities
The current application window, which opened on August 12 and closes on August 31, 2026, allows operators only 19 days to compile an extensive body of regulatory evidence.
The application form, encompassing 33 sections and 236 questions, mandates deliverables that structurally require weeks or months to execute. These include:
- A comprehensive penetration test and report conducted by a CREST-certified firm.
- Independent reserve attestations for stablecoin and token issuers (within the preceding three months).
- A legal opinion detailing the token’s status under the Investments and Securities Act 2025.
- Up to three years of audited financial statements, a Data Protection Impact Assessment, enterprise-wide AML/CFT/CPF risk assessments, and a board-approved policy library comprising up to 28 distinct procedures.
VASPA notes that the 19-day deadline inadvertently favors applicants with pre-existing, deep-pocketed compliance infrastructures—often well-capitalized foreign entities—at the expense of indigenous, early-stage innovators. To prevent the inaugural cohort from becoming thin and unrepresentative, VASPA respectfully requests an extension of the application window by 60 to 90 days (targeting November 30, 2026), or the transition to a rolling/cohort-based intake model.
VASPA’s 8 Recommendations to Strengthen the Sandbox
In addition to the timeline extension, VASPA has proposed the following structural reforms to enhance the accessibility, proportionality, and supervisory success of the Sandbox:
- Adopt a Rolling or Cohort-Based Intake: Replacing the single deadline with quarterly intakes would allow the CBN to manage supervisory bandwidth effectively and enable applicants to apply when genuinely ready, mirroring the SEC’s Accelerated Regulatory Incubation Programme (ARIP).
- Introduce a Two-Stage Application Process: Implementing an initial expression-of-interest screening phase would concentrate effort on shortlisted candidates, saving both applicants and the CBN significant administrative time and resources.
- Apply Proportionality Across VASP Categories: A RegTech tool or non-custodial wallet should not face the same evidentiary burden as a stablecoin issuer or third-party custodian. A tiered documentary matrix is necessary to keep the Sandbox accessible to lower-risk innovators.
- Distinguish Pre-Admission Requirements from In-Sandbox Milestones: Time-intensive deliverables, such as full penetration tests or completed board policy libraries, should be conditionally accepted at admission as milestones to be satisfied before customer onboarding, rather than pre-conditions to apply.
- Provide Pre-Launch Applicant Guidance: Clear guidance is needed for pre-revenue startups answering questions that presuppose an operating history (e.g., historic transaction volumes or prior STR filings).
- Publish Templates and Data Safeguards: Releasing standardized templates for KPIs, sponsorship letters, and ownership charts, alongside a clear policy on how sensitive personal and corporate data will be secured and retained, will streamline submissions and build applicant trust.
- Streamline Jurisdictional Overlap: To eliminate duplicative filings, the CBN and the Securities and Exchange Commission (SEC) should coordinate a mutually-recognized intake for activities that straddle both mandates.
- Clarify the CBN/SEC Perimeter: The CBN should explicitly exclude VASPs whose operations (like tokenized products, exchange services, and broad digital asset custody) fall squarely under the SEC’s investment mandate. The CBN Sandbox should remain focused strictly on monetary transmission, stablecoins, digital wallets, and fiat on/off-ramp services.
A Spirit of Genuine Partnership
Signed by Franklin Peters (Executive Chair), Hissan Siita Sofo (Secretary-General), and Favour Uche (Lead, Policy and Regulatory Affairs), the letter concludes by reaffirming VASPA’s alignment with the CBN’s objective of a safe, well-regulated digital asset market.
“We are confident that a modest adjustment to the timeline, together with the measures recommended above, will materially widen and deepen participation in the inaugural cohort—to the benefit of the market, the consumer, and the Bank’s own supervisory objectives.”
The complete submission, available here in PDF, has been copied to the Governor of the Central Bank of Nigeria and the Director-General of the Securities and Exchange Commission.
Media Enquiries:
Policy & Regulatory Affairs Unit, VASPA
policy@vaspa.org
