Banks Yet To Meet CBN Recapitalization Requirements

With less than three months remaining until the Central Bank of Nigeria’s (CBN) March 31, 2026, recapitalization deadline, the Nigerian banking sector is in a state of heightened activity.

As of early January 2026, approximately 22 banks have successfully met the new minimum capital requirements, while around 14 others are still working to comply, raising the possibility of mergers, acquisitions, or license downgrades for those lagging behind.

Financial experts predict an acceleration in capital-raising efforts in the coming weeks, with some banks expected to announce compliance by the end of January.

What Led To The Recapitalization Exercise?

The CBN initiated the recapitalization program in March 2024 to bolster the resilience of Nigeria’s banking sector amid economic challenges, including inflation, currency volatility, and the need to support President Bola Ahmed Tinubu’s vision of a $1 trillion economy by 2031.

The directive requires banks to increase their minimum paid-up capital within a 24-month window, from April 1, 2024, to March 31, 2026.

This marks the first major recapitalization since 2005, aimed at enhancing banks’ capacity to absorb shocks, expand lending to the real sector, and align with global standards.

Capital thresholds vary by license type
Banks with international authorization ₦500 billion, National banks ₦200 billion, Regional banks ₦50 billion, Merchant banks ₦50 billion, Non-interest banks (national) ₦20 billion, Non-interest banks (regional) ₦10 billion

Banks can meet these requirements through rights issues, private placements, public offerings, mergers/acquisitions, or by downgrading their licenses.

The CBN has emphasized that the exercise will strengthen financial stability, deepen inclusion, and position banks for growth in key sectors like healthcare, transportation, and technology.

As of November 2025, only 16 banks had complied, but the number has risen steadily, reflecting strong investor confidence despite economic headwinds.

The process has not been without challenges. Some banks have faced delays in regulatory approvals, while others have pursued strategic divestments or capital injections from parent companies.

Industry analysts warn that non-compliance could lead to forced consolidations, echoing the 2005 exercise that reduced the number of banks from 89 to 25.

Banks That Have Met The Recapitalization Requirements

As of January 2026, market intelligence indicates that around 22 institutions have achieved compliance, including all major Tier-1 listed banks.

This includes recent additions like United Bank for Africa (UBA), which crossed the ₦500 billion threshold following a ₦178 billion rights issue, and First Bank of Nigeria, which met its requirement through a combination of rights issues, private placements, and divestments. Standard Chartered Bank Nigeria fulfilled its ₦200 billion national bank requirement in November 2025 via internal capital strengthening and balance sheet management.

A comprehensive list of banks that have met the required capital benchmarks, organized by license type according to verified reports:

International Banks (₦500 billion)
Access Bank, Zenith Bank, UBA, GTBank (GTCO), First Bank of Nigeria, Fidelity Bank

National/Regional Banks (₦200 billion / ₦50 billion)
Citibank Nigeria, Ecobank Nigeria, Globus Bank, Stanbic IBTC Bank, Sterling Bank, Wema Bank, PremiumTrust Bank, Providus Bank, Standard Chartered Bank Nigeria

Merchant Banks (₦50 billion)
FSDH Merchant Bank, Greenwich Merchant Bank, Nova Bank

Non-Interest Banks (₦10–20 billion)
Jaiz Bank, Lotus Bank, TAJBank, Alternative Bank

These banks have demonstrated robust strategies, with many exceeding requirements well ahead of schedule.

For instance, First Bank’s achievement was hailed by Chairman Femi Otedola as positioning the institution for accelerated growth and innovation.

Similarly, Ecobank and Stanbic IBTC leveraged parent group support to comply early. The CBN has commended the progress, noting it enhances the sector’s ability to support economic transformation.

List Of Banks That Have Not Met The Recapitalization Requirements

Despite the advancements, about 14 banks remain non-compliant as of early January 2026, with efforts ongoing to close their capital gaps.

These institutions are intensifying fundraising, with some exploring mergers or acquisitions to avoid penalties, such as license revocation or forced takeovers.

The list includes a mix of commercial, merchant, and non-interest banks, many of which have announced plans but await verification.

The banks yet to meet the requirements include:

International/National Commercial Banks (₦500 billion or ₦200 billion)
First City Monument Bank (FCMB), Unity Bank, Keystone Bank, Union Bank (post-merger with Titan Trust Bank), Polaris Bank.

National/Regional Commercial Banks (₦200 billion/₦50 billion)
Parallex Bank, SunTrust Bank, Signature Bank, Optimus Bank.

Merchant Banks (₦50 billion)
FBNQuest Merchant Bank (also referred to as FBH or FBN Merchant Bank), Rand Merchant Bank, Coronation Merchant Bank.

Non-Interest Banks (₦20-10 billion)
Taj Bank, Alternative Bank, and certain smaller regional non-interest players.

FCMB and Union Bank are reportedly in advanced stages of capital raises, while Keystone and Polaris have kept strategies under wraps, sparking speculation about potential mergers.

Analysts expect announcements from several of these banks soon, as the deadline pressure mounts.

In conclusion, the recapitalization exercise is reshaping Nigeria’s banking landscape, with compliant banks poised for expansion and non-compliant ones facing critical decisions.

The CBN continues to monitor progress closely, assuring stakeholders of a stable transition.

As the March 31 deadline nears, the sector’s evolution could lead to a more consolidated and resilient financial system.