Nigeria’s banking recapitalisation has moved from policy ambition to last-mile arithmetic. With the Central Bank of Nigeria’s March 31, 2026 deadline closing in, attention has narrowed to three questions: which institutions have cleared the bar, which are still awaiting verification, and which may need a merger to stay standing.
A growing number of banks have now been counted among the early finishers in market trackers and regulatory-disclosure summaries. But recapitalisation cycles are rarely defined by the winners alone. They are defined by the holdouts, especially as the market begins to read “pending” as a narrowing of options.
The CBN’s thresholds remain the spine of the programme: ₦500 billion for commercial banks with international authorisation, ₦200 billion for national banks, and ₦50 billion for regional banks, with non-interest banks set at ₦20 billion for national authorisation and ₦10 billion for regional authorisation.
The “missing eight” — on the compliance watchlist
As the compliance window tightens, the more precise way to describe the “missing” group is not that they are failing in public, but that their position has not been settled through the same combination of bank-level announcements, transaction completion, and regulator verification that is now visible elsewhere in the system.
On that basis, eight names stand out as a practical watchlist, institutions that are not consistently counted in widely circulated compliance trackers and are not uniformly cited as having crossed the relevant threshold. They include three commercial banks with regional licences, Parallex Bank, SunTrust Bank and Signature Bank. Each faces the ₦50 billion benchmark.
The remaining five are national-authorised commercial banks for which the benchmark is ₦200 billion: Unity Bank, Polaris Bank, Keystone Bank, FCMB and Optimus Bank.
This is not presented as a regulatory finding of non-compliance. It is a market framing. What hat matters is whether an institution can move from “still in the process” to “settled”, and whether it can do so fast enough to avoid negotiating from weakness.
Mergers are no longer theoretical: the Unity–Providus template
If 2024 and early 2025 were dominated by rights issues and public offers, late 2025 and early 2026 are beginning to restore the other instrument in the CBN playbook: consolidation.
Unity Bank’s proposed merger with Providus Bank has already progressed beyond rumour and into formal shareholder action. In September 2025, Unity Bank’s shareholders approved the merger at a court-ordered meeting, endorsing a scheme structure that would dissolve Unity Bank without winding up and leave Providus as the surviving entity.
That matters because it changes incentives. Once one combination becomes the sector’s working precedent, other mid-tier and smaller banks, particularly those facing time pressure, begin to see mergers less as a last resort and more as the most realistic route to a compliant balance sheet.
Analysts have also begun to normalise this expectation. Several market outlooks now project further combinations ahead of the deadline as institutions scramble to meet the March 31 target, even when the parties are not named in public.
The compliance scoreboard is now clearer — and more nuanced
Three developments require the story to be updated from earlier versions that treated several mid-tier banks as “unconfirmed”.
Providus Bank should no longer be framed as an open question on the ₦50 billion regional threshold. Market coverage increasingly treats the institution’s recapitalisation route as merger-led and substantially advanced through the Unity combination.
Globus Bank also sits more squarely in the “completed” camp than in the “still pending” bucket. In a published interview, the bank’s chief executive said the institution had completed its ₦200 billion capital raise, subject to the CBN’s capital verification and approval.
Wema Bank, meanwhile, illustrates the difference between “completed fundraising” and “settled compliance”. Wema announced it had concluded a ₦150 billion rights issue with regulatory approvals, and market reports have cited a qualifying capital level of ₦214.7 billion. Yet some tracking summaries continue to use verification language, reflecting the principle that the final state of compliance is, ultimately, a regulatory determination.
This is not a contradiction so much as a feature of recapitalisation reporting: the market counts the money, but the regulator confirms the status.
Why “pending” can quickly become “merge”
Recapitalisation compresses time and reduces optionality. Banks that are not able to settle their status early typically face a harsher set of trade-offs: capital is more expensive, terms are more dilutive, and investor patience is thinner.
That is where mergers become the default answer. A combination can convert two borderline capital positions into one compliant institution, often with governance resets that help attract fresh money. It can also protect depositor confidence, which is the regulator’s overriding priority.
Nigeria has seen this movie before. The 2004 consolidation under then-CBN Governor Charles Soludo reduced the number of banks dramatically and changed competitive dynamics for a generation. The current exercise is more structured, but the logic is familiar: the system will not carry undercapitalised institutions indefinitely, and the final months of the window tend to produce deal-making.
A separate precedent underlines the point. Union Bank announced in September 2025 that it had completed its merger with Titan Trust Bank following final CBN approval, a reminder that consolidation can reach a clear endpoint in the modern regulatory era.
Investor entry: where the deadline creates opportunity
For large investors, private equity firms, strategic financial institutions, and deep-pocketed local groups, recapitalisation windows can function like auction windows. Time pressure often improves terms for capital providers: stronger covenants, clearer governance rights, and discounted pricing relative to normal market cycles.
Regional licences, in particular, can be attractive in a way that is easy to miss. They are less expansive than national or international licences, and therefore often less appealing for public-market narratives built on scale. But the ₦50 billion threshold is lower, and the licence still provides a platform, a deposit base, operating infrastructure, and regulatory permissions, that can be acquired faster than building from scratch. The “entry via acquisition” logic becomes even more compelling when the alternative is a late-stage capital raise into a market that is pricing risk, not optimism.
What happens next
Between now and March 31, 2026, the watchlist banks face a narrowing set of outcomes. Some may still close capital raises and move into the “completed” category; others may settle through formal combinations; a few may end up with licence adjustments that shrink ambition to match balance-sheet reality.
But the sector’s direction is already visible. The recapitalisation story is no longer merely about who can raise money. It is now about who can settle their position, through verified compliance or through deal-making, before the window closes.
Banks that have met the new CBN recapitalisation thresholds
International banks, ₦500 billion: Access Bank; Zenith Bank; First HoldCo, for First Bank; GTCO; UBA; Fidelity Bank.
National banks, ₦200 billion: Wema Bank; Citibank Nigeria; Standard Chartered Nigeria; Ecobank Nigeria; Globus Bank; Stanbic IBTC; PremiumTrust Bank.
Regional banks, ₦50 billion: Providus Bank.
Merchant banks, ₦50 billion: FSDH Merchant Bank; Greenwich Merchant Bank; Nova Merchant Bank; Rand Merchant Bank.
Non-interest banks, ₦20 billion and ₦10 billion: Jaiz Bank; Lotus Bank; TAJBank.
Note: Other sources publish longer compliance lists that include additional banks beyond early January snapshots; differences often reflect timing and whether a source counts completed fundraising versus verified compliance.