As of September 2025, only six of the country's 13 listed banks had met the CBN's new minimum capital threshold, according to Ecofin Agency reporting from 15 September 2025. The six compliant banks are Access Bank, Zenith Bank, GTBank (Guaranty Trust Holding Company), Wema Bank, Jaiz Bank and Stanbic IBTC. The remaining seven face a structured set of regulatory options: pursue a merger, attract an acquisition, downgrade their operating licence to the national tier, execute a fresh capital raise, or face direct regulatory intervention.
In June 2024 the CBN revoked Heritage Bank's licence over the bank's deteriorating financial condition.
OPTIONS FOR NON-COMPLIANT LENDERS
The prospect of a licence downgrade to the national tier offers an alternative path for banks that cannot or choose not to pursue capital raises or combinations. A national licence comes with narrower operational permissions and geographic constraints relative to an international licence.
OUTLOOK FOR CONSOLIDATION
Analysts cited by Ecofin expect the sector could consolidate from about 20 banks to around a dozen stronger players, depending on the outcome of ongoing merger and capital-raising activity. The CBN has been clear that the deadline is firm.
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