CBN Opens Regulatory Sandbox Cohort 2 to Unlicensed Nigerian Fintech Startups

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The Central Bank of Nigeria (CBN) has launched Cohort 2 of its Regulatory Sandbox, making it accessible to unlicensed fintech startups with working minimum viable products for the first time. The program runs for six to twelve months and provides supervised testing with real users under CBN oversight, culminating in a readiness assessment for a full licence application. Applicants can apply under one of two tracks: a VASP track for crypto and digital asset products, or a Non-VASP track covering open banking, payments, fraud detection, and financial inclusion services. To qualify, startups must demonstrate meaningful innovation, have no outstanding regulatory sanctions, and meet compliance requirements including AML policies, data protection, cybersecurity controls, and a named compliance officer. Experts advise builders not to pursue the VASP track unless their product genuinely involves digital assets, as it carries significantly greater regulatory and technical complexity, including SEC Nigeria oversight and blockchain analytics obligations.

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