In June 2025, the Central Bank of Nigeria (CBN) issued a directive that has become operational over the past few weeks. According to TheCable, the CBN directed banks to suspend foreign investment and capped equity investments in foreign subsidiaries at 10 percent of total shareholders’ funds. The regulator also gave lenders a 12-month window to comply. The rule rests on Section 19(8) of the CBN guidelines for financial holding companies. According to Innocent Ike, Group Managing Director of Access Holdings, quoted by BusinessDay, “as of 2025, the foreign matter was flagged under Section 19 subsection 8, which limits investment in foreign banking subsidiaries to 10 percent of shareholders’ funds. The holding company has been given a 12-month window to fully remediate this, and we are fully engaging with the Central Bank of Nigeria to ensure this is resolved”.
The rule has just produced its first major operational consequence. On 5 May 2026, during an investor call in Lagos, Access Holdings, parent company of Nigeria’s largest bank by assets, announced that it will reduce its equity stakes in some of its foreign subsidiaries. The group’s current exposure is well above the cap. According to Bloomberg via TheCable, Access Holdings’ current exposure stands at 19.4 percent. “We are looking at divestments to bring down our equity stake. We will still be the controller of those banking entities, and the value creation will continue to be strong”.
The order of magnitude is significant. According to Ecofin, Access Holdings reported shareholder equity of 4.253 trillion naira ($3.09 billion) as of December 31, 2025. Under the new CBN threshold, Access Holdings would only be allowed to hold around 425.3 billion naira in foreign banking investments. A single recent transaction already exceeds this cap: the AfrAsia Bank Mauritius acquisition alone cost 611.1 billion naira, a figure that exceeds the entire 10% cap on its own.
The question this article addresses is what this regulation signals beyond the Access Holdings case, and what consequences it produces for African regional banking.
Reading: an explicit prioritisation of the domestic market
The regulatory framing is not ambiguous. According to Business Post Nigeria, citing the Access Bank CEO, the goal is to help contain risk and preserve capital, which are fundamental to long-term financial system stability. Analyses converge on a more pointed reading: a move analysts say is designed to redirect more banking capital toward the domestic economy. Ecofin adds that the CBN’s decision reflects a broader effort to keep more banking capital inside Nigeria and channel funding toward the local economy. By limiting how much capital financial groups can commit to foreign subsidiaries, the regulator is signaling that domestic lending and investment should remain the priority for Nigerian banks.
This regulation is consistent with the broader CBN policy sequence under Governor Olayemi Cardoso. The recapitalisation programme launched in 2024, which required commercial banks with international authorisation to raise a minimum of 500 billion naira, concluded on 31 March 2026. As BusinessDay reported, in less than 21 days to the deadline, no fewer than 31 banks had met the new capital rule, leaving out two that were reportedly awaiting verification. The combined shareholders’ funds of the five tier-1 lenders reached a new high: the combined shareholders’ funds of Access Holdings Plc, United Bank for Africa Plc, Zenith Bank Plc, First HoldCo Plc, and Guaranty Trust Holding Company Plc rose to 20.22 trillion naira in 2025, representing a 21 per cent increase from 16.72 trillion naira recorded in 2024.
The 10% foreign equity cap therefore arrives in a context where Nigerian banks have just been forced to significantly strengthen their capital base. The combination of these two measures sends a structural signal: the bank capital raised in 2024-2026 is intended to support domestic credit creation, not aggressive offshore expansion. As one analysis puts it: by limiting the proportion of shareholders’ funds that can be tied up in foreign subsidiaries, the CBN is effectively signalling that it views the Nigerian domestic market as the primary obligation of licensed Nigerian banks, with international operations subject to capital allocation discipline.
Implications: a reversal of trajectory for African pan-African banking
The first concrete implication is the partial reversal of the most aggressive Nigerian banking expansion trajectory of the past decade. As Bloomberg noted via The Billionaires Africa, the announcement marks a significant reversal in trajectory for one of Africa’s most aggressive banking expansion stories. Access Holdings will sell down stakes in some of its 24-country subsidiary network. Access Bank’s recent acquisitions (Mauritius, Tanzania, The Gambia) place the group well above the new threshold. The practical implication is that Access Holdings cannot maintain its current ownership levels across its entire international network under the new regulatory framework. It will need to identify which subsidiaries to reduce its stake in, find buyers willing to acquire those stakes at appropriate valuations and execute the transactions within 12 months.
The second implication concerns the structure of group profitability. Foreign operations have become a growing source of earnings for the major Nigerian groups. According to Ecofin, pre-tax profit from Nigerian operations fell to 584 billion naira during the last financial year, down from 723 billion naira a year earlier. Meanwhile, profit from the rest of Africa rose sharply to 284 billion naira from 144 billion naira. International operations contributed a total of 289 billion naira to overall group profit. UBA, in its own 2025 communication, has stressed this trajectory: “UBA continues to demonstrate the true strength of its Pan-African diversified model. Despite the moderation in bottom-line performance compared to the prior year’s highs, our core business engines, especially in our subsidiaries outside Nigeria delivered double-digit growth”. The 10% cap therefore arrives precisely as foreign subsidiaries are becoming a strategic profit lever; their structural readjustment will affect group consolidated results.
The third implication concerns the regional banking equilibrium. The Nigerian banks affected (Access, UBA, GTCO, Zenith, FirstBank) are present in 20 to 24 countries, particularly in West Africa, East Africa and southern Africa. Their forced repositioning opens up space in two directions. Either the divested stakes will be acquired by other African banking groups, in which case the change in control of regional subsidiaries will follow. Or the Nigerian groups will retain operational control through corporate structures (UK or other holding entities) while reducing direct equity exposure, in which case the regulatory signal will not translate into a substantive change in the regional banking footprint. Access Holdings’ CEO statement that “we will still be the controller of those banking entities” suggests the latter trajectory is being explored.
Outlook: three indicators to monitor
For decision-makers across UEMOA, East Africa and Southern Africa where Nigerian groups operate, three indicators will measure the actual reach of the 10% cap.
The first is the type of divestment structure adopted. If Nigerian groups proceed primarily through corporate restructuring (transfer of ownership to UK or international holding entities), the regulatory measure will mainly produce a balance sheet adjustment without changing the regional banking landscape. If they proceed through actual stake sales to third parties, the consequences will be deeper: change of control in some subsidiaries, opening of repositioning windows for African banking competitors (Moroccan, Kenyan, South African groups), and potential recomposition of the customer banking offer in the affected markets.
The second is the impact on intra-African banking financing. Pan-African banking groups have been a vehicle for cross-border banking flows over the past decade. A retreat of the largest Nigerian groups, even partial, modifies the supply of cross-border banking products: corporate financing for African multinationals, trade finance, intra-African correspondent banking. The conditions under which these services are now offered, and the actors that will replace them, will measure the practical impact of the regulation.
The third indicator is the conformity calendar. The 12-month deadline imposed on Access Holdings opens an execution period during which the actual sales must be structured, negotiated, approved by regulators in the various countries, and closed. The pace at which these operations are concluded, and the prices at which they are completed, will measure whether the cap is producing an orderly transition or a forced sale dynamic that affects valuations.
The 10% cap is therefore not a technical detail. It is the second leg of a coherent policy sequence: capital raising domestically, capital retention domestically. The first leg, the 2024-2026 recapitalisation, mobilised over 4.6 trillion naira in fresh capital. The second leg, the 10% cap, redirects how this capital can be deployed. For Nigerian banks, this is a constraint on their continental ambitions. For the rest of the continent, this is a reconfiguration of who actually owns and controls the regional banking pipes. The next twelve months will measure to what extent.