As the March 31 deadline for bank recapitalisation set by the Central Bank of Nigeria (CBN) expires on Tuesday (tomorrow), a handful of banks remain under pressure to meet the requirement.
The affected banks are still dealing with regulatory, legal and structural challenges that have slowed their progress, even as most of the industry has already achieved full compliance.
A review of the latest update from Proshare’s Banking Sector Recapitalisation Compliance Tracker as of March 26, 2026, shows that while most banks have met the new capital thresholds, a small group is still classified as “In Progress,” “Pending,” or “In Review,” underscoring the uneven final stretch of the exercise.
The tracking table shows that Union Bank of Nigeria remains in progress largely due to its status as a CBN-managed entity, while Unity Bank is relying on an ongoing business combination to bridge its capital gap.
Keystone Bank, still under the supervision of the Asset Management Corporation of Nigeria (AMCON), is similarly in transition, and Polaris Bank is under review with limited disclosure on its capital raise.
The Mauritius Commercial Bank Nigeria is yet to move beyond a pending status, according to the tracker.
The situation reflects what industry observers describe as a shift from purely financial constraints to more complex governance and ownership issues.
This is further compounded by a recent Federal High Court ruling that nullified the CBN’s 2024 intervention in Union Bank, reinstating its previous board and halting the recapitalisation process initiated under regulatory management.
CBN Governor Olayemi Cardoso has already signalled that some of these banks may miss the timeline, citing legal and structural complications, even as the regulator prepares to transition the sector into a stress-testing phase from April 1, marking a pivot from capital adequacy to long-term resilience.
Compliance Across Licensed Banks
Across licence categories, the recapitalisation drive has largely achieved its objective of strengthening bank balance sheets, particularly among top-tier lenders.
Banks with international licences, which require a minimum capital base of N500 billion, have all attained compliance.
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The group, comprising Zenith Bank, Access Holdings, FBN Holdings, Guaranty Trust Holding Company, United Bank for Africa, Fidelity Bank and FCMB Group, raised substantial capital through a mix of market instruments, pushing their post-recapitalisation figures well above regulatory thresholds. FBN Holdings emerged with the highest capital base in this category.
In the national licence segment, where the minimum requirement is N200 billion, most lenders have also met the benchmark.
Ecobank Nigeria required no fresh capital injection, while others, such as Stanbic IBTC and Wema Bank, raised funds through a combination of equity and hybrid instruments. Foreign-owned subsidiaries like Standard Chartered and Citibank met their obligations primarily through parent capital injections.
Regional banks, with a N50 billion threshold, have achieved full compliance, with institutions such as Providus Bank, Signature Bank and SunTrust Bank successfully closing their capital gaps.
The non-interest banking segment has also recorded full compliance, with Jaiz Bank, Taj Bank, Lotus Bank, Alternative Bank and Summit Bank meeting their respective thresholds.
Merchant banks are similarly aligned with regulatory requirements, except for the Mauritius Commercial Bank in Nigeria, which remains outstanding.
Instruments That Drove the Capital Raise
The recapitalisation exercise has been underpinned by a diverse mix of financial instruments, reflecting differences in bank size, ownership structure and market access.
Rights issues have emerged as one of the most widely used tools, enabling existing shareholders to inject fresh capital while preserving ownership structures.
Private placements have also been prominent, particularly among both large and mid-tier banks seeking quicker capital inflows without broad market exposure.
Public offers have been dominated by tier-one lenders, allowing them to raise significant funds from retail and institutional investors at scale.
In contrast, foreign-owned banks have largely depended on parent capital injections, reflecting strong backing from their global affiliates.
Business combinations, including mergers and acquisitions, have also played a strategic role. Unity Bank’s ongoing merger effort highlights this pathway, while Providus Bank’s successful combination of a merger and private placement has already delivered compliance.
Other instruments such as convertible notes, divestments and licensing capital have been deployed more selectively, depending on each bank’s circumstances.
Licensing Capital vs Market Raises
A clear distinction has emerged between banks raising capital through public markets and those meeting regulatory thresholds through licensing capital.
Large banks have leaned heavily on public offers and rights issues to build buffers well above minimum requirements, reinforcing their capacity for expansion and risk absorption.
By contrast, some smaller or newly licensed institutions have relied on licensing capital—essentially meeting the regulatory floor without significant excess buffers.
This approach is evident among certain regional banks, where capital levels align closely with minimum thresholds, suggesting a compliance-driven rather than expansion-focused strategy.
With 33 of the 37 banks tracked having announced compliance and 32 already verified by the CBN, the sector appears largely recapitalised.
However, with the recapitalisation exercise now concluded, experts say the Nigerian banking sector is set to enter a new phase, where the focus shifts from raising capital to delivering real economic impact.
Renowned economist Muda Yusuf cautioned that despite the strong progress recorded, there is an urgent need to reconnect banks to the real economy, Pinnacle Daily earlier reported.
His position is that the recapitalisation wins should not be left in the balance sheet of the banks but should result in critically lending credits to businesses, including the small and medium enterprises (SMEs).
“The recapitalisation programme has successfully strengthened the resilience and stability of Nigeria’s banking system,” he said; however, “the ultimate success of this reform will be determined not just by stronger balance sheets but by the extent to which the banking system supports investment, enterprise, job creation and economic transformation.”
“At this critical juncture, the priority must shift from capital adequacy to economic impact…Nigeria needs not just stronger banks but banks that work for the economy,” Yusuf said.
Alex is a business journalist cum data enthusiast with the Pinnacle Daily. He can be reached via ealex@thepinnacleng.com, @ehime_alex on X
