Nineteen years after Soludo, on 28 March 2024, the Central Bank under Governor Olayemi Cardoso announced the second great recapitalisation of the Nigerian banking system. Circular BSD/DIR/CON/GEN/01/006 set new minimum paid-up capital thresholds for every category of deposit-taking institution and gave the banks twenty-four months — until 31 March 2026 — to comply.
The new floors, by licence category, were: commercial bank with international authorisation, ₦500 billion; commercial bank with national authorisation, ₦200 billion; commercial bank with regional authorisation, ₦50 billion; merchant bank (national), ₦50 billion; non-interest bank (national), ₦20 billion; non-interest bank (regional), ₦10 billion. The Soludo-era floor of ₦25 billion had eroded — in dollar terms — from US$190 million in 2005 to under US$16 million by early 2024, after the cumulative naira depreciation of 2015, 2016, 2020, 2023 and 2024. The CBN explicitly framed the exercise as a restoration of real capital, not an increase in nominal terms.
A second feature distinguished the Cardoso recap from Soludo's. Banks were told they could not count retained earnings or revaluation reserves towards the new floor — only fresh equity (paid-up share capital plus share premium) would qualify. This forced even the largest banks to go to the market. Within the first nine months, eight of the country's largest tier-1 banks (Access Holdings, GTCO, Zenith, FBN Holdings, UBA, Fidelity, FCMB, Stanbic IBTC) had launched or completed rights issues, public offers or hybrid offers cumulatively raising over ₦3.6 trillion — at the time, the largest concentrated capital raise in the history of the NSE.
Unlike Soludo, Cardoso did not promise a 25-bank end-state. The expectation in the policy paper was that the twenty-five surviving commercial-bank licences of 2005 would consolidate further to roughly 15–18 banks by the deadline. Mergers began in 2025: the FBN Holdings / Access Bank exploratory talks, the Providus / Unity Bank announced merger (December 2024), the Premium Trust Bank acquisition of a tier-3 peer. The end-state is not yet written, but the architecture is. The naira floor of 2024 is, in real US-dollar terms, almost identical to the floor of 2005 — which is to say: forty years after the SAP-era licensing explosion, the Nigerian banking system has finally been re-anchored to the size of bank Nigeria's economy genuinely needs.
Figure 1
Licensed Nigerian banks, 1894–2024
Every regulatory cycle since 1952 has compressed the field. The 2005 Soludo consolidation cut ninety banks to twenty-five in eighteen months.
Figure 2
Minimum paid-up capital required to operate a bank, 1952–2024 (₦ million, log scale)
The regulatory bar has risen by seven orders of magnitude. Each step up has reset who is allowed to call themselves a Nigerian bank.