The Central Bank of Nigeria’s second regulatory sandbox cohort has moved beyond its application stage, but the regulator has yet to publicly account for the outcome of its first cohort launched more than three years ago.
Applications for Cohort 2 closed on August 31, 2026, after the CBN introduced separate tracks for virtual asset service providers and data-enabled financial services. The virtual-asset track covers stablecoins, payments, wallets, custody and other virtual-asset products, while the data-enabled track covers services such as data sharing, payment initiation, fraud prevention and data-driven credit.
The unresolved record of Cohort 1 is significant because the CBN’s Regulatory Sandbox Framework, published in 2021, says the Bank will publish the list of firms included in each cohort and communicate decisions on participants’ sandbox-test outcomes. Where applicable, participants may receive an Approval-in-Principle subject to meeting licensing requirements.
The first cohort’s application window opened on December 6, 2022, and closed on February 1, 2023. The CBN said applicants would be informed of approval or non-approval within 60 working days after the deadline.
CBN’s published records, however, contain conflicting figures on the number of applications received. In its April 2023 CBN Update, the Bank said 291 entries were received, 58 met the eligibility criteria and 27 reached the final evaluation stage.
But a June 2023 CBN Financial Stability Report separately said more than 1,000 applications had been received by the February 1 deadline. The documents reviewed do not explain the difference between the two figures.
By August 2023, applicants were still seeking clarity on the programme. TechCabal reported on August 3, 2023 that AbdulAfeez Oguntoyinbo, founder of Esusu Africa, said the CBN had told the company it had reached the final stage of the sandbox process but had not subsequently communicated a final outcome.
The issue has resurfaced as the CBN, under Governor Olayemi Cardoso, moves ahead with a broader second cohort. Cardoso assumed office in September 2023 and formally began his tenure as governor in October 2023.
Senator Ihenyen, Lead Partner at Infusion Lawyers and Chair of the Ecosystem Growth & Advocacy Committee of the Virtual Asset Service Providers Association, told Condia on August 17, 2026 that no public list of Cohort 1 participants or their outcomes had surfaced.
Ihenyen said transparency is important to the sandbox because the programme is intended to give innovators a clearer regulatory pathway while allowing the CBN to learn from supervised testing.
The CBN’s current sandbox framework also makes clear that admission into the programme is not itself a licence to operate outside approved testing parameters. The regulator says results from supervised testing can inform future regulatory and supervisory frameworks.
For companies entering Cohort 2, the unresolved record of the first experiment leaves a straightforward question for the regulator: what happened to the firms that went through Cohort 1, and what regulatory outcomes followed their testing?
A public account of those outcomes would give new applicants a clearer picture of what happens after entering the CBN’s sandbox.
