By Suleyman A. Ndanusa PhD OON
I warmly congratulate the Securities and Exchange Commission and Nigeria’s wider capital market community on the progress made over the past decades. The passage of the Investments and Securities Act 2025, the transition to T+1 settlement, and the growth of collective investment scheme assets from ₦263 billion to more than ₦9.3 trillion are significant milestones. They strengthen the foundations for a market that can serve investors better, channel more savings into productive use and help Nigerian businesses and public projects access long term capital. This progress deserves recognition and provides a strong platform from which to consider the unfinished work and greater ambitions of Masterplan 2.0.
Nigeria’s first Capital Market Masterplan, launched for 2015–2025, set out to make the market more useful to the national economy, strengthen its structure and competitiveness, and improve regulation and oversight. Non-interest finance and capital market literacy were also developed as complementary plans. The 2021–2025 revision brought those areas into the main strategy and introduced four updated themes, 21 objectives, 55 initiatives, targets, measures and a revised governance structure.
That evolution was sensible, but the implementation record is mixed. The SEC’s earlier review identified the 2016 recession, oil-price shocks, foreign exchange volatility and the COVID-19 pandemic as serious headwinds. It also identified problems that a strategy could have addressed more directly. The plan was not embedded in the Federal Government’s economic programme; stakeholder support and coordination were uneven; data were weak; and progress was often measured by whether activities were completed rather than whether they produced the intended results. Masterplan 2.0 reports that 63% of activities were completed by 2025, but only two of 21 macro-objectives were fully achieved. Because the new plan does not give a separate final score for the revised 2021–2025 edition, it would be premature to attribute that overall result to the revision alone. The lesson is not that planning has failed, but that implementation, institutional ownership and outcome measurement have not yet matched the ambition.
Malaysia offers a useful, though not directly comparable, benchmark. Its first Capital Market Masterplan (2001–2010) focused on building the market’s foundations; its second (2011–2020) pursued further growth alongside stronger governance and stability. Nigeria’s 2021 review cited Malaysia’s first plan as achieving 95% implementation, with substantial growth in equity, corporate debt and Islamic finance. Malaysia’s Securities Commission reported that the overall market expanded from RM2.0 trillion in 2010 to RM3.4 trillion in 2020. Yet Malaysia’s progress was not uniform: its corporate debt market contracted over the second plan period even as Islamic finance grew. The lesson is not to copy another country’s targets, but to build successive plans around a clear sequence, accountable delivery and honest assessment of results by market segment.
Masterplan 2.0 is a logical progression from Nigeria’s earlier plans. It turns broad themes into five clearer pillars: regulatory clarity and enforcement; modern infrastructure; broader issuance and product choice; a deeper investor base; and stronger institutional and professional capacity. The pillars recognise that these changes depend on one another. New products need clear rules and functioning infrastructure; issuers need investors; investors need confidence, choice and reliable protection.
Regulatory reform is therefore more than one pillar among five: it is the framework that enables the rest. Masterplan 2.0 proposes consolidating SEC rules, codifying established practices, strengthening coordination among regulators, and making the process for developing and reviewing regulations more transparent. It also addresses supervision of digital and tokenised assets, systemic risk, investor protection, derivatives, sustainable finance and sub-national issuance. Nigeria should make this framework clear and predictable while keeping requirements proportionate to risk. Rules that are duplicated, slow or inconsistently enforced can deter issuers. Innovation without sound supervision can damage the confidence the market is trying to build.
The regional ambition deserves equal prominence. West African regulators and exchanges have pursued capital market integration through WACMIC since 2013, with a phased approach from sponsored trading access to passported brokers and, ultimately, a common regional market. Nigeria also participates in the African Exchanges Linkage Project. Masterplan 2.0 calls for an AfCFTA aligned regional strategy, a dedicated West African working group, regulatory recognition, prospectus passporting and cross border listings. It expects early outputs including the first cross border listings and African Depositary Receipt issuances in Years 2–3. This is not an ambition to leave until 2036; it is a programme that should begin early, build on existing regional work and publish milestones towards deeper integration.
To attract African companies to dual-list in Nigeria, the market must offer more than a welcome. Issuers need access to capital and investors, credible liquidity, transparent disclosure, manageable compliance costs, dependable custody and settlement, and confidence that dividends and sale proceeds can move predictably. Nigeria already has building blocks: the NGX provides for dual listings and depositary receipts, while its cross-border rules include a fast-track assessment for eligible foreign issuers. The SEC exposed proposed rules on cross border securities trading and custody in July 2026. These steps should be brought together into a clear regional issuer offer: a passport for issuers supervised by recognised regulators; one coordinated SEC -NGX application process with published decision timelines; and practical arrangements for fungible shares, depositary receipts, local custody, currency choice, settlement and investor recourse. Recognition should depend on credible standards and effective supervision, with appropriate Nigerian safeguards not blanket exemptions.
Nor will a faster listing process be enough if the shares do not trade. Nigeria should connect cross border listings to regional trading links, equip brokers and custodians to serve investors across borders, encourage analyst coverage and ensure that eligible securities can be considered by domestic institutions under clear prudential rules. Any fee incentives should be transparent, time limited and tied to outcomes such as new capital raised or sustained public float. The scorecard should count active issuers and measure capital raised, local ownership and trading, liquidity, settlement performance, application times and investor complaints. Listing numbers alone are not evidence of integration if trading remains thin.
The plan’s own benchmarks point in the right direction but could support a bolder vision. It targets listed domestic company capitalisation of 60% of GDP and 250 listed companies by 2036. The plan describes the company target as comparable with Egypt’s, while below South Africa’s. Those are meaningful measures of market development, but they do not express a clear leadership ambition. Nigeria should state that it intends to become West Africa’s leading capital market and set out selected African leadership goals for example, to rank first by 2036 in the value of cross border capital raised by African issuers on its markets. Such targets should use published baselines and interim milestones, and should be complemented by measures of real liquidity, free float, investor diversity and productive capital formation. Market size alone can be distorted by inflation and currency movements.
The success factors are clear: sustained political sponsorship; firm commitments from agencies beyond the SEC; predictable, costed funding; capable institutions; reliable data; and disciplined sequencing with public reporting against outcomes. The central test is whether more viable businesses and infrastructure projects can raise long-term finance, whether investors have more trusted and liquid choices, and whether African issuers increasingly choose Nigeria as a place to raise and trade capital.
Masterplan 2.0 is a stronger and more candid framework than the plans before it. It connects national development, regulatory reform and regional integration in a way that can give Nigeria a more consequential role in African finance. The journey deserves recognition. The next chapter should be more audacious: not simply to build a larger market, but to become the market that African issuers and investors choose and to measure that leadership in outcomes the public can see.
Suleyman A. Ndanusa, PhD, OON, is an economist, lawyer, strategic studies scholar, and public policy thinker and practitioner with extensive experience in financial markets, regulation, governance, national Security and development.
