Does the CBN's $10,000 a day limit apply to your business?

A domiciliary account is a Nigerian bank account held in a foreign currency, usually dollars. Form A is the application you fill in to pay for a service abroad. The wider picture of what changed this year is in Nigeria's money rules in 2026, and this piece is about the one figure everybody quotes.

What is the $10,000 a day limit, and where does it come from?

The $10,000 a day figure comes from the Fourth Edition of the CBN's Foreign Exchange Manual, which replaced the 2018 edition and took effect on 1 June 2026. The change it describes is that an ordinary domiciliary account holder can send money abroad up to $10,000 a day without the full trade documentation pack, and without a Form A.

Before this, moving money out of a domiciliary account meant completing a Form A and supplying the papers behind it, even where you had funded the account yourself. A comparison of the new manual against the previous edition, published on 2 June 2026, records the Form A requirement on ordinary domiciliary remittances as no longer applying, while noting banks still have to check the purpose of what you send.

The two published readings of the daily figure don't agree on what the $10,000 actually measures, and the difference changes what you can do:

• Pavestones Legal, on 12 June 2026, describes it as direct telegraphic transfers of up to $10,000 a day, without triggering exhaustive trade documentation. A telegraphic transfer is the instruction your bank sends another bank to pay money abroad.
• The Sun, on 8 June 2026, describes it as cash deposits of up to $10,000 a day being usable for telegraphic transfers, provided the bank reports the purpose.

Those are different rules. One is a ceiling on what you can send; the other is a ceiling on how much cash you can pay in and then send. Get your own bank's answer in writing before you plan a payment around either, because the two readings would give you different answers on the same transfer.

Does the $10,000 a day limit cover your company's transfers?

Every dated reading of the manual attaches this relaxation to ordinary domiciliary accounts held by individuals. BusinessDay's report, on 3 June 2026, says ordinary domiciliary account holders are guaranteed unfettered and unrestricted access to their funds, and that Form A “is no longer mandatory for remittances funded directly from these personal accounts”. It describes no equivalent relaxation for corporate accounts.

What it means for you: if you run a CAC-registered company and you were expecting your corporate domiciliary account to get the same treatment, nothing published says it does. The safest planning assumption is that your company's outward payments still sit under the documentation rules that applied before June, and that your relationship manager will ask for the same papers.

The manual itself is firm about the route a company has to use. Memorandum 2, item 3 says payments for imports of goods and services must be remitted through an Authorised Dealer Bank, which is a bank the CBN has licensed to handle foreign exchange. Memorandum 14 goes further on domestic pricing, stating that using foreign currency to pay for goods and services inside Nigeria is prohibited except where a law permits it, and that one Nigerian company billing another must price and be paid in naira.

So there are two questions to separate, and people run them together. Whether you can hold dollars freely is one question, and the answer got better this year. Whether your company can send those dollars abroad on light paperwork is a different question, and nothing published says it did.

What does the $10,000 in the manual itself refer to?

Read the manual's own text and the $10,000 you find is about cash crossing the border, not about a bank transfer. The Foreign Exchange Manual, Fourth Edition, Memorandum 7, sets $10,000 as the point at which foreign currency you carry in or out has to be declared. That is a separate rule from the daily transfer allowance, and it is the one written down in the document.

The thresholds in the manual's own words:

• Bringing currency in: foreign currency “not exceeding US$10,000.00 or its equivalent” needs no declaration. Above that, it “shall be declared at the point of entry” (Memorandum 7, Import, item 1(a)).
• Taking currency out: up to $10,000 needs no declaration. Above $10,000 and up to $50,000, the whole amount must be declared at the point of exit (Memorandum 7, Export, item 2(a)).
• Above $50,000: you also need evidence of a transaction or procurement through an Authorised Dealer (Memorandum 7, Export, item 2(a)(iii)).
• The declaration itself is made on Forms TE and TM, which Memorandum 4, item 2 names as the forms for declaring currency and other instruments above $10,000.

The practical consequence is that a business owner who reads “$10,000” and plans to carry cash to a supplier is reading the right rule, and one who plans to wire $10,000 a day from a company account on no paperwork is reading the wrong one.

Why will your bank ask for more paperwork, not less?

Because the same manual that removed a form put a large fine on the bank for getting the records wrong. The Sun's report, on 8 June 2026, says the manual carries a penalty of ₦100 million for documentation failures, plus ₦10 million for each transaction found to be in breach. That exposure sits with your bank, not with you.

Banks also have a new recording job on every transfer. They must record the purpose of every transaction and classify it correctly under the Foreign Exchange Management System code book, which is the CBN's list of transaction purpose codes. BusinessDay reports the same obligation for third-party transfers out of export proceeds accounts, with the purpose stated by the account holder and reported by the bank.

What it means for you: the form you no longer fill in has been replaced by a question your bank has to answer accurately, and the answer comes from you. Expect to be asked what a payment is for, in terms that fit a code, and expect a payment to sit still until somebody is satisfied with that answer.

Two things make this smoother in practice:

1. Tell your bank the purpose of the payment before you send it, in the words of the invoice rather than in your own shorthand.
2. Keep the invoice, the contract and the proof of what the money was for together, in one place, per payment. A bank facing a ₦100 million exposure will ask for them again later.

What changed for a company's export proceeds account?

For exporters the manual tightened rather than loosened. An export proceeds account is the domiciliary account your foreign sales revenue lands in. BusinessDay's report of the new rules says cash withdrawals from export proceeds domiciliary accounts “are no longer permitted”, and that access for eligible transactions is subject to documentation requirements for the specific transaction.

The rest of what BusinessDay records on these accounts:

• A third-party transfer needs the account holder to state the purpose, which the bank then reports using the Foreign Exchange Management System sectoral utilisation codes.
• Access has to comply with the existing money-laundering and terrorism-financing rules.
• International companies in extractive industries, excluding indigenous firms, may repatriate 100% of export proceeds through Authorised Dealer Banks, subject to adequate documentation and monthly reporting to the CBN.

So the headline that personal dollar accounts were freed and the headline that exporters got more oversight are both about the same document. If your company earns abroad and banks that money in Nigeria, the June changes gave you a reporting obligation rather than a relaxation.

Do you still need Form M and Form A if you pay through a fintech?

Form M still applies if goods are coming into Nigeria, whoever moves the money. Form M is the import declaration your bank registers before the goods ship, and it follows the goods rather than the payment route. Changing provider doesn't remove it. The full position on both forms is in do you still need Form A and Form M in Nigeria in 2026.

Form A is the one that moved, and it moved for a specific case: an outward remittance for a service, funded from an ordinary domiciliary account. If you are paying for a service abroad out of a dollar balance you funded yourself, that is the case the reports describe.

The thing to be clear about with any non-bank provider: the $10,000 a day allowance and the Form A waiver are described as features of a domiciliary account at an Authorised Dealer Bank. A fintech dollar account isn't that, so neither the allowance nor the waiver is the thing you would be relying on. You would be relying on whatever that provider's own process requires, and on the import rules still applying. Daya Business is one of those providers, and how to pay international suppliers from Nigeria covers what each route asks for.

Where does Daya Business fit?

Daya Business is for a CAC-registered Nigerian company that needs to collect foreign currency and pay abroad without going through a bank's domiciliary account for every leg. Its own page says a business can receive US dollars, British pounds and euros, hold them, and convert between dollars and naira.

On payouts, daya.co/business lists four routes: bank transfer, wire, ACH, and on-chain in USDT or USDC. Opening an account needs CAC registration and business verification, which means BVN or NIN, personal identification, CAC documents and director details. A sole trader without a registered company is pointed to Daya Borders instead.

What that means against the rule this article is about: Daya Business isn't a domiciliary account at an Authorised Dealer Bank, so the $10,000 a day Form A waiver isn't what you would be relying on when you pay through it. And it changes nothing about Form M. If you're importing goods, the declaration still follows the goods.

Where Daya Business isn't the pick: if the payment you're making is an import that your bank has to document on a Form M anyway, the bank is doing a job your provider can't take off you, and you'll be running both. Ask any provider, Daya included, what record you get after a payment, because that record is what your accountant and your auditor will want. Corporate domiciliary account versus a business USD account sets the two routes side by side, and best business dollar accounts in Nigeria compares the providers.

How much can you move inside Africa on basic documentation?

$5,000 a month for a company, if the payment goes through PAPSS. PAPSS is the Pan-African Payment and Settlement System, which settles payments between African countries in local currencies. The manual's Memorandum 13, item 33(i) says basic know-your-customer and anti-money-laundering documentation is acceptable for transactions up to $2,000 for individuals or $5,000 for corporates, or the equivalent monthly.

Above those amounts, full documentation applies. The manual also says that export proceeds repatriated under PAPSS are subject to certification by the processing banks.

This is the one genuinely light-documentation route in the manual with a number attached to a company, and it is small. It suits a recurring payment to a supplier or contractor elsewhere in Africa rather than an import run. Ask your bank whether it is connected to PAPSS before you plan around it, because not every Nigerian bank offers it on the same terms.

What should you do before your next payment abroad?

Five things, and all of them are quicker than having a payment held:

1. Ask your bank, in writing, whether the $10,000 a day allowance applies to your company's account or only to personal ones.
2. Ask which of the two published readings your bank follows, a ceiling on the transfer or a ceiling on cash paid in.
3. Work out whether what you're paying for is goods or a service, because that decides whether a Form M is in play at all.
4. Write the purpose of the payment down in the words of the invoice, so your bank can classify it without coming back to you.
5. If you earn export revenue, check what your bank now needs from you on a third-party transfer, because that is the part that got stricter in June.

None of this is a reason to delay a payment you need to make. It's the difference between a transfer that goes out today and one that sits in a queue while somebody asks you what it was for.