- Access Holdings, UBA, Zenith Holdings win big
- UK seen as profit engine for banks
- 2025 numbers show “UK + Africa vs Nigeria” split
- FY2026 to show consolidated HoldCo
Ahead of the 2026 financial year-end reporting by Nigerian banks, an analysis of the country’s Tier-1 lenders popularly known as FUGAZ banks, is pointing to a fundamental but interesting outcomes that would be shaped by the June 2026 draft rules on Financial Holding Companies (FHC) by the Central Bank of Nigeria (CBN).
The analysis using the two key goals of the CBN in the FHCs draft rules, attempts to project what financial year 2026 reporting would look like for FUGAZ who operate on a holding company basis.
The CBN has directed in the draft rules that financial institutions in the country operating foreign subsidiaries must have them held under the HoldCo, not the Nigerian bank. It also directed that HoldCo must own 51 percent of all banking and non-banking subsidiaries.
Michael Ogbonna, a corporate and commercial lawyer and former banker, in an exclusive analysis for Business a.m. and published in this edition, used the 2025 audited reports of the FUGAZ banks to examine how they are each positioned for the HoldCo model in the face of CBN’s draft HoldCo rules.
“The 2025 numbers already show a clear “UK + Africa vs Nigeria” split, and they reveal which FUGAZ bank is structurally best positioned for the new HoldCo model,” he writes.
According to the analysis, most foreign subsidiaries of the financial holding companies sit directly under their Nigerian bank, but with the draft requiring them to be restructured under a HoldCo within 12 months, the reporting impact for the FUGAZ banks will see that instead of “Nigeria vs International” segments inside the bank, FY2026 will show a consolidated HoldCo with distinct buckets: “Nigerian Bank”, “UK Subsidiaries”, “Rest of Africa”, and “Non-Banking”, adding that intercompany eliminations and dividend flows will sit at HoldCo level.
Using what he called the “2025 precursor test”, Ogbonna’s analysis shows that Access Holdings, United Bank for Africa (UBA) and Zenith Bank will emerge winners in the first reporting round under the implementation of the CBN’s FHC draft rules.
“Using 2025 as a model three winners emerge,” the analysis states, adding that Access Holdings will emerge in the first position because it is already the most “HoldCo-ready” as it has the largest UK book at ₦288.6 billion PBT, plus material African and non-banking subs: ARM Pensions ₦13.1 billion PBT, Hydrogen Payments +273% PBT growth, and Oxygen X ₦2.2 billion PBT in H1.
“With 52 percent of banking profit already outside Nigeria, Access will show the cleanest HoldCo diversification on day one,” the analysis shows.
It however notes that Access Holdings’ ₦189.7 billion lead over its #2 UK peer “is structural, not cyclical.”
The second position will go to UBA, the analysis states. This view is backed up by the fact that UBA has the advantage of breadth.
“It is in 19 African countries plus the UK, France, UAE, and the US. While UK numbers are not disclosed, the ‘Rest of Africa’ is estimated at ~₦120 billion – ₦140 billion PBT. The June rules reward geographic diversification under one HoldCo umbrella. UBA’s 30-32 percent international PBT share will translate directly to a larger “HoldCo International” line than Zenith or GTCO,” Ogbonna stated in his FUGAZ analysis.
He drew attention to the fact that UBA presents an interesting play, despite the underperforming Nigerian arm bulging down with NPL above 10 percent while Access is 2.5 percent.
This interesting play is well captured in the following numbers by Zrost Investment Management, which noted that UBA PLC investment @ foreign subsidiaries was about N200 billion, but added that it had about N600 billion revenue last year and the investment is worth N2 trillion today while the total worth in NGX by today’s price is about N1.9 trillion.
The analysis also shows that the other two FUGAZ financial holdCos, Guarantee Trust Company (GTCO), which parents GTBank, and FirstHoldco, will lag under the new model for some reasons.
According to the analysis, GTCO’s GTBank UK fell to ₦17.9 billion and International is ∼15 percent of group PBT.
“The HoldCo structure will expose GTCO’s relative underweight to offshore earnings,” Ogbonna wrote.
For FirstHoldCo, and based on the mid-2025 financial report breakdowns which this analysis draws on, and recognising that First HoldCo’s 2025 foreign subsidiary figures were not publicly disclosed or completely aggregated, it would appear as if it missed out on the ₦399.2 billion mid-term UK profit pool entirely.
The analysis further disclosed that outside the UK, all five banks captured their African subsidiaries’ operations, noting that in aggregate, “International” earnings are already material.
“Access reported that banking subsidiaries contributed 65 percent of Banking PBT in H1 2025, and African + International ops delivered 52 percent of Access Banking PBT for the full year.
“UBA, the most pan-African, is estimated at ∼30-32 percent of group PBT from outside Nigeria, with the ‘Rest of Africa’ contributing ~₦120 billion-₦140 billion,” it stated.
Summing up, Ogbonna’s analysis states that “the June draft does not change the economics of 2025, but it changes the lens,” noting that FY2025 shows that Access and UBA win because they already derive the majority of growth and a large share of profit from the UK and Africa. Under HoldCo reporting, that diversification becomes the headline, not a footnote.”
