In a bid to enhance accountability and strengthen consumer protection within the digital lending ecosystem, the Federal Competition and Consumer Protection Commission (the FCCPC or Commission) has issued the Digital, Electronic, Online, or Non-Traditional Consumer Lending Regulations, 2025 (the Lending Regulations), which came into effect on 21 July 2025.
This follows the Commission’s prior measures to address unethical and predatory practices within the digital lending ecosystem, particularly through the issuance of the Limited Interim Regulatory/Registration Framework and Guidelines for Digital Lending 2022 (the Interim Guidelines).
The Lending Regulations establish a definitive legal framework for the provision of Consumer Lending Services in Nigeria in relation to registration, compliance obligations, consumer protection and competition safeguards to be adopted, and the applicable penalties for contravention of any provisions thereof.
In this Newsletter, we provide an overview of the notable changes introduced by the Lending Regulations and assess their likely impact on the digital lending industry in Nigeria.
What the Consumer Lending Regulations cover
The scope is wide. The Regulations reach any Consumer Lending Service offered by digital, electronic, online or other non-traditional means, where the lender expects repayment or a return. That return can be money, airtime, data, cashback, services or barter. The rules also catch vendors, partners and collaborators that take a share of lending revenue. As a result, telecommunications companies, mobile money operators, agritech platforms and barter-based schemes now fall inside the framework.
The Regulations also close a jurisdictional gap. They apply to a lender that operates within a single state, and to one whose operations span several states or run on technology built to reach beyond one state. Banks and other institutions licensed under the Banks and Other Financial Institutions Act 2020 are exempt. However, a lender that piggybacks on a finance company or microfinance bank licence through a partnership must still obtain FCCPC approval.
Approval, fees and partnership scrutiny
Every lender and service provider must apply for and obtain prior FCCPC approval. The fees are a non-refundable application fee of ₦100,000 and a registration fee of ₦1,000,000, which covers up to two software applications, plus ₦500,000 for each further application. Existing operators had 90 days from commencement, to 19 October 2025, to regularise and to sign fresh Consumer Lending Services Agreements. The FCCPC then has 30 days to review an application, and an approval lasts three years.
Partnerships face close review. Each partner’s agreement goes to the FCCPC with the application, and the Commission may treat several parties as one joint application. If one partner falls short, the Commission can refuse the whole application, though we expect it to allow a replacement partner in many cases. After approval, a lender cannot change partners or amend the agreement without the FCCPC’s consent.
Disclosure, data sharing and sanctions
Lenders must publish clear information on rates, fees and charges, and state their terms in plain English. They report to the FCCPC every six months, file annual returns by 31 March, and keep transaction and complaint records for at least five years. Where the Commission or a sector regulator requires it, a lender must also share service data with a recognised credit bureau, which helps build credit histories for informal-sector borrowers.
Telecommunications companies that lend airtime or data had until 19 September 2025 to engage at least two service providers for activation, one of them wholly Nigerian owned. The penalties are heavy. A natural person faces a fine of up to ₦50,000,000, and a company faces up to ₦100,000,000 or 1% of annual turnover, whichever is greater. A director can be fined or disqualified for up to five years where the company is in breach. Our note on the key takeaways from the CBN Fintech Report 2025 and our Technology, Innovation and Fintech 2025 Wrap-Up give the wider regulatory picture.
Click the button below to read our full analysis of the Consumer Lending Regulations 2025 and the compliance steps lenders should take now.
