Introduction
- The Nigerian digital lending sector has grown exponentially in recent times. Mobile lending applications and online lending platforms have emerged as a lifeline for millions of Nigerians who are excluded from the traditional banking credit system but still need quick, unsecured credit. While these innovations have supported financial inclusion, they have also attracted significant criticism, including complaints of predatory interest rates, hidden fees, borrower harassment, and unlawful access to personal data, which have placed the sector under intense regulatory scrutiny.[1]
- In response, the Federal Competition and Consumer Protection Commission (“FCCPC” or “the Commission”), exercising its powers under the Federal Competition and Consumer Protection Act, 2018 (“FCCPA”), has issued the Digital, Electronic, Online or Non-Traditional Customer Leading Regulations, 2025 (the “Regulations”). Published in the Federal Government Gazette on 21 July 2025, the Regulations set out a comprehensive set of rules governing the operations of digital lenders and other non-traditional consumer credit providers.
- The Regulations are significant for two main reasons: first, they provide a legally binding regime that brings digital lending firmly under the FCCPC’s oversight. Second, they establish an extensive compliance framework that digital lenders must now navigate, covering issues from licensing and disclosure obligations to data privacy, competition, and consumer protection.
- This article provides a summary of the Regulations, the implications for digital lenders and consumers, the interaction between the FCCPC and other regulators, and other key issues, including evaluating whether the FCCPC has the power to regulate consumer lending.
What Gives the FCCPC Power to Regulate Consumer Lending?
- Primarily, the FCCPC derives its regulatory authority from the FCCPA. Section 17 empowers the FCCPC to protect and promote consumer interest, prevent exploitative practices, and ensure fair markets.[2] The FCCPC also has the power to regulate all undertakings providing goods or services in Nigeria that comply with the FCCPA, unless specifically exempted.[3] Under Section 163, the FCCPC is empowered to make regulations and issue directives necessary to give effect to the FCCPA.[4]
- On this basis, the FCCPC has a credible statutory basis to regulate the consumer protection and competition aspects of digital and non-traditional consumer lending. This includes issues such as misleading disclosures, unfair contract terms, excessive or hidden charges, abusive recovery practices, misuse of consumer data, and anti-competitive lending structures.
- However, the FCCPC should not be understood as replacing sector regulators. Where lending activities involve banks, mobile money operators, telecommunications operators or other regulated entities, the relevant sector regulator, such as the Central Bank of Nigeria (CBN) or the Nigerian Communications Commission (NCC) remains responsible for licensing and sector supervision. The Regulations are better understood as creating a consumer protection and competition overlay, rather than a wholesale financial services licensing regime.
- Accordingly, the FCCPC’s authority is strongest in relation to non-bank digital lenders and other non-traditional lending providers that may otherwise fall outside a sector regulator’s direct licensing or regulatory framework. The more difficult issue arises where the Regulations require prior FCCPC approval of lending partnerships involving sector-regulated entities. In those cases, the concern is not necessarily that the FCCPC lacks all jurisdiction, but that the regime may create regulatory overlap, duplicative approvals and potential overregulation, as further discussed in this article.
Key Provisions of the Regulations
Applicability and Scope
- The Regulations could likely apply to a lender on a two-pronged analysis. First, they may apply because of the nature of the transaction the lender is conducting under Section 3. Second, they may apply under Section 4 because of the lender’s corporate or regulatory character.
- On applicability, Section 3 adopts a deliberately expansive “applicability” test that is both transaction‑based and participant‑based. First, Section 3(a) applies to all applicable transactions of unsecured consumer loans carried out through digital, electronic, online, or other non‑traditional means.[5] The description of “lending” (in the Regulations) is broad: it covers lending not only by cash, but also by airtime, data, cashback, services, or barter, provided the transaction involves a specific or verifiable monetary value and an expectation of repayment, regardless of how the value or interest component is calculated.[6]
- Section 3(b) extends the Regulations beyond the primary lender to the wider lending value chain.[7]It applies to every lender or provider of monetary value (in cash, services, or otherwise) and expressly extends to parties involved as a primary or secondary lender, vendor, service provider, or partner/collaborator to the extent such person or undertaking receives a benefit or a portion of the revenue associated with the transaction.[8] In practical terms, this language can capture key enabling participants, such as platforms, aggregators, or revenue‑sharing partners, where their commercial upside is linked to lending activity.
- Section 3(c) closes a potential “sector regulator” escape route by extending the Regulations to regulated‑industry operators. It states that the Regulations apply to persons or undertakings operating in a “regulated industry” under the FCCPA, citing FCCPA sections 104 and 105.[9] In effect, being subject to a sector regulator does not, by itself, remove an undertaking from the Regulations’ intended reach where competition and consumer protection issues arise.[10]
- Section 4 then addresses “scope” in a territorial/operational sense and clarifies interaction with other regulators. It extends to persons doing business in Nigeria, whether physically or electronically, and participating in commercial activity (linked back to Section 2 of the FCCPA).[11]
- The scope provisions also target regulatory arbitrage created by geography and licensing boundaries. For example, Section 4(b) covers situations where licences or jurisdiction are territorially limited (e.g., within a state), but the business is intended to operate, or in fact operates, beyond state lines, to the extent of such cross‑state operations.[12] Section 4(c) further captures any component of the business hosted, conducted, or transmitted on platforms, infrastructure, or technology that extends beyond a single state.[13]
- Finally, Sections 4(d)–(e) clarify regulatory overlap rather than creating exemptions: sector‑regulator oversight in regulated industries “shall continue” under enabling instruments “without prejudice” to these Regulations, and FCCPC approval under these Regulations does not substitute for any required licence/approval by a sector regulator. Read together, Section 4 is best understood as a scope and non‑substitution clause, confirming wide territorial reach and concurrent compliance expectations, rather than an exemption regime.[14]
- In practical terms, a digital lender can determine whether FCCPC registration/approval is required by applying a three‑step test: (i) confirm the product involves an unsecured consumer lending transaction delivered through digital/online/non‑traditional channels (including cash, airtime, data, cashback, services or barter with repayment expectation); (ii) confirm whether the business participates anywhere in the lending value chain in a manner that earns a benefit or revenue share linked to the transaction; and (iii) confirm a Nigerian nexus (business conducted physically or electronically in Nigeria / affecting Nigerian commercial activity). If these conditions are met, the lender should proceed on the basis that FCCPC approval is required, noting that operating in a regulated industry does not disapply the Regulations and that FCCPC approval does not substitute for sector-regulator licensing; compliance is concurrent.
Objectives of the Regulations
- Section 5 of the Regulations sets out the objective of the regime as the protection and promotion of consumers’ interests. This objective is not limited to preventing direct consumer harm, such as harassment, unfair contract terms or misleading disclosures. Rather, it is to be achieved by ensuring that consumers have access to a wider variety of high-quality products at competitive prices.[15] In this sense, the Regulations adopt the broader consumer welfare approach under the FCCPA, where competition and consumer protection are mutually reinforcing rather than distinct or unrelated objectives.
- Accordingly, the competition-related aspects of the Regulations should be understood as an inherent part of the consumer protection framework. Preventing anti-competitive conduct, unfair market practices, exploitative partnerships, or restrictive arrangements is one way of protecting consumers in the digital lending market. A market in which lenders or lending platforms operate transparently, compete fairly, and are unable to exploit consumers through opacity, excessive charges, abusive recovery practices, or exclusionary arrangements is more likely to produce better pricing, wider consumer choice, improved service quality and safer lending products.
- Section 6 further gives practical content to this objective by confirming the FCCPC’s functions and powers to protect and promote consumer interests, ensure that consumer interests receive due consideration, provide redress against obnoxious practices or unscrupulous exploitation, guarantee that goods and services are safe for their intended or normally expected use, reduce risks associated with consumer products and services, and ensure that service providers comply with applicable local and international standards of quality and safe service delivery.[16]
- The implication is that the Regulations proceed on the basis that fair competition is a core tool for consumer protection. This is particularly important in the digital lending sector, where consumer harm may arise not only from individual lender misconduct but also from market structures, partnership models, data-driven practices, pricing arrangements, or revenue-sharing structures that reduce consumer choice, obscure the true cost of credit, or facilitate exploitative lending practices.
Eligibility, Registration, and Approval
- A cornerstone of the Regulations is the mandatory registration and approval framework for undertakings engaged in Consumer Lending Services.[17] Section 7 requires every undertaking involved in the provision of Consumer Lending Services, whether as a lender, service provider or ancillary support provider, prior to the commencement of the Regulations, to apply to and obtain the FCCPC’s approval to continue offering such services within 90 days of commencement.[18] Nigerian-domiciled undertakings must also be duly registered with the Corporate Affairs Commission or under any other applicable statute regulating corporate registration in Nigeria.[19]
- The practical implication is that the Regulations do not focus only on digital lenders in the narrow sense. They may also capture service providers, vendors, technology partners, infrastructure providers, platform operators, and other participants in the consumer lending value chain whose roles are connected to the provision of lending services and who receive a benefit or revenue share from the transaction.
- Section 8 is particularly important for undertakings that are already subject to sector-specific regulation. It provides that where an undertaking participating in, or intending to participate in, Consumer Lending Services is otherwise regulated by another regulator, such undertaking may not enter into any agreement, contract, joint venture or other arrangement for the purpose of providing lending, vendor, ancillary, related, associated or subsidiary services unless it has a valid and subsisting licence, permit or approval from the relevant sector regulator.[20] This confirms that FCCPC approval is not a substitute for sector-regulator authorisation. Banks, mobile money operators, telecommunications-related service providers and other regulated entities must therefore ensure that their underlying sector licences permit the relevant activity before seeking or relying on FCCPC approval.
- Section 10 further prohibits an undertaking from partnering with another undertaking to provide Consumer Lending Services unless the relevant contract is presented to the FCCPC as part of an application and expressly approved by the Commission.[21] This shifts the regime beyond entity-level registration into approval of the contractual and commercial arrangements through which consumer lending products are delivered. This has significant implications for fintech and banking collaborations, as all such contractual arrangements are now subject to the approval requirements under Section 10 of the Regulations.
- Section 11 has broader implications for the fintech ecosystem. It applies where a person or undertaking operating in a regulated industry collaborates with another person or undertaking that is not licensed or regulated by the relevant sector regulator, including through joint ventures, fee-sharing arrangements, partnerships, joint operations, service provision, vendor arrangements, strategic alliances or product/service licensing arrangements linked to revenue from consumer lending activity.[22] Such collaborations are prohibited unless documented in a mutual Consumer Lending Services Agreement[23] or another service-level agreement and submitted to the FCCPC for approval. This may affect bank-fintech partnerships, embedded finance arrangements, white-labelled lending products, API integrations, loan origination partnerships, infrastructure-sharing models and revenue-sharing arrangements, including those that predate the Regulations.
- The retrospective effect on existing collaborations is a key commercial issue. While the Regulations primarily require undertakings already involved in Consumer Lending Services to apply for approval within the prescribed transition period, the breadth of Sections 10 and 11 suggests that existing partnership agreements may need to be reviewed and, where applicable, submitted to the FCCPC for approval. This may require lenders and their partners to revisit legacy API, infrastructure, service-level, outsourcing and revenue-sharing arrangements to determine whether they constitute Consumer Lending Services Agreements or otherwise support regulated lending activity.
- Section 12 sets out the documentation required for approval, including the Consumer Lending Services Agreement, application forms, evidence of payment of fees, sector-regulator licences where applicable, corporate documents, board and shareholder information, evidence of financial capacity, standard terms and conditions, and other documents requested by the FCCPC. Section 12(3) is especially significant because it requires all applicants to obtain prior FCCPC approval before consummating or implementing any Consumer Lending Services Agreement. Section 12(4) also subjects modifications, amendments, assignments, subcontracts or novation of such agreements to prior FCCPC approval.[24]
- This prior approval requirement may create practical constraints for lenders and fintech operators. It may delay product launches, slow down commercial negotiations, affect agile product iteration, and require regulatory clearance for amendments to commercial arrangements that would ordinarily be implemented quickly.
Consumer Protection Framework
The Regulations impose some of the most stringent consumer protection standards yet, covering the following areas:
- Disclosure and Transparency:[25] Lenders must disclose interest rates, fees, and repayment terms upfront in plain, clear English. Websites and other platforms must conspicuously display all current charges. Advertisements must not be misleading, exaggerated, or offensive.
- Fair Contract Terms[26]: Any provisions that unilaterally vary terms, waive statutory rights or impose disproportionate obligations are deemed unfair and void. Any attempt to exclude lender liability for misrepresentation or negligence is prohibited.
- Responsible Lending Conduct[27]: Lenders must conduct creditworthiness assessments before disbursing loans. Automatic or pre-authorised lending is expressly prohibited, and consumers must give active consent before receiving credit.
- Debt Recovery Practices[28]: Harassment, defamation, or unauthorised disclosure of borrower information is banned. Debt recovery must be conducted in line with fair lending principles and due process. This is key, given the multiple harassment reports by consumers/debtors against lenders.
- Data Protection: Lending apps must not access consumer contacts, photos, or call logs. This is also important, since most digital lenders generally request access to consumers’ contact details and leverage them as part of their recovery mechanisms. Compliance with the Nigeria Data Protection Act, 2023, is mandatory, including carrying out Privacy Impact Assessments.[29]
- Complaints and Redress:[30] Consumer complaints must be resolved within 24-48 hours; unresolved complaints may be escalated directly to the FCCPC. This raises the question of whether the FCCPC has the competence to handle these complaints, a discussion for another time. However, lenders are still obligated to comply with the Regulations.
Competition Provisions
- To mitigate the risks of concentration and abuse of dominance in digital markets, the Regulations introduce specific competition safeguards:
- Airtime and data lending providers are required to engage at least two intermediaries and/or service providers for service activation, one of which must be a Nigerian-owned entity.[31]
- Exclusivity arrangements and any conduct amounting to abuse of dominance are prohibited.[32]
- Undertakings must comply with the Restrictive Agreements Regulations 2022 and the Abuse of Dominance Regulations 2022.[33]
Reporting and Compliance Obligations
- Section 25 of the Regulations imposes extensive and ongoing compliance obligations on lenders, underscoring the FCCPC’s commitment to customer protection within the credit market. These obligations are to ensure that lending activities remain fair and in alignment with regulatory standards.
- Lenders are required to submit biannual reports detailing their lending operations. These reports must capture key information, including transaction values, applicable interest rates, fees charged, and the nature and volume of complaints received.[34] This mechanism enables the regulator to monitor market trends, identify potential risks, and intervene where consumer harm is evident.
- In addition, lenders must file annual returns by 31 March of each year.[35] These filings are expected to include audited financial statements and compliance summaries, providing the FCCPC with a comprehensive view of the lender’s financial health and regulatory compliance.
- The Regulations also impose strict record-keeping obligations. All lending records must be preserved for a minimum of 5 years, ensuring the availability of accurate, verifiable data for regulatory audits and dispute resolution. Moreover, lenders are obliged to produce such records within 48 hours upon request by the FCCPC, thereby reinforcing timely regulatory access to critical information.
- Lenders are mandated to report borrower data to recognized credit bureaus whenever required, further entrenching accountability and credit market transparency.
Dispute Resolution and Enforcement
- Sections 26 & 27 of the Regulations expressly provide for dispute resolution and enforcement, aimed at protecting consumers and ensuring lender accountability. Consumers are granted the right to seek redress for violations through the FCCPC-established complaint resolution mechanisms.
- To give effect to these protections, the Regulations vest the FCCPC with wide-ranging enforcement powers.[36] These include:
- Individuals found in breach may face fines of up to N50 million
- Corporate entities may be fined up to N100 million, or 1% of annual turnover, whichever is higher
- Directors and key officers may also be held personally liable, facing penalties such as fines or even disqualification from serving as company directors for up to 5 years
- The FCCPC may suspend or revoke approvals granted to lenders
- An unlawful consumer lending agreement may be terminated outright, effectively curtailing non-compliant operations.
Additional Legal Considerations: Regulatory Overlaps
FCCPC and NDPC
- The Regulations require lenders seeking approval from/registration with the FCCPC to submit data protection-related compliance documents, including evidence of a Data Compliance Audit and a Data Privacy Impact Assessment (DPIA). This creates an obvious point of contact with the Nigeria Data Protection Commission (NDPC), the statutory regulatory authority for data protection in Nigeria under the Nigeria Data Protection Act (NDPA).
- The foregoing requirement, without more, does not create a direct conflict between the FCCPC and the NDPC. The NDPA remains the primary legislation governing the processing of personal data, including the obligations of data controllers and processors, data privacy impact assessments, data security, registration requirements, complaints, investigations and enforcement. The FCCPC’s role under the Regulations should therefore be understood as requiring evidence of data protection compliance as part of its consumer lending approval process, rather than creating a separate or parallel data protection regime.
- To demonstrate compliance with the NDPA, Schedule 3 of the Regulations references the NDPC’s Audit Trustmark process, signaling that FCCPC-registered lenders may leverage existing NDPC compliance structures rather than construct parallel ones. In practice, evidence of compliance with the NDPC’s regulatory processes, such as the Audit Trustmark issued upon submission of a compliance audit, should ordinarily suffice as proof of compliance, rather than duplicating the NDPC’s role.
- On this basis, the relationship between the two frameworks is complementary. A digital lender may be required to comply with the NDPA as a data controller or processor, and to provide evidence of such compliance to the FCCPC for the purpose of obtaining or maintaining approval under the Regulations.
FCCPC and CBN
- A vital point to consider in implementing the Regulations is the potential regulatory overlap with the CBN. The Banks and Other Financial Institutions Act, 2020 (“BOFIA”) empowers the CBN to license and regulate entities carrying on business in the banking and finance sectors in Nigeria. This mandate extends to banks and other financial institutions, regardless of whether their operations are conducted virtually, digitally, or electronically.[37] Accordingly, where a bank or other CBN-licensed institution provides credit or participates in a lending arrangement, the CBN remains the primary prudential and sector regulator.
- The Regulations nevertheless appear to contemplate FCCPC oversight of certain lending arrangements involving regulated entities. In particular, the Regulations apply to persons or undertakings operating in regulated industries, while also stating that sector-regulator oversight continues without prejudice to the Regulations and that FCCPC approval does not substitute for any licence, approval or permission required from the relevant sector regulator.
- Accordingly, there is an overlap in CBN’s regulatory function with the Regulations, which also seek to govern conduct in the digital lending space. Notably, the CBN (as part of its oversight role in the financial services industry) already operates a consumer protection framework through the issuance and application of various consumer protection frameworks that are applicable to financial institutions in Nigeria (e.g., the CBN Consumer Protection Regulations 2019).
- Therefore, a bank or CBN-regulated institution may not itself be treated the same as an unregulated digital money lender, but its consumer lending partnerships with non-bank entities may still trigger FCCPC approval requirements if the arrangement falls within the Regulations. This is particularly relevant to bank-fintech partnerships, embedded lending products, white-labelled lending services, API integrations, loan origination partnerships, infrastructure collaborations and revenue-sharing models.
- Arguably, one the one hand, the FCCPC is not purporting to license banking business or replace the CBN’s supervisory authority; rather, it is asserting a consumer protection, and competition overlay over digital and non-traditional consumer lending arrangements. On another view, the requirement for prior approval of agreements involving CBN-regulated institutions may be criticised as regulatory overreach, particularly where the relevant activity is already subject to CBN licensing, conduct and consumer protection rules.
- The more balanced position is that the Regulations create a concurrent compliance regime rather than a clear hierarchy between the FCCPC and the CBN. The CBN should remain the primary regulator for banking and financial institution licensing, prudential supervision and financial sector conduct, while the FCCPC may regulate competition and consumer protection concerns arising from digital lending arrangements. However, because the Regulations may require FCCPC approval of partnership agreements involving CBN-regulated entities, there is a need for inter-agency guidance to clarify the boundaries of both regulators’ powers and to prevent duplicative approvals or inconsistent obligations.
FCCPC and NCC
- The Regulations’ broad definition of ‘consumer lending’ which extends to airtime and data advances brings the FCCPC into potential jurisdictional overlap with the NCC. The NCC is the statutory regulator for the telecommunications sector and exercises oversight over communication services, licensing, consumer protection, quality of service, tariffs, numbering, spectrum and other technical and economic aspects of telecommunications operations.
- The overlap arises because airtime and data advances are ordinarily offered within the telecommunications ecosystem, often by mobile network operators (MNOs) or their value-added service partners.[38] However, where such airtime or data is advanced to a consumer as credit, with a specific or verifiable monetary value and an expectation of repayment, the FCCPC appears to treat the transaction as a consumer lending service for the purposes of the Regulations.
- This does not necessarily mean that the FCCPC is displacing the NCC’s sectoral authority. A more balanced interpretation is that the NCC remains the primary regulator of telecommunications services and telecom-sector licensing, while the FCCPC is asserting a consumer protection and competition overlay with respect to the lending or credit element of airtime and data advances. The difficulty, however, is that the Regulations also prescribe operational requirements for airtime and data lending providers, including the requirement to engage at least two intermediaries or service providers, one of which must be Nigerian-owned.[39] This may affect commercial and technical arrangements within the telecoms value chain and therefore raises legitimate regulatory overlap concerns.
- As a result of this regulatory overlap, market operators have responded; specifically, some of the leading telecommunications companies in Nigeria have now discontinued their airtime advance service offerings, citing operational and commercial constraints arising from the Regulations.[40]
- Thus, without a doubt, the Regulations may impose severe and unintended operational constraints on the market, and formal inter-agency guidance may be required to address any overlaps and operational issues.
FCCPC and local money lending regulatory authorities e.g. Lagos
- An often overlooked dimension of the regulatory landscape for digital lending in Nigeria is the role of state-level money lending legislation. Several states, including Lagos, Ogun, and Rivers, have enacted money lending laws that impose their own licensing and conduct requirements on entities that lend money to members of the public within their territories.[41] Lagos State, for instance, operates a robust money lending regulatory framework administered by the Lagos State Ministry of Home Affairs.
- The introduction of the Regulations does not, on its face, expressly repeal, displace or replace state money lending laws. Rather, the Regulations appear to create a federal consumer protection and competition framework for digital, electronic, online and other non-traditional consumer lending. This means that digital lenders may be exposed to concurrent obligations: FCCPC approval under the Regulations and state money lender licensing where required under applicable state law.
- The interaction between both regimes is particularly important for digital lenders operating across state lines. Section 4 of the Regulations appears designed to address businesses whose operations are not territorially limited to a single state, including businesses conducted through platforms, infrastructure or technology that extend beyond one state. This gives the FCCPC a basis to assert federal oversight over cross-state or online digital lending activities. However, this does not necessarily eliminate state licensing obligations, particularly where the lender has customers, operations or enforceable lending activity within a particular state.
- This raises important questions about the interaction between the federal regulatory framework and these state regimes. The constitutional doctrine of covering the field may become relevant where there is a direct inconsistency between federal and state regulation, the safer practical position is that, until judicial clarification or formal harmonisation is issued, lenders should assume that both regimes may apply. Therefore, the main concern is that the concurrent jurisdiction creates a compliance burden, particularly for lenders operating across multiple states.
- At present, the Regulations do not expressly address or displace state money lending laws, and there has been no formal harmonisation exercise between the FCCPC and state governments. Digital lenders should therefore conduct a careful assessment of their exposure to state-level regulation alongside their FCCPC compliance obligations and engage counsel familiar with the specific requirements of each state in which they operate.
Conclusion
- The Regulations are a watershed development in Nigeria’s consumer credit ecosystem. They represent a decisive step toward protecting borrowers, sanitizing lending practices, and promoting fair competition in a sector that has, until now, operated with limited oversight.
- For digital lenders and fintech platforms, the Regulations create significant new obligations. Registration, disclosure, data protection compliance, and reporting are no longer optional. Non-compliance carries the risk of substantial fines, reputable damage and even suspension of operations.
- For customers, the Regulations promise greater transparency, fair treatment and accessible redress. They may also usher in a more competitive digital lending marketplace, where operators must compete on quality and fairness rather than exploitative practices.
- In summary, the Regulations signal a new era of accountability and consumer empowerment in Nigeria’s digital lending industry.
For further clarification or assistance regarding compliance with the Digital, Electronic, Online or Non-Traditional Consumer Lending Regulations, 2025 or any related legal matters, you can contact us via email – lawyers@credence-law.com
[1] Kunle Sanni, Premium Times, Investigation: How digital loan providers breach data privacy, violate rights of Nigerians, December 10, 2021, available at: https://www.premiumtimesng.com/news/headlines/499999-investigation-how-digital-loan-providers-breach-data-privacy-violate-rights-of-nigerians.html?tztc=1. Accessed on November 15, 2025.
[2] Section 17 of the FCCPA.
[3] Section 18 of the FCCPA.
[4] Section 163 of the FCCPA.
[5] Section 3(a) of the Regulations.
[6] Ibid.
[7] Section 3(b) of the Regulations.
[8] Ibid.
[9] Section 105 of the FCCPA describes concurrent jurisdiction and states FCCPC has precedence in competition/consumer protection matters (while also requiring coordination agreements).
[10] Section 3(c) of the Regulations.
[11] Section 4 of the Regulations.
[12] Section 4(b) of the Regulations.
[13] Section 4(c) of the Regulations.
[14] Section 4(d-e) of the Regulations.
[15] Section 5 of the Regulations.
[16] Section 6 of the Regulations.
[17] Under Section 30 of the Regulations, “Consumer Lending Services” is defined to include the lending to a consumer of cash and shall include cashback service, barter in exchange for specific or verifiable monetary value regardless of how value or interest component is calculated or derived provided that such transaction occurs by digital, electronic, online or non-traditional means.
[18] Section 8 of the Regulations.
[19] Section 9 of the Regulations.
[20] Section 8 of the Regulations.
[21] Section 10 of the Regulations.
[22] Section 11 of the Regulations.
[23] Section 30 of the Regulations defined “Consumer Lending Services Agreement” as the agreement entered between and among Lender/Service Provider and/or other intermediaries for the purpose of providing Consumer Lending Services to consumers.
[24] Section 12 of the Regulations.
[25] Section 17 of the Regulations.
[26] Section 18 of the Regulations.
[27] Section 19 of the Regulations.
[28] Ditto
[29] Section 21(a) of the Regulation.
[30] Section 22(d) of the Regulations.
[31] Section 24 (1) of the Regulations.
[32] Section 24(2) of the Regulations.
[33] Section 24(2b) of the Regulations.
[34] Section 25 of the Regulations.
[35] Ditto.
[36] Section 27(1) of the Regulations.
[37] Section 131 of the BOFIA
[38] Section 1 & Section 4(1)(b) of the Nigerian Communication Act, 2003
[39] Section 24(1) of the Regulations
[40] See https://techcabal.com/2026/04/17/why-mtn-and-airtel-temporarily-suspended-airtime-lending/ accessed on May 15, 2026.
[41] Money Lenders Law, Chapter 7, Laws of Lagos State.