Introduction
In a landmark effort to sanitize Nigeria’s rapidly expanding digital lending ecosystem, the Federal Competition and Consumer Protection Commission (“FCCPC”) has, pursuant to its powers under sections 17, 18 and 163 of the Federal Competition and Consumer Protection Act 2018 (“FCCP Act”), introduced the Digital, Electronic, Online, or Non-Traditional Consumer Lending Regulations, 2025 (the “Digital Lending Regulations 2025” or “DEON Consumer Lending Regulations 2025”), which took effect on 25th July 2025 with far-reaching implications for fintech businesses in Nigeria.
These Regulations provide standards, guidelines and guidance to undertakings, their collaborators, affiliates, associates, or partners with respect to the provision of applicable consumer lending services. These comprehensive regulations are designed to safeguard consumers, foster fair competition, and enforce ethical lending practices across fintech platforms. The new Digital Lending Regulations 2025, which has been enacted pursuant to the FCCPC Act of 2018, covers a broader scope than the Limited Interim Regulatory/Registration Framework and Guidelines for Digital Lending, 2022 (the “Digital Lending Guidelines 2022”), which had previously governed digital lending activities before July 2025.
This article presents, in a question-and-answer format, the fundamental updates introduced by the Digital Lending Regulations 2025 as follows:
What Are the Key Updates Introduced by the Digital Lending Regulations 2025?
i. Expanded Scope of Coverage
Unlike the 2022 Guidelines, which was limited to digital money lending activities by money lenders, finance companies, buy-now-pay-later (“BNPL”) companies and microfinance institutions, the 2025 Regulations now apply to all applicable transactions of unsecured loans delivered via digital, electronic, online, or non-traditional channels by way of cash, airtime, data, cashback, installment payment transactions (BNPL), and barter transactions with monetary value regardless of how value or interest component is calculated or derived so long as such transactions occur by digital, electronic, online, or non-traditional means. Consequently, the regulations now extend to telecommunications companies, mobile money operators, agricultural technology platforms, real estate, issuers of non-cash credit arrangements, and barter-based lending schemes. See Regulation 3 of the Digital Lending Regulations 2025.
ii. Introduction of Re-Registration and Application and Registration Fees
Regulation 7 of the Digital Lending Regulations 2025provides for a mandatory re-registration of all existing digital lenders or other eligible service providers within ninety (90) days from the commencement of the Regulations. The Regulations provide as follows:
“Every undertaking involved in the provision of Consumer Lending Services as a Lender/Service Provider or other ancillary support prior to the commencement of these Regulations shall, where eligible, apply to, and receive the Commission’s approval to continue to offer such services or engage in the conduct that is subject of these Regulations no later than 90 (ninety) days from the commencement of these Regulations.”
What this means for existing digital lenders is that they must now renew their FCCPC approval within ninety (90) days from 24th of July 2025. The deadline for submission of application for re-registration with the FCCPC is 5th of November 2025.
Under the 2025 Regulations, FCCPC approvals now expire on 31st December of the third calendar year from the issuance date and shall be renewed no later than 31st March of the subsequent year from the third calendar year anniversary.
The application for re-registration is now at a cost. Previously, applicants were not required to pay application or registration fees to obtain FCCPC approval for digital lending operations, except when registering more than two software applications where each additional application attracted a fee of ₦500,000.
Under the new regulations, a non-refundable application fee of ₦100,000 and a registration/approval fee of ₦1,000,000 now apply, covering the registration of two software applications. An additional ₦500,000 is payable for each extra application. These fees also apply to Mobile Money Operators (MMOs) offering consumer lending through airtime and data advances. See Regulation 3 of the Digital Lending Regulations 2025.
Please note that, just as provided in the 2022 guideline, applicants are only allowed to register a maximum of five (5) software applications under the Digital Lending Regulations 2025.
The approval shall be renewed after December 31st of the third year anniversary and, thereafter, every thirty-six (36) calendar months from the date of the first renewal, subject to the payment of the prescribed annual levy in the sum of N500,000.00 (Five Hundred Thousand Naira only). This implies that applicants are now required to renew their respective FCCPC approval and registrations before expiration.
iii. Mandatory Disclosure of Interest Rates
Regulation 17 mandates that digital lenders must clearly disclose interest rates, repayment terms, and associated fees in plain English before any transaction is completed and conspicuously on the website of the digital lending companies.
Although the FCCPC does not set any rate as a mandatory interest rate for digital lenders to adopt, the Regulation 23, however, provides that the Commission shall periodically monitor interest rate for services of consumer lending, and ensure rates are not exploitative and inimical to consumer interest. Such monitoring is in compliance with the provisions of Guidelines developed pursuant to Section 163 of the FCCP Act.
iv. Exemption of Microfinance Banks
Banks and financial institutions licensed under the Banks and Other Financial Institutions Act, 2020 are exempted from the registration requirements. However, microfinance banks and finance companies licensed by the CBN must obtain a formal waiver from the FCCPC to engage in digital lending. The procedure for the waiver is essentially the same as that of actual registration of other digital lenders.
v. Regulation of Partnerships and other Third Service Providers
Digital lenders must now obtain prior FCCPC approval before entering into any partnerships related to consumer lending. All new and existing partnership agreements with vendors must be submitted for review, and any amendments are subject to FCCPC consent. Service level agreements are now explicitly prohibited unless approved by the Commission. See Regulations 7, 8, 9, 10 and 11 of the Digital Lending Regulations 2025
vi. 30-Day Approval Timeline
Regulation 14(4) stipulates a 30-day timeline for the review, assessment, and issuance of approvals following submission of complete application documents. The FCCPC may extend this timeline at its discretion.
vii. Annual and Bi-Annual Compliance Reporting
Regulation 25(1)(b) requires Undertaking and/or Lender/ Service Providers and their third-party vendors/service providers to submit annual returns and bi-annual compliance reports to the FCCPC. The returns entail accurate records of all consumer lending transactions, consumer interactions, and complaints (and resolutions to same). The biannual reports to the Commission must detail the digital lender’s operations, including the number of consumer lending transactions, total transaction value, interest and fees collected, and any consumer complaints received and their resolution. Provided that the Regulated Undertaking and/or Lender/ Service Providers shall upon request provide the Commission with the relevant documents and information.
viii. Monetary Penalties for Non-Compliance
Non-compliance of the provisions of the Regulations attracts severe penalties. Corporations may be fined up to ₦100,000,000 (One Hundred Million Naira or 1% of their turnover from the preceding financial year, whichever is higher. Individuals (such as director, manager or other employee) may face penal fines up to ₦50,000,000 (Fifty Million Naira), and company directors may be disqualified for up to five years. Additional sanctions include suspension, delisting, or revocation of approval. See Regulation 27 of the Digital Lending Regulations 2025.
What Are the Other Key Highlights of the 2025 Regulations?
a. Mandatory Registration: All digital lenders must register with the FCCPC within 90 days of the regulation’s commencement. Required documentation includes financial statements, board profiles, and data protection compliance reports.
b. Approval of Partnerships: Any collaboration between lenders and third parties (e.g., vendors, service providers) must be approved by the FCCPC. Unauthorized partnerships are strictly prohibited.
c. Complaint Handling and Redress Timelines: Regulation 26 allows consumers to report violations of the Regulations through lenderstaskforce@fecpe.gov.ng or such other complaint resolution window on the Commission’s website. A digital lender must ensure that consumer complaints are addressed and resolved within 24 (twenty-four) hours from the receipt of such complaints. Where impracticable, the Lender/Service Provider shall communicate the timeframe for the resolution of such complaint, which shall not in any case exceed 48 (forty-eight) hours from the receipt of the consumer’s complaints.
d. Service Activation Intermediaries: Regulation 24(1) mandates all Regulated Undertakings involved specifically in lending airtime and data to consumer, shall not later than 60 (sixty) days from the commencement of the Regulations, ensure that they have at least 2 (two) intermediaries and/or service providers for service activation, one of whom shall be a fully owned local service provider.
The Key Obligations of Digital Lenders to consumers under the Regulations
Digital lenders are now required to:
- Ensure Transparency: Clearly disclose interest rates, repayment terms, and fees in simple English before any transaction.
- Treat Consumers Fairly: Avoid discrimination, misleading terms, or exploitative contract clauses.
- Compliance with the Nigeria Data Protection Act, 2023, and refrain from accessing call logs, contacts, or gallery data.
- Credit must be granted only upon active consumer request. Automatic or pre-authorised lending is banned.
- Consumer complaints must be resolved within 24–48 hours, with visible channels for redress.
- Digital lenders must maintain records for five (5) years and produce them within 48 hours upon request and cooperate with credit bureaus and regulators for data sharing and transparency.
In conclusion, the introduction of the Digital Lending Regulations 2025 marks a decisive shift toward accountability and consumer-centric fintech operations. Digital lenders must now operate with heightened diligence, ethical standards, and regulatory compliance. For consumers, it’s a win, ushering in safer, fairer, and more transparent lending experiences.
