- within Consumer Protection, Finance and Banking and Real Estate and Construction topic(s)
- in Africa
Introduction
Digital lending business has grown extensively, especially with the high cost of living. Again, digital lending has simplified lending processes and procedures for small business owners, salary earners, and even first-time borrowers to access quick credit through apps and online platforms without collateral. However, this innovation came with recurring problems such as excessive interest rates, hidden fees, unethical debt recovery procedures, and privacy violations.
After constant complaints from customers and in a bid to address these concerns, the Federal Competition and Consumer Protection Commission (FCCPC) introduced the Digital, Electronic, Online or Non-Traditional Consumer Lending Regulations 2025 (the Regulation). It is assumed that this regulation has replaced the interim guidelines of 2022 to ensure consumers are treated fairly.
Which entities or activities does the Regulations Cover?
The Regulation applies to any digital, electronic, online, or non-traditional consumer lending activity in Nigeria, such as:
- Cash-based consumer loans delivered through apps or websites
- Airtime or data advances
- Cashback or barter arrangements that have a verifiable monetary value
- Partners, vendors, agents, and technology providers that share in the revenue or play an active role in loan delivery.
Please note that the Regulation exempts Banks and other financial institutions licensed under the Banks and Other Financial Institutions Act (BOFIA) from its scope. Again, businesses that are already under the exclusive supervision of another regulator, such as the Central Bank of Nigeria (CBN), may be exempt from this law, provided that the FCCPC and that regulator have an established coordination mechanism.
Can Digital Lending Businesses Operate Without FCCPC Approval?
No, the Regulation does not allow these entities to operate a digital lending business without FCCPC approval, even after obtaining other applicable licenses. Existing businesses are expected to register with FCCPC within 90 days of the commencement of the law. New applicants on the other hand, are expected to obtain approval from FCCPC before launching operations.
Requirements for Registering with FCCPC
- Certificate of incorporation, CAC Status Report, or Memorandum and Articles of Association
- Filling of the prescribed forms
- Operational license where applicable
- Detailed list and profile of members of the Board of Directors and key management personnel
- List of shareholders and beneficial owners
- Financial statements for at least the three (3) years preceding the application
- Standard terms for the provision of lending services to borrowers, or consumer lending contract
- consumer lending service agreement or other ancillary agreements
- Company’s terms of use
- Company’s privacy policy
- Company’s code of conduct.
- Audit trust mark from the Nigerian Data Protection Commission.
- Compliance audit report and privacy impact assessment report from a duly registered Data Protection Compliance Organization
- A brief description of the business, and where relevant, its groups, subsidiaries, and affiliates
- Organogram showing the role players, and the location of key role players and any operational approving authorities.
- Details of a person within the business who is authorized to accept all correspondence and service on the business’s behalf
- Evidence of membership in any trade or professional associations.
- Any or all Service Level Agreements with any service providers with respect to operations, excluding administration
- Evidence of feedback and complaint resolution mechanism
- Evidence of tax payments or tax waivers (where applicable)
- Such other documents or details as the Commission may request from time to time
- Payment of the prescribed fees
Cost of Registration
- Non-refundable application fee-₦100,000
- Approval fee-₦1,000,000
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