On July 25, 2025, the Federal Competition and Consumer Protection Commission (FCCPC) introduced the Digital, Electronic, Online, or Non-Traditional Consumer Lending Regulations, 2025. These new rules represent a major shift in Nigeria’s lending ecosystem, aiming to protect consumers from exploitative practices and to bring greater stability and accountability to the industry.

Key Highlights of the Digital Lending Regulations 2025

1. Expanded Scope of Coverage
Now applies beyond digital lenders to telcos, agritech companies, mobile money operators, BNPL providers, barter schemes, and issuers of non-cash credit.

2. Mandatory Re-Registration & Fees

• All lenders must re-register within 90 days of commencement.
• Application fee: ₦100,000.
• Approval/registration fee: ₦1,000,000 (covers two software applications).
• Additional applications: ₦500,000 each (maximum of five applications).
• Approvals expire every 3 years and must be renewed (₦500,000 annual levy).

3. Mandatory Disclosure of Loan Terms
Interest rates, repayment terms, and all charges must be clearly disclosed in plain English before transactions.

4. Interest Rate Monitoring
While the FCCPC does not fix rates, it will now monitor digital lending rates to ensure they are not “exploitative or inimical to consumer interests.”

5. Regulation of Partnerships
No partnerships with vendors or service providers without prior FCCPC approval. Unauthorized partnerships will be void.

6. Reporting Obligations

• Biannual reports on operations, transactions, and consumer complaints.
• Annual returns by 31 March.
• Records must be kept for 5 years and produced within 48 hours of request.

7. Data Protection & Consumer Rights

• Compliance with the Nigeria Data Protection Act 2023 is mandatory.
• Prohibition on accessing consumers’ contacts, photos, and call logs.
• Complaints must be resolved within 24–48 hours.

8. Sanctions for Non-Compliance

• Corporations: up to ₦100,000,000 fine or 1% of turnover (whichever is higher).
• Individuals: up to ₦50,000,000 fine.
• Directors: possible disqualification for up to 5 years.
• Sanctions may include suspension, delisting, or revocation of approvals.

What This Means for Digital Lenders

• Short compliance timeline: 90 days to re-register and align systems.
• New costs of compliance: firms must budget for approval and renewal fees.
• Partnership scrutiny: fintechs and lenders need to review existing vendor contracts.
• Higher consumer protection standards: privacy, fair disclosure, and complaint resolution processes must be strengthened.

Who is Covered?

The regulations apply broadly to entities offering consumer credit, including:

• Digital lenders and fintech startups
• Mobile money operators
• Telecoms offering airtime/data advances
• Agritech companies offering input financing
• Businesses offering “buy now, pay later” installment credit

Penalties for Non-Compliance

The FCCPC has taken a zero-tolerance approach:

• Individuals: ₦50 million fine
• Companies: ₦100 million fine or 1% of previous year turnover (whichever is higher)
• Possible suspension, delisting, or revocation of license

Why These Regulations Matter

1. Consumer Protection
   Nigerians have long complained about exploitative interest rates and harassment by lenders. The new rules directly address these issues.
2. Market Stability
   By enforcing transparency and ethical practices, the FCCPC is ensuring that digital lending becomes a credible and sustainable industry.
3. Industry Maturity
   Digital lending is no longer a “side hustle” — it’s part of the formal financial system, and the FCCPC is treating it accordingly.

Industry Concerns

Some lenders argue that the FCCPC’s monitoring of interest rates could distort the market. They note that lending rates reflect the cost of funds and risk factors, especially in Nigeria’s high-risk environment.

Nonetheless, many lenders have welcomed the ban on unethical practices, such as accessing customer contacts or harassing borrowers, as a much-needed reform.

FAQs

1. Do these regulations affect only loan apps?
No. They affect any business offering consumer credit digitally, including fintechs, telcos, and “buy now, pay later” platforms.

2. What reports must digital lenders file?

• Biannual reports on transactions and complaints.
• Annual returns by March 31 each year.

3. Can lenders still set their own interest rates?
Yes, but the FCCPC will monitor rates to ensure they are not exploitative.

4. What happens if a lender violates these rules?
They risk fines (up to ₦100m), suspension, or license revocation.

5. How should businesses prepare?
By reviewing their lending structures, contracts, software, and compliance systems to align with the FCCPC’s requirements.

How Cardinal Counsel Can Help

At Cardinal Counsel, we are at the forefront of advising fintechs, digital lenders, and consumer-facing businesses across Africa. Our expertise spans:

• Regulatory compliance and FCCPC registration
• Drafting and reviewing lending agreements
• Data protection and consumer rights compliance
• Structuring partnerships and credit arrangements
• Crisis management for non-compliance issues

If you are a digital lender, fintech startup, telco, or business offering consumer credit in Nigeria, now is the time to ensure full compliance. To discuss compliance with the FCCPC’s new Digital Lending Regulations 2025, contact us at info@cardinalcounsel.co or call +2349052628465