Starting from Monday, January 5, 2026, any loan app and digital lender that has not secured full approval under the new FCCPC’s regulations would face severe sanctions. These penalties include paying up to N100,000,000 or 1% of the previous year’s turnover for companies, up to N50,000,000 for individuals, and board directors could face suspensions and disqualification for up to five years.
The Digital, Electronic, Online, and Non-Traditional Consumer Lending (DEON) regulations 2025, which came into effect on July 21, 2025, target all digital, online, or non-traditional consumer loans. This encompasses a wide range of financial services, including unsecured cash loans, airtime credit, data loans, cashback schemes, and barter schemes where a verifiable monetary value is exchanged. The regulations also extend to fintechs, mobile money operators like Airtel SmartCash, agritech platforms, and cross-state vendors, even if they hold other state or federal licenses.
According to the Federal Competition and Consumer Protection Commission (FCCPC), these new regulations require all lenders and partners to register with and secure approval from them. They are mandated to obtain FCCPC approval for all partnerships, submitting contracts that detail risks, data protection, and dispute resolution for all existing and new agreements.
While licensed Microfinance Banks (MFBs) are exempt from direct registration, they must still obtain a formal waiver from the FCCPC. The rest of the industry, including the 399 fully approved and 40 conditionally approved lenders from the interim phase, must transition to final approval before the specified deadline.
Compliance Guidelines for Digital Lenders
Digital lenders must adhere to a structured process to comply with the new regulations:
Step 1: Mandatory Registration and Documentation
- •Complete and submit the mandatory DEON Consumer Lending Form 001 and the Declaration Form 002.
- •Pay the non-refundable application fee of N100,000. An approval fee of N1,000,000 is payable upon successful approval for up to two apps.
- •Mandatorily submit all Service Level Agreements (SLAs) with any third-party service providers for the FCCPC’s express, prior review and approval. This requirement applies to both existing and new contracts.
- •Ensure that the apps to be deployed will not have access to consumer call logs, contacts, and photos/gallery.
Step 2: Operational and Ethical Overhaul
- •Obtain and submit a Compliance Audit Report and Data Protection Impact Assessment (DPIA) Report from a duly registered Data Protection Compliance Organisation (DPCO), ensuring strict adherence to the Nigeria Data Protection Act, 2023.
- •Revise all apps and marketing materials to fully disclose all fees, interest rates, and penalties in clear, simple language before a consumer commits. Hidden charges are now illegal.
- •Implement an internal credit assessment process to profile and assess the consumer’s capability to repay sustainably. Automatic or pre-authorised lending is strictly prohibited; credit must be actively opted in by the consumer.
- •Revise collection policies to adhere to ethical standards. Harassment, public shaming, or contacting third parties for debt shaming are immediate grounds for sanction.
- •Establish and document a robust, fair, and transparent feedback and complaint resolution mechanism. All consumer complaints must be addressed and resolved within 24 to 48 hours.
Step 3: Sustained Reporting and Monitoring
- •Submit reports every six months detailing consumer transactions, interest rates charged, and records of complaints and their resolution.
- •File comprehensive annual returns by March 31st of the following year, covering lending activities, consumer complaints, and audited financial statements.
- •Maintain accurate records of all transactions for a minimum of five years and be prepared to furnish them to the FCCPC within 48 hours of a request.
The initial approval is valid for one year. Subsequent renewals will be required every 36 months, subject to an annual levy.
Key Documents Required for Full FCCPC Approval
To successfully transition from the interim framework to full compliance, the application must be supported by the following documents as stipulated in the Guidelines:
- Duly filled DEON Consumer Lending Forms (Form 001 and 002).
- Certified Copy of the Certificate of Incorporation of the Applicant.
- Company’s Terms of Use, Privacy Policy, and Code of Conduct.
- Data Protection Documents: Audit Trust Mark from the Nigeria Data Protection Commission (NDPC).
- Compliance Audit Report and Privacy Impact Assessment Report (DPIA) from a registered DPCO.
- Evidence of Payment of the non-refundable Application Fee (N100,000).
- Full Details of All Operational Bank Account(s) (Bank, Account Name, and Account Number).
- Proposed Interest Rate Regime and any applicable calculation formulae.
- List of All Apps in operation or intended for operation (maximum of five apps).
- Mandatory Submission of All Service Level Agreements with all service providers with respect to operations (excluding administration).
- Evidence of a Feedback and Complaint Resolution Mechanism.
- Evidence of Tax Payments or Tax Waivers, where applicable.
