FCCPC’s CRACKDOWN ON NON-COMPLIANT DIGITAL MONEY LENDERS: WHAT YOU NEED TO KNOW.

The Federal Competition and Consumer Protection Commission (FCCPC), hereinafter referred to as “the Commission”, in line with the Digital, Electronic, Online and Non-Traditional Consumer Lending Regulations, 2025 (DEON Regulations), has taken steps to clamp down on Digital Money Lending (DML) operators who have failed to comply with the requirements of the Commission.

The DEON Regulations were issued in July 2025, and to show support, the FCCPC in November 2025 issued the Guidelines to provide implementation details. By this, a compliance deadline of January 5, 2026 was stated for operators to regularise their standing with the Commission . It is in line with this that the FCCPC via a statement released on January 21, 2026 has commenced a phased implementation of enforcement measures in respect of DML operators that did not regularise their status in accordance with the DEON Regulations.

The Executive Vice Chairman/CEO of the Commission, Tunji Bello, while speaking in a press release dated Wednesday, January 21, 2026, stated that the enforcement measures put in place are necessary to give effect to the Regulations and to maintain regulatory certainty in Nigeria’s digital lending market.

This newsletter will provide insight into the requirements that DML operators must meet, as well as the Commission’s position on the need for such compliance and its benefits to consumers.

Requirements of Digital Money Lending Operators

The Commission, as part of its mandate to, amongst other things, promote fair business practices and safeguard the interests of consumers, has laid down regulatory requirements to be met by DML operators before they can carry on business activities.

DML operators include lenders and service providers supporting the lending process, as well as digital or non-traditional platforms.

The strict adherence to these requirements is premised on the Commission’s determination to promote discipline, transparency, and consumer confidence within the digital lending space, not to disrupt legitimate business activity.

As part of its support to operators in meeting the requirements, the Commission also released an additional instrument, the Guidelines on the Digital, Electronic, Online, and Non-Traditional Consumer Lending Regulations, 2025, made under sections 17 and 163 of the Federal Competition and Consumer Protection Act. The Guidelines provide practical guidance for lenders and related service providers.

Key Compliance Requirements for Digital Money Lending Operators

1. Mandatory Registration and Approval

Existing operators were required to apply for FCCPC approval within the transitional period provided under the Regulations, with FCCPC setting January 5, 2026, as the compliance deadline.

Additionally, any business that intends to offer consumer lending services, whether through cash loans, cashback services, or barter arrangements with a clear and verifiable monetary value, must submit the required documentation to the Commission for approval, regardless of how the loan value or interest is determined.

2. Payment of Application and Approval Fees

DML operators in making applications to the Commission are to pay a nonrefundable Approval Fee of One Million Naira only (N1,000,000.00) or such other amount as the Commission shall determine from time to time by the issuance of the Guidelines. Applicants in this category shall be entitled to the initial registration of two (2) apps, and if Applicants are desirous of registering additional apps, they shall pay an additional fee of Five Hundred Thousand only (N500,000.00) for each additional app, and can register up to five apps.

3. Fair Treatment, Transparency, and Unfair Terms

DML operators are required to conduct their operations in a fair, transparent, and non-discriminatory manner. Consumers must be treated with dignity and respect at all times, and lending practices must align with principles of fairness and accountability. In particular, operators are required to:

• Treat all consumers equitably and without bias;
• Refrain from the use of unfair, oppressive, or one-sided contractual terms;
• Clearly disclose the total cost of credit, including interest, fees, and charges, prior to a consumer’s acceptance of any loan offer;
• Ensure that all communications, advertisements, and marketing materials are accurate, clear, and not misleading; and
• Implement appropriate measures for the secure handling of consumer complaints and the protection of personal and financial data.

4. Responsible Lending Standards:

The Regulations further impose responsible lending obligations on DML operators to ensure that consumer lending practices are ethical, informed, and sustainable. Lending must be consumer-initiated and based on informed consent. Accordingly, operators are expected to:

• Ensure that borrowing is voluntary and that no unsolicited, automatic, or pre-authorised lending occurs;
• Assess a consumer’s suitability for credit by reasonably evaluating their ability to repay before granting any loan;
• Communicate clearly and promptly with consumers regarding any changes to repayment timelines, terms, or conditions; and
• Maintain accessible, efficient, and user-friendly channels for customer enquiries and complaint resolution.

Regulatory Consequences of Non-Compliance

DML operators who have failed to meet the compliance window set for 5^th January 2026 to complete the required regularisation process within the transitional period have had their conditionally approved status previously granted by the Commission withdrawn. Furthermore, such operators have been removed from the Commission’s published register of approved digital lenders, pending their compliance with the applicable regulatory requirements.

The January 21, 2026 release also highlighted that those provisionally designated as eligible under transitional arrangements, have been further issued a deadline of April 2026 to regularise their registration under the DEON Regulations.

Conclusively, the Commission encourages consumers to exercise caution when dealing with digital lenders that do not appear on the Commission’s current list of approved operators, as the list serves to inform the public on operators who have met the applicable regulatory requirements. Operators are encouraged to confirm their status on the FCCPC register and commence remediation if delisted.