Regulatory Update: 2025 Digital, Electronic, Online, Or Non-Traditional Consumer Lending Guidelines – Navigating Compliance

Introduction

In furtherance of its regulatory powers, the Federal Competition and Consumer Protection Commission (the "Commission") on November 18, 2025 issued the Digital, Electronic, Online, or Non-Traditional Consumer Lending Guidelines, 2025 (the "Guidelines"). The Guidelines aim to contextualize, clarify, and enhance the provisions outlined in the Digital, Electronic, Online, or Non-traditional Consumer Lending Regulations 2025 (the "Regulations") issued by the Commission in July 2025.

The Guidelines which became effective on November 18, 2025, introduce key provisions affecting digital lenders—such as approval of lending applications, transition for previous license holders, and pilot lending programme.

In this newsletter, we examine some of the key provisions introduced by the Guidelines, which improves on the provisions of the Regulations as discussed in our newsletter earlier written.

1. Scope of the Guidelines

The Guidelines apply to all individuals, entities, or institutions involved in providing, facilitating, or managing digital, electronic, online, or other non-traditional consumer lending services within the Federal Republic of Nigeria. This includes those operating directly or through digital platforms, agents, or other intermediaries, as well as Nigerian citizens residing both inside and outside Nigeria.

Furthermore, the Guidelines extend to cross-border digital consumer lending services offered to consumers in Nigeria, as well as corporate bodies or government agencies engaged in commercial lending or holding controlling interests in such activities.

However, the Guidelines do not apply to:

1. financial institutions duly licensed and regulated by the Central Bank of Nigeria;
2. lending arrangements between employers and employees conducted strictly under an employment relationship; and
3. cooperative societies that are duly registered, licensed, and operating in accordance with relevant laws.

2. Approval of Lending Applications

Prior to the Guidelines, the Commission was not obligated to review or approve the mobile or web applications used by lenders in delivering their lending services.

However, under the Guidelines, in addition to the registration requirement for digital lenders outlined in paragraph 15 of the Regulations, applicants are now required to submit the mobile or web application intended for lending services to the Commission for approval.

The Guidelines further require intending digital lenders to provide:

1. evidence of compliance with relevant standards for mobile applications, data messaging, information security, data quality, and secure authentication, as set by the International Organization for Standardization (ISO);
2. proof of ownership of intellectual property rights in the lending application or a valid, active license to use it;
3. confirmation that the lending application complies with the Nigeria Data Protection Act, 2023, and other applicable laws and guidelines of the Nigeria Data Protection Commission; and
4. any additional information or documentation the Commission may request.

If an applicant fails to disclose any lending application used or intended for consumer lending services, the Commission may refuse approval. If approval was already granted before this nondisclosure is discovered, the Commission may revoke approval or impose a penalty on such applicant. The Commission may also order any application marketplace or digital platform to delist such lending application for violating the Regulations or Guidelines.

The aim of this requirement is to ensure that digital lending platforms meet regulatory standards for security, intellectual property, and data protection before approval, thereby safeguarding consumer interests and maintaining compliance with relevant laws.

Furthermore, the non-refundable approval fee of One Million Naira (N1,000,000) as provided under the Regulation, shall entitle an applicant to register up to two (2) lending applications. Where an applicant seeks to register additional lending applications such that the total number exceeds two (2), the applicant shall pay an additional fee of Five Hundred Thousand Naira (N500,000) per application. In any case the maximum registrable number of applications shall not exceed five (5).

3. Transition for Previous License Holders

The Guidelines establish the requirements for transitions by digital lenders who were registered under the Digital Lending Guidelines, 2022. It provides that entities registered with the Commission under the 2022 Guidelines and before the 2025 Regulations came into effect, will be regarded as Deemed Licensees.

It is understood that such Deemed Licensees hold a deemed license to offer consumer lending services until June 30, 2026, and Deemed Licensees wishing to continue providing consumer lending services beyond this date must apply to the Commission for approval at least sixty (60) days before the expiration.

Under the Guidelines, a Deemed Licensee is not required to obtain immediate approval from the Commission to provide Consumer Lending Services pursuant to the Regulations. Nevertheless, Deemed Licensees must submit the following to the Commission:

1. a schedule of loan books and transactions;
2. the financial statements for the previous financial year;
3. details of the lending applications used by the Deemed Licensee for digital lending services;
4. evidence of compliance with annual returns filing as required by the Companies and Allied Matters Act, relevant sector-specific laws and regulations; and
5. any other information the Commission may request.

If the Commission determines that there has been a significant change since the date of registration—such as changes in the Deemed Licensee's details, ownership structure, or business nature—the Deemed Licensee will be required to formally apply for approval under the Regulations.

4. Pilot Programme

The Guidelines introduced new provisions for entities seeking to provide consumer lending services under a Pilot Programme. The Pilot Programme is meant to cater for entities who wish to test the digital lending market prior to full registration, and is a proactive step towards meeting FCCPC's comprehensive regulatory expectations.

Under the Guidelines, a Pilot Programme means a limited, trial implementation of consumer lending services for the purpose of evaluating performance, functionality, and feasibility in a controlled environment, prior to a full-scale commercial deployment or implementation.

To apply under the Pilot Programme, amongst other information requested by the Commission, an applicant is required to submit: (i) a board resolution approving application and participation; (ii) Certificate of Incorporation; (iii) company profile, organogram, and contact details; (iv) MEMART and updated Status Report; (v) CVs of directors and management staff; and (vi) AML/CTF policy.

The Commission may approve a Pilot Programme if the consumer lending exposure does not exceed One Million Naira (N1,000,000) and onboards less than one hundred (100) unique customers. Other considerations by the Commission include: the sufficiency of resources and expertise to manage risks and losses; the level of innovation and likelihood to enhance accessibility, efficiency, security, quality, or fill market gaps; and the viability of business plan for post-pilot deployment.

The Pilot Programme is valid for a period of ninety (90) days, and is renewable once for an additional period of ninety (90) days upon request. Applicants intending to obtain a full license must apply in writing at least fourteen (14) days before expiration of the Pilot Programme and the Commission may grant full license based on the entity's performance during the Pilot Programme.

Conclusion

The Guidelines represent a significant step forward by the Commission in enhancing the regulatory framework for digital lending in Nigeria. Implementation of the Guidelines would ensure operational integrity, strengthen consumer protection, foster transparency and accountability within the digital lending ecosystem, and support the sustainable growth of fintech innovations in Nigeria.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.