Introduction
A “NO REFUND” notice on a shop wall, receipt or website does not settle whether a business can lawfully refuse a refund in Nigeria. Under the Federal Competition and Consumer Protection Act 2018 (FCCPA), the answer depends on the circumstances. Consumers may have statutory remedies when goods are defective, unsuitable for a disclosed purpose or materially different from the agreed description, or when a supplier fails to perform a service to the required standard. But the law does not give every buyer an automatic right to return goods simply because they have changed their mind. Understanding this distinction helps consumers identify their rights and helps businesses develop refund policies that comply with Nigerian consumer protection law.
Key takeaways
- A blanket “No Refund” notice cannot remove the statutory remedies for defective, unsafe or misdescribed goods, or the rights that apply when a service fails.
- The FCCPA does not give a general right to return goods that match what was agreed simply because the customer has changed their mind.
- Businesses can set fair returns policies, but wording, timing and substance matter. A notice cannot make an unlawful term enforceable.
What Does the FCCPA Say About No-Refund Policies in Nigeria?
The principal law is the Federal Competition and Consumer Protection Act 2018. Although it bears the year 2018, it was published in the Federal Gazette on 1 February 2019. Part XV sets out specific consumer rights. The provisions that matter most here are sections 120, 122 and 127–129, alongside the quality and service obligations in sections 130–132.
The key distinction is between a business setting conditions for voluntary returns and a business trying to contract out of rights the law already gives its customers.
When Can You Get a Refund for Defective or Misdescribed Goods?
Under section 122 of the FCCPA, a consumer may return goods and receive a full refund in specified circumstances. These include where goods intended for a particular purpose communicated to the supplier prove unsuitable for that purpose within a reasonable time after delivery. The provision also covers goods that the consumer could not examine before delivery and rejects within a reasonable time because they do not correspond with the agreed description, sample, or type and quality reasonably contemplated by the sales agreement.
The Act separately addresses product quality. Sections 131 and 132 establish standards for goods and provide that, where goods fail to meet the applicable requirements, they may be returned within three months of delivery without penalty and at the supplier’s risk and expense. The supplier must repair or replace the failed, unsafe or defective goods, or refund the price paid.
The precise remedy depends on the applicable provision and circumstances. So a quality complaint does not automatically mean an immediate full refund
Illustrative example: A Lagos customer orders a new laptop advertised with a particular processor and storage capacity. The seller delivers a materially different specification. A notice on the receipt stating “goods sold are not returnable” does not settle the matter. The customer may have statutory grounds to reject the goods and seek the appropriate remedy.
Can a Business Refuse a Refund if You Change Your Mind?
Usually, yes. The FCCPA does not create a general cooling-off period for every purchase.
If a customer buys a dress, decides at home that they do not like the colour, and receives exactly what was advertised and agreed, the Act gives them no automatic right to a refund. A business may still offer exchanges or change-of-mind returns as a matter of customer service, and it can attach reasonable conditions to them, provided those conditions don’t undermine statutory rights.
Advance bookings are different. Section 120 gives consumers the right to cancel an advance booking, reservation or order for goods or services, subject to a reasonable cancellation charge. What counts as reasonable depends on how much notice you gave, whether the business could resell the slot, and what’s normal in that industry. No cancellation fee may be charged where the consumer cannot honour the booking because the person it was made for has died or been hospitalised.
This matters for advance orders, events and travel. Cancelling before a service is provided is a different legal situation from returning an ordinary purchase you no longer want. Sector-specific rules and the contract itself may also apply.
Can You Get a Refund for a Service That Was Not Properly Delivered?
Consumers who pay for services are protected too. Under section 130, services should be done on time, you should be told promptly about any unavoidable delay, and the work should meet the standard people are generally entitled to expect. Where a supplier falls short, section 130(2) lets the consumer require the supplier to fix the defect or refund a reasonable portion of the price, depending on how serious the failure was.
Illustrative example: A customer pays a repair business to fix a generator. The business takes the fee but doesn’t carry out the agreed repair, then points to a “No Refund” clause. That clause does not, on its own, extinguish the customer’s remedies under the Act or the contract.
Can a No-Refund Clause Override Consumer Rights Under the FCCPA?
Sections 127–129 address unfair contractual terms and prohibited conditions.
Section 127 prohibits unfair, unreasonable or unjust terms and practices, including requiring consumers to waive rights or accept liability on unfair terms.
Section 128 requires notices that purport to limit liability or impose certain risks or obligations on consumers to be conspicuous and to give consumers an adequate opportunity to receive and understand them before entering the transaction.
Section 129 goes further. It prohibits terms that purport to waive a consumer’s right to return defective goods, remove rights created by the FCCPA, avoid an undertaking’s statutory duties or override the Act. A term that contravenes section 129 is void to the extent of the contravention.
Making a prohibited term visible does not make it lawful. A customer may see a sign, tick a box or receive a receipt with a disclaimer on it. None of that gives a business permission to ignore its statutory obligations.
What Did the Court Decide About Peace Mass Transit’s No-Refund Policy?
In Chukwuma v Peace Mass Transit Ltd (Suit No E/514/2021), the High Court of Enugu State, presided over by Justice C.O. Ajah, declared the company’s “no refund after payment” policy unlawful after a passenger was denied a refund for a trip that did not go ahead as booked. The judgment, delivered in April 2022, reportedly relied on sections 120, 104 and 129(1) of the FCCPA. Section 104 is the Act’s supremacy provision. The court awarded ₦500,000 in damages. The FCCPC publicly welcomed the decision in a statement dated 27 October 2025.
The case shows the limits of a blanket no-refund policy where a supplier has not provided the service paid for. It does not establish a right to cancel every completed purchase, or to a refund whenever a customer changes their mind.
How Should a Nigerian Business Write a Lawful Returns Policy?
A blanket no-refund policy may seem to protect cash flow and discourage opportunistic returns. But it can turn a small complaint into a regulatory issue, a court claim or a public dispute.
The FCCPC reported on 27 October 2025 that it had facilitated recoveries of more than ₦10 billion for consumers across 30 sectors between March and August 2025. The figure covers all consumer complaints, not refund disputes alone, but it shows the regulator is active.
A well-drafted policy helps a business separate legitimate statutory claims from voluntary returns. It can set expectations about the product’s condition, proof of purchase, how returns work, and reasonable time limits for change-of-mind requests. It also helps staff respond consistently, rather than inventing rules at the counter.
The better approach is to make the policy clear before payment, keep transaction records, train customer-facing staff and resolve credible complaints promptly. A fair process protects the customer relationship and still lets a business guard against misuse.
Other Consumer Rights Under the FCCPA
- The displayed price is the price. Section 115 prohibits charging more than the displayed price. Where several prices are displayed at once, the customer pays the lowest.
- Youare entitled to a receipt. Under section 118, suppliers must provide a written record of each transaction unless that is impracticable. In practice, that means a proper receipt showing who sold you what, when, and for how much.
- You can reject an item before buying it. Section 121(2) lets consumers select or reject goods displayed or sold from open stock before completing the purchase.
- Second-hand goods must be labelled. Section 117 requires a conspicuous notice where goods are used, second-hand, reconditioned, rebuilt or remade.
- Advance bookings can be cancelled. Section 120 permits cancellation subject to a reasonable charge, with no fee in specified circumstances.
- Defective goods carry statutory protection. Sections 131 and 132 cover safety, quality and remedies, including return, repair, replacement or refund.
- Poor service can justify more than an apology. Section 130 provides remedies when services fall below the required standard, and section 129 stops businesses using prohibited terms to remove those rights.
How to Escalate a Refund Dispute to the FCCPC
If you are a consumer: Keep your receipt, payment confirmation, product listing, photographs, order details and messages with the supplier. Explain the problem clearly and say what remedy you want. If the supplier doesn’t resolve it, you can use the FCCPC’s complaint process. The FCCPC says complaints are free. Its guidance asks consumers to approach the supplier first and to submit supporting documents when escalating.
If you run a business: Review your receipts, website terms, invoices and in-store notices. Separate change-of-mind returns from defective goods, misdescription and service failure. State voluntary return conditions clearly before payment, avoid clauses that purport to remove statutory rights, keep proper records and give customers an accessible way to complain.
Frequently asked questions
Is a no-refund policy legal in Nigeria?
Not as a blanket rule. A no-refund policy cannot remove statutory rights under the FCCPA to return defective, unsafe or misdescribed goods, or to a remedy when a service fails. But a customer who simply changes their mind about goods that match the agreement has no general right to a refund.
Can I return goods if I simply changed my mind?
Generally, no. The FCCPA does not give a right to return goods that match what was agreed just because you no longer want them. A seller may choose to allow change-of-mind returns and set reasonable conditions. Advance bookings and orders are different, section 120 lets you cancel, subject to a reasonable charge.
How do I report a business to the FCCPC?
Contact the business first and give it a chance to resolve the problem. If it doesn’t, file a complaint through the FCCPC’s official complaint portal, with your receipt, order details, messages and a clear statement of the remedy you want. The Commission may investigate or refer the matter to a sector regulator. A complaint doesn’t guarantee a particular outcome.
What can a business lawfully put in its returns policy?
A business can set clear, fair rules for voluntary change-of-mind returns, such as a return period, proof of purchase and reasonable conditions on the product’s condition. Those rules must be communicated before payment and cannot remove statutory rights for defective goods or failed services. Sections 127–129 of the FCCPA govern unfair and prohibited terms.
What can I recover beyond a refund?
Depending on the facts, possibly compensation or restitution. Extra damages are not automatic: you must show the breach and the loss. Section 152 of the FCCPA gives a right to go to court for compensation or restitution following an FCCPC investigation, and section 136 covers liability for damage caused by defective goods.
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.
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