On 21 July 2025, the Federal Competition and Consumer Protection Commission (“FCCPC”) issued the Digital, Electronic, Online or Non-Traditional Consumer Lending Regulations, 2025 (“DEON Regulations”) to establish a regulatory framework governing digital, electronic consumer lending services in Nigeria.
Further to this, the FCCPC issued the Digital, Electronic, Online or Non-Traditional Consumer Lending Guidelines 2025 (the “DEON Guidelines”) which became effective on 18 November 2025. The DEON Guidelines were issued pursuant to sections 17 and 163 of the Federal Competition and Consumer Protection Act 2018 (“FCCPA”) to provide practical direction for lenders and intermediaries and clarify documentation requirements in ensuring compliance with the DEON Regulations.
This article examines the DEON Guidelines and highlights the obligations for consumer lending service providers.
Scope and Applicability
The DEON Guidelines apply to all persons, entities, or institutions engaged in providing, facilitating, or administering nontraditional consumer lending services in Nigeria, whether through digital platforms, agents, or other intermediaries. It also applies to businesses and establishments under Section 2 of the FCCPA and extends to cross-border digital lending services offered to consumers in Nigeria. [1]
However, the DEON Guidelines exclude the following: (i) financial institutions licensed and regulated by the Central Bank of Nigeria (“CBN”); (ii) lending arrangements between employers and employees arising from contractual arrangements; and (iii) duly registered and licensed cooperative societies. [2]
The DEON Guidelines clarify that any other arrangements outside the scope of exemptions above shall be subject to the provisions of the DEON Regulations and the DEON Guidelines. [3]
Regulatory Oversight of Digital Lending Services
The DEON Guidelines place digital lending services under the FCCPC’s regulatory purview and provide that such services shall only be rendered to the extent permitted under the FCCPA, the DEON Regulations, and DEON Guidelines. [4] The FCCPC is also required to engage with undertakings seeking registration, as well as registered undertakings, on matters relating to its regulatory oversight of digital lending services, including requests for clarification, issues arising from the application process, and consumer complaints. [5]
Waiver for Transitions
To facilitate an effective transition, the DEON Guidelines empower the Executive Vice Chairman of the FCCPC to waive any requirement under the DEON Regulations or the DEON Guidelines. A waiver will only be granted upon request and provided it does not defeat the purpose of the FCCPA, the DEON Regulations, or the DEON Guidelines. Any such waiver will be in force for a period not exceeding three (3) months and is not subject to further extension. [6]
Repeal of the Digital Lending Guidelines 2022
The DEON Guidelines repeal the Limited Interim Regulatory/Registration Framework and Guidelines for Digital Lending 2022 (the “Digital Lending Guidelines 2022”), establishing the DEON Regulations as the new operative framework. [7] However, the repeal does not affect the previous operation of the Digital Lending Guidelines 2022 or any right, privilege, obligation, liability, penalty, or punishment accrued or incurred under them. Any investigation, legal proceeding, or remedy in respect of such matters will proceed as if the Digital Lending Guidelines 2022 had not been repealed. [8]
[1] Paragraph 2 of the DEON Guidelines
[2] Paragraph 2 of the DEON Guidelines
[3] Paragraph 3 of the DEON Guidelines
[4] Paragraph 4 of the DEON Guidelines
[5] Paragraph 5 of the DEON Guidelines
[6] Paragraph 6 of the DEON Guidelines
[7] Paragraph 7 of the DEON Guidelines
[8] Paragraph 8 of the DEON Guidelines
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