Bills and deadlines

Lenders must now shape up before January 6

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Hate it or love it, lenders have to shape up by January 5.

Lending is one of my favorite topics. The expensive lessons around it, and how culture impacts lending, are what fascinate me so much. If you’re Nigerian, you’re not a stranger to the million-and-one jokes about PalmPay loans and collection methods. You’ve also likely heard or experienced being contacted by a loan company to persuade/shame an acquaintance or friend into paying back their loans.

It was clear the sector needed some policies, and the Federal Competition and Consumer Protection Commission stepped in with much-needed rules.

The first attempt was the 2022 “interim framework” that forced loan apps to register or be kicked off Google Play. It was clunky, but it sent a message that you can’t just scrape people’s contacts and insult their ancestors on WhatsApp in the name of risk management.

The 2025 rules are the grown-up version of that experiment. On the positive side, they clarify things that should never have been up for debate. Lenders are now barred from harassing, defaming, or shaming borrowers; they can’t pre-authorise loans people didn’t clearly ask for; and they must put loan terms in plain language that states the interest, fees, penalties, and total cost of borrowing upfront. They’re also tethered to the Nigerian Data Protection Act.

But the same regulations also wandered into territory that drew very fair criticism: if you benefit in any way from consumer lending done through an app, USSD, website, or other “non-traditional channel,” you’re in the net. That includes telcos offering airtime and data advances, BNPL at checkout and agri platforms giving farmers inputs on credit.

Every such business now needs FCCPC approval within 90 days of the rules kicking in, and the Commission reserves at least 30 days to review your application. Corporates can be fined up to ₦10 million or 1% of prior-year turnover, while directors themselves can be banned.

It was another case of a regulator becoming licensing authority, on top of existing licences from the CBN, NCC, and the Data Protection Commission. After pushback, the Commission clarified that banks and licensed financial institutions don’t need to re-register (even though their conduct is still covered).

But the big idea remains intact: if you’re making money from consumer credit in the digital economy, FCCPC wants you on a list, under a microscope, and filing reports.

Which brings us to January 5.

The Commission has now said that by that date, every lender is expected to have registered, submitted the mountain of paperwork (including a compliance audit and data-protection impact assessment), cleaned up their contracts and marketing, and built proper complaints channels. Say byebye to the days of random loan apps popping up everywhere. Lenders (small and big) are part of the financial system with all the bureaucracy, fines, and grown-up supervision that implies.

Nigeria’s digital age

While the FCCPC is busy telling lenders to grow up, lawmakers in Abuja have been working on something more ambitious: a law that tries to drag the entire Nigerian state into the digital age. The National Digital Economy and e-Governance Bill had its public hearing last week, and the framing from the ministry was grand: “first of its kind,” “transformational,” “critical to hitting $1 trillion GDP,” all the usual hits.

Beneath the grandstanding is a genuinely important shift. The Bill basically gives full legal backing to electronic records, electronic signatures, and digital communications. It forces ministries and agencies to standardise how they collect, store, and share data. It even nudges them towards a proper national data-exchange system so that Nigerians aren’t submitting the same documents to ten different agencies.

If implemented well (and that’s always the biggest “if” in Nigeria) this could meaningfully reduce friction for almost everyone: startups dealing with KYC, companies stuck in compliance loops, and everyday people trying to register businesses.

There’s the risk that the Bill also slides into a turf war (it feels a lot like many of the bills from the last few months have this problem) where every agency wants to be the one true regulator of the digital economy. Telcos, through Association of Licensed Telecoms Operators of Nigeria, are already complaining that the Bill gives NITDA powers that sound suspiciously like NCC’s.

Still, it’s a rare moment where the Nigerian government seems to understand the scale of the digital economy—not just fintech, not just Big Tech—and is trying to build a legal operating system for it. It’s ambitious, occasionally overreaching, and very Nigerian in its tendency to create new authority rather than fix old ones. But if the Digital Economy Bill delivers even half of what it promises, it’ll bring a level of predictability and interoperability that’s useful.

The real test is the same as it’s always been: whether the systems, incentives, and human beings responsible for carrying it out can execute it masterfully.

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