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How the new FCCPC rules will reshape digital lending in Nigeria

September 15, 2025

Adedeji Olowe

In this post

On Thursday August 28, 2025, Lendsqr hosted a high-impact webinar bringing together legal, compliance and lending practitioners to unpack Nigeria’s new Federal Competition and Consumer Protection Commission (FCCPC) rules on digital lending.

More than 100 attendees from fintech, banking, legal and regulatory circles joined the one-hour discussion led by Grace Effiom (Head of Enterprise, Lendsqr) with Olagoke Kuye, Partner at Aluko & Oyebode, one of Nigeria’s leading law firms. Together, they unpacked the Federal Competition and Consumer Protection Commission’s (FCCPC) new digital-lending framework, its implications for lenders and consumers, and practical steps to achieve compliance.

Setting the stage: Lendsqr’s platform and lender commitment

Grace opened the session by introducing Lendsqr as Nigeria’s most robust SaaS platform for digital lending; powering everyone from start-ups to established brands. She highlighted key platform capabilities:

End-to-end support for loan origination, disbursement, repayment and collections
A wide range of loan products: single-tenor, multi-tenor, savings-linked loans, employee salary loans, travel loans and investment products
Advanced risk-management features: credit-bureau integration, dynamic KYC checks, device and location whitelisting/blacklisting, and liveness verification
A dedicated team offering compliance support, and partner integrations.

She stressed that Lendsqr’s mission is not only to supply technology but also to help lenders navigate regulatory change with confidence.

Why this webinar?

The FCCPC’s previous 2022 framework focused primarily on digital lenders distributing apps via Google Play or Apple Store. Since then, consumer complaints about privacy breaches and harassment have grown, prompting a new, more comprehensive set of rules. These rules now capture all forms of digital, electronic, online and “non-traditional” lending activities, regardless of how the product is delivered. Grace outlined the session’s agenda:

Overview of the new FCCPC rules
How they differ from the 2022 guidelines
Implications for lenders, vendors, and collaborators
Practical steps to achieve compliance
Live audience Q&A

Key insights from Olagoke Kuye

Here are the key takeaways from Olagoke Kuye during the webinar:

Scope and applicability

Ola Kuye explained that the new rules apply to digital and online lenders operating outside CBN’s direct licensing framework and Service providers, vendors and collaborators that “benefit” from lending transactions (for example, payment processors, data partners, field agents)

He noted that the FCCPC has not yet clearly defined “benefit,” creating uncertainty for third-party providers. Traditional money lenders not using digital or online channels are generally outside the scope but should still monitor developments. “If your business touches lending in any digital form, assume you’re covered until told otherwise” Olagoke advised.

Compliance timelines and enforcement

Olagoke Kuye focused on the timelines:

Existing lenders: 90 days to comply and obtain FCCPC approval
FCCPC’s stated approval time: 30 days, but this is discretionary and may be extended
Under the Business Facilitation Act, licences may be “deemed approved” if regulators don’t act in time, but the new FCCPC rules still prohibit operation without explicit approval, setting up a potential legal grey area

He urged participants to apply early to avoid a backlog and to document all communications with the FCCPC.

Stronger data protection requirements

The new rules mandate alignment with the Nigeria Data Protection Act (NDPA), including appointment of Data Protection Officers (DPOs) and periodic compliance reports.
Lenders must respect consumer preferences and control over unsolicited marketing messages, going beyond the previous guidelines.
Explicit consumer consent for data processing and marketing
A ban on threatening or harassing communications with borrowers

Cost of compliance vs. risk of non-compliance

Compliance will require:

Hiring or outsourcing a DPO
Upgrading app security and privacy controls
Legal and filing fees

While this may burden smaller lenders, the cost of non-compliance, fines, loss of licence, litigation, reputational damage, is far higher. Early compliance can actually improve business by boosting investor confidence, enabling better pricing, and reducing default risk.

Market impact and opportunities

The speakers predicted:

Increased collaboration or consolidation among smaller players to share compliance costs
More data-driven underwriting, leveraging credit-bureau information, which can reduce defaults and support unsecured lending growth
Opportunities for compliant lenders to differentiate themselves on trust and transparency

Licensing & renewals

Licences expire on 31 December of the third year; renewable for another three years subject to an annual levy
Minimum capital requirements vary by state (e.g. Lagos vs. Ogun); lenders should consult legal counsel or contact [email protected] for guidance

Protecting lenders while protecting consumers

Although skewed toward consumer protection, the new FCCPC framework also encourages lenders to improve credit assessments and leverage credit bureau data, ultimately helping reduce defaults. For third-party providers accessing customer financial data under open banking arrangements, the panel advised direct engagement with the FCCPC to clarify obligations.

Audience questions & clarifications

During the lively Q&A, attendees asked about:

Definition of “non-traditional lenders” (still to be clarified by FCCPC)
Exemptions for traditional money lenders
Capital and licensing fees across states
Impact on unsecured vs. secured loans

Olagoke Kuye also fielded live questions from attendees. Check here to view all questions asked and the responses.

Next steps

Digital lenders should begin compliance preparation immediately to meet the 90-day window.
Service providers and collaborators must assess whether they “benefit” from lending transactions and if they fall under the FCCPC’s scope.
Traditional lenders should confirm their exemption status.
Consumers can expect stronger data protection and more transparent practices.

As Grace Effiom concluded, “These regulations are not just about compliance, they are an opportunity for lenders to differentiate themselves through trust, transparency and stronger operations.”

Want to learn more?

If you have questions about how to comply with the new FCCPC rules or how Lendsqr can support your lending operations, reach out to the team at [email protected] or [email protected].