PROTECTING THE DIGITAL BORROWER: A CRITICAL APPRAISAL OF THE FCCPC’S 2025 DEON CONSUMER LENDING REGULATIONS

Abstract

The past decade witnessed a rise in digital lending in Nigeria. With a population vastly underserved in financial services, digital lending represents financial inclusion while simultaneously exposing consumers to privacy breaches, predatory lending practices, and invasive debt recovery tactics. On 21 July 2025, the Federal Competition and Consumer Protection Commission

(FCCPC) issued the Digital, Electronic, Online or NonTraditional (DEON) Consumer Lending Regulations 2025, in exercise of its powers under Section 163 of the Federal Competition and Consumer Protection Act 2018. Under the lenses of the doctrinal model, this article considered relevant statues and the Regulations itself, including a voyage into Kenya, India, the UK, South Africa and the US for comparative analysis. In doing so, the article critically examined the efficacy of the Regulations and accessed the implications for consumer and lender rights and juxtaposed same with financial innovation needs of the Nigerian economy. Part of its attraction is the requirement for full disclosure of digital loan terms, mandatory registration of digital lenders, prohibition of pre-authorised lending, strict debt collection terms, and sanctions for non-compliance. Also, data protection obligations stand tall as a key component of the framework. However, the Regulations failed to provide clear interest rate caps; limited enforcement capacity, and potential overlap with existing moneylending regimes. Moreover, the costs of compliance could prove a burden for smaller lenders and undermine credit access for low-income consumers. The article argued that the success of the DEON Regulations rests on practical enforcement, and recommended that public awareness, harmonization across regulatory regimes and periodic review of the regulations are key to its sustained success. Effectively implemented, the Regulations could place Nigeria as a global leader in digital consumer rights protection.