Getting a digital lending licence in Nigeria is a two-stage process. First, the lender needs the legal right to lend money, either through a CBN licence or a state money lending licence. Second, before it lends through an app, website, USSD or any other digital channel, it must be registered and approved by the Federal Competition and Consumer Protection Commission (FCCPC).
This guide explains both stages, the documents and fees for FCCPC registration under the Digital, Electronic, Online or Non-Traditional Consumer Lending Regulations 2025 (the DEON Regulations), the rules loan apps must follow once they are approved, and the penalties for lending without approval.
Laws that regulate digital lending in Nigeria
- The Federal Competition and Consumer Protection Act 2018 gives the FCCPC power to protect consumers, including borrowers.
- The DEON Regulations 2025 require digital consumer lenders to register with the FCCPC and set the rules on pricing, disclosure, data and debt recovery. They replaced the FCCPC's 2022 Limited Interim Regulatory/Registration Framework.
- The state moneylenders laws, such as the Moneylenders Law of Lagos State, require lenders that are not licensed by the CBN to hold a money lending licence.
- The Banks and Other Financial Institutions Act 2020 and the CBN Act govern banks, microfinance banks and finance companies, and prohibit unlicensed banking business, including taking deposits.
- The Nigeria Data Protection Act 2023 governs how lenders collect and use borrowers' personal data.
- The tax laws require lenders to register with the Nigeria Revenue Service (formerly the Federal Inland Revenue Service) and pay tax on their profits.
In July 2026, the Federal High Court upheld the DEON Regulations in a challenge brought by telecoms value-added service providers, and the FCCPC resumed full enforcement after a short suspension.
Who needs a digital lending licence in Nigeria?
The DEON Regulations apply to anyone offering unsecured consumer loans through digital, electronic, online or other non-traditional channels, whether the loan is paid in cash or in kind, such as airtime or data. This includes:
- loan apps and online lenders
- buy-now-pay-later providers
- lenders that originate loans through USSD, social media, agents or partners
- airtime and data lending services
- foreign platforms lending to consumers in Nigeria
- partners and service providers that share in the lending business
CBN-licensed institutions, such as banks and microfinance banks, must still apply to the FCCPC for approval or a formal waiver, and remain bound by its conduct rules.
Stage 1: Obtain the right to lend
FCCPC registration does not, on its own, give a business the right to lend money. The FCCPC application asks for the lender's sectoral licence, so the lender must first hold one of the following:
| Licence | Issued by | Best for |
|---|---|---|
| Money lending licence | The state Magistrate's Court and, in Lagos, the Ministry of Home Affairs | Most loan apps and small lenders, at lower cost and in weeks |
| Finance company licence | Central Bank of Nigeria | Larger lenders that want a single nationwide licence |
| Microfinance bank licence | Central Bank of Nigeria | Lenders that also want to take deposits |
Most loan apps start with a state licence in the state where they have their office. Our guide on how to get a money lending licence in Lagos and Abuja explains the documents, the Magistrate's certificate, fees and renewal. For the CBN routes, see our guides on the finance company licence and the microfinance bank licence.
Stage 2: Register the loan app with the FCCPC
Step 1: Prepare the company and compliance documents
The FCCPC application requires:
- the prescribed application forms
- the company's CAC documents and status report
- details of the directors, shareholders and beneficial owners
- the lender's money lending licence or CBN licence
- audited financial statements, where available
- the standard loan agreement, terms and conditions and a schedule of all interest, fees and charges
- the privacy policy and customer service policy
- a complaints handling procedure, with a clear escalation path
- a Data Protection Impact Assessment and compliance audit report prepared by a data protection compliance organisation licensed by the Nigeria Data Protection Commission
- details of the apps and digital channels the lender will use
- agreements with partners and service providers, including debt recovery agents
- evidence of tax compliance
Step 2: Submit the application and pay the fees
The application is submitted to the FCCPC with the non-refundable fees set by the DEON Regulations:
| Fee | Amount |
|---|---|
| Application fee | ₦100,000 |
| Approval fee, covering up to two apps | ₦1,000,000 |
| Each additional app, up to a maximum of five | ₦500,000 |
Step 3: Review by the FCCPC
The FCCPC reviews the application, the loan terms and the lender's partners, and may ask for changes or further information. Applicants should allow at least 30 days for the review, and longer where the FCCPC raises queries.
Step 4: Approval and listing
Once approved, the lender is listed on the FCCPC's register of approved digital lenders. App stores check this register, and apps that are not approved can be removed. Agreements with new partners, recovery agents and other service providers must be approved by the FCCPC before they take effect.
Rules for approved digital lenders
The DEON Regulations focus on how lenders treat borrowers. An approved lender must:
- disclose the loan terms clearly before the borrower commits, including the total cost of credit, interest, fees and penalties, and give the borrower a copy of the agreement before the money is paid out
- lend only on request, without automatic top-ups, pre-approved loans the borrower did not ask for, or loans tied to unrelated products
- advertise honestly, and give notice before changing the terms
- recover debts lawfully, without threats, harassment or shaming the borrower, and only through recovery agents approved by the FCCPC
- use personal data lawfully, in line with the Nigeria Data Protection Act 2023, and never contact people in a borrower's phone book to pressure them
- handle complaints promptly, acknowledging them within 24 hours with a date for resolution
- keep records for at least five years, and file the periodic reports and annual returns the FCCPC requires
The state money lending licence must also be renewed every year, as a lapsed licence can affect both the FCCPC approval and the lender's right to recover its loans.
Penalties for lending without FCCPC approval
The FCCPC can impose fines of up to ₦100 million or 1% of annual turnover, whichever is higher, on a company that breaks the DEON Regulations, and fines of up to ₦50 million on individual officers. It can also disqualify directors for up to five years, suspend operations, revoke approvals and direct app stores to remove the lender's apps. Separately, the Nigeria Data Protection Commission can sanction lenders for misusing personal data, and a lender without a valid money lending licence may be unable to enforce its loans.
Digital lending licence in Nigeria: a checklist
- Incorporate a company with money lending in its objects
- Obtain a state money lending licence, or a CBN finance company or microfinance bank licence
- Register for tax with the Nigeria Revenue Service and the state tax authority
- Commission a Data Protection Impact Assessment and compliance audit
- Prepare compliant loan terms, privacy and complaints policies
- Apply to the FCCPC and pay the fees
- Launch only after FCCPC approval, and renew the state licence every year
Frequently asked questions
Do loan apps need FCCPC approval in Nigeria?
Yes. A loan app must be registered and approved by the FCCPC under the DEON Regulations before it lends to consumers, in addition to holding a money lending licence or CBN licence.
Is FCCPC registration a lending licence?
No. FCCPC approval regulates how a lender deals with consumers. The right to lend comes from a state money lending licence or a CBN licence.
How much does FCCPC registration cost for a loan app?
The DEON Regulations set an application fee of ₦100,000 and an approval fee of ₦1,000,000 for up to two apps, with ₦500,000 for each additional app, up to five apps.
Can a loan app contact my phone contacts?
No. Contacting a borrower's contacts to shame or pressure them breaches the FCCPC's rules and data protection law.
Do microfinance banks need FCCPC approval for digital loans?
CBN-licensed microfinance banks that lend digitally must apply to the FCCPC for approval or a formal waiver, and must follow its conduct rules.
How our lawyers can help
Our consumer protection lawyers help lenders obtain a digital lending licence in Nigeria from start to finish: incorporating the company, obtaining the state money lending licence or CBN licence, registering the loan app with the FCCPC, preparing compliant loan terms and privacy policies, and responding to FCCPC enquiries. See also our fintech lawyers and data protection compliance services. Find out more about our banking and finance lawyers, or read more digital lending guides.
To launch your lending app, contact us.
