The Federal Competition and Consumer Protection Act 2018 (FCCPA) created a single regime for competition and consumer protection in Nigeria, enforced by the Federal Competition and Consumer Protection Commission (FCCPC). The same regulator reviews mergers, investigates cartels and abuse of dominance, protects consumers against unfair practices and unsafe products, and registers digital lenders. Its decisions can be appealed to the Competition and Consumer Protection Tribunal.
The FCCPC has become one of Nigeria's most active regulators. It has imposed large penalties on multinational companies, including a 220 million US dollar penalty against Meta that the Tribunal upheld in 2025, and it regularly investigates pricing, digital lending, aviation, telecoms and consumer goods. Because competition and consumer protection sit under one law and one regulator, we advise on both together, so that a deal, a product launch or a pricing decision is checked against all the rules that apply.
What we advise on
| Area | What the FCCPA covers | How we help |
|---|---|---|
| Merger control | Acquisitions of control and joint ventures above the thresholds | Notifiability assessments, filings and approvals |
| Restrictive agreements | Price-fixing, market sharing, bid-rigging and other restrictive agreements | Contract reviews and compliance advice |
| Abuse of dominance | Conduct by businesses with market power | Pricing and distribution strategy reviews |
| Consumer protection | Information, fair dealing, safe products and redress | Product, terms and customer journey reviews |
| Digital lending | Registration and conduct rules for loan apps | Registration and ongoing compliance |
| Enforcement | Investigations, inspections, penalties and appeals | Responses, defence and Tribunal appeals |
Merger control and FCCPC approvals
Transactions that amount to a merger under the FCCPA, including acquisitions of control and certain joint ventures, must be notified to the FCCPC where they meet the financial thresholds set by the Commission, which are based on turnover in Nigeria. A notifiable merger cannot be implemented until it is approved, and completing early can attract significant penalties linked to turnover. Transactions between foreign companies can also be notifiable where the target has Nigerian subsidiaries, assets or turnover.
We advise on:
- whether a transaction is notifiable, and whether a simplified procedure is available
- preparing merger notifications, supporting documents and filing fees
- engaging with the FCCPC during the review, including information requests and meetings
- remedies and conditions where the FCCPC has competition or public interest concerns
- building approval timelines into mergers and acquisitions, joint ventures and corporate due diligence
- other approvals that run alongside merger control, such as the CBN, SEC, NCC or NAICOM in regulated sectors
Restrictive agreements and abuse of dominance
The FCCPA prohibits agreements that prevent, restrict or distort competition, such as price-fixing, market sharing and bid-rigging, and the abuse of a dominant position, such as excessive pricing, refusals to supply and exclusive dealing that shuts out competitors. We help businesses review:
- distribution, supply and franchise agreements, including exclusivity, territorial restrictions and resale price provisions
- trade association activities and information exchange between competitors
- pricing, rebates and commercial practices of businesses with significant market power
- joint purchasing, joint bidding and cooperation agreements between competitors
We also act for businesses harmed by anti-competitive conduct, including complaints to the FCCPC against competitors and suppliers.
Consumer protection compliance
The FCCPA gives consumers rights to information, fair dealing, safe and good-quality products and redress, and allows the FCCPC to investigate complaints, order refunds and impose penalties. Sector regulators such as the CBN, NCC and NCAA also have consumer protection rules for the businesses they supervise. We help businesses comply in:
- terms and conditions, warranties, returns and refund policies, which cannot override statutory consumer rights
- pricing transparency, including the display of prices and charges
- product labelling, safety and recall procedures, alongside NAFDAC registration and SON certification
- complaint handling procedures and responses to consumer complaints
- advertising, which generally needs vetting by the Advertising Regulatory Council of Nigeria under the ARCON Act 2022, and promotions and competitions
Digital lending registration and compliance
Under the FCCPC's 2025 regulations on digital, electronic, online and non-traditional consumer lending, digital lenders must register with the FCCPC and comply with rules on pricing, disclosure, data use and debt recovery. Practices such as contacting a borrower's phone contacts or publishing shaming messages are prohibited. We register loan apps, prepare compliant loan terms and privacy policies, and respond to FCCPC enquiries. See our guide to the digital lending licence in Nigeria and our fintech lawyers service.
E-commerce and online platforms
Online businesses must give clear information about sellers, prices, delivery and returns, and handle personal data lawfully. We prepare website terms and privacy policies, review checkout and subscription flows, and advise on data protection compliance, which the FCCPC and the Nigeria Data Protection Commission increasingly examine together.
FCCPC investigations and enforcement
The FCCPC can request information, summon witnesses, conduct inspections and search premises, impose penalties, order refunds and other remedies, and prosecute offences. A fast and careful response makes a significant difference to the outcome. We:
- advise on rights and obligations during inspections and dawn raids
- prepare responses to information requests and summons
- negotiate settlements, undertakings and consent orders
- defend proceedings and appeal FCCPC decisions to the Competition and Consumer Protection Tribunal, and onward to the Court of Appeal
Compliance programmes and training
We prepare competition and consumer protection compliance policies, train sales, pricing and customer service teams, and carry out compliance audits, so that commercial decisions are made with the risks in mind and the business can show the FCCPC that it takes compliance seriously.
How we help
- assessing merger notifiability and securing FCCPC approvals
- reviewing contracts, pricing and distribution for competition risk
- reviewing products, terms, marketing and customer processes for consumer protection compliance
- registering digital lenders and keeping them compliant
- representing businesses in FCCPC investigations, settlements and Tribunal appeals
- compliance programmes, policies and training
Our regulatory compliance lawyers in Lagos and Abuja advise local and international businesses on competition and consumer protection law. To discuss a transaction, product or investigation, contact us.
