In the last few years, the Nigerian fintech ecosystem and the digital lending space have witnessed significant growth and innovation in terms of players and product offerings. From instant/payday loans to other forms of bespoke lending products, for better or worse, digital lending has fast become one of the most active sub-sectors of the Nigerian financial services industry.

However, recently, their operations have come under greater regulatory scrutiny due to perceived predatory lending practices such as risk-based pricing, inflated fees and charges and unethical debt recovery tactics.

It is against this backdrop that the Federal Competition and Consumer Protection Commission (the “FCCPC”) in August 2022 issued interim guidelines for the registration of digital lending platforms in Nigeria (the “DL Guidelines”).

In this publication, we look at some of the critical registration requirements, the practical implications for digital lending platforms, and the roles of the FCCPC and the CBN in regulating this sector.