In July 2026, the Wireless Application Service Providers Association of Nigeria (WASPAN) lodged an appeal with the Federal Court of Appeal to challenge the Federal Competition and Consumer Protection Commission (FCCPC)’s Digital, Electronic, Online or Non‑Traditional Consumer Lending Regulations 2025 (referred to as DEON).
The case stems from a judgment delivered on 20 July 2026 by Justice Ambrose Lewis‑Allagoa of the Federal High Court of Lagos, which dismissed WASPAN’s original suit and upheld the validity of FCCPC’s DEON rules. Following the judgment, FCCPC immediately announced the resumption of enforcement. WASPAN filed its notice of appeal on 21 July and applied for an injunction to suspend enforcement of the DEON regulations pending the appeal hearing.
The DEON regulations impose substantial additional obligations on digital‑lending service providers. All entities offering digital consumer‑lending services must complete registration with FCCPC within 90 days of the rules’ entry‑into‑force. Registration requires a non‑refundable application fee of NGN 100 000 plus a non‑refundable processing fee of NGN 1 000 000. Registration remains valid for 36 months and requires renewal upon expiry. Providers must retain records of all consumer‑loan transactions and complaint handling for a minimum of five years, submit annual reports to FCCPC by 31 March each year, obtain prior FCCPC approval before launching any lending service, and furnish compliance‑audit reports alongside data‑protection‑impact‑assessment reports. Breaching entities may incur penalties up to NGN 100 million or 1 % of annual turnover; company directors may also face regulatory sanctions.
WASPAN submits that its members are already licensed and regulated by the Nigerian Communications Commission (NCC) under the Nigerian Communications Act 2003. According to WASPAN, DEON’s requirement for additional FCCPC approval, registration and oversight alongside existing NCC licences creates regulatory overlap and conflict with telecom‑sector authorities. WASPAN specifically challenges Clause 7 of DEON, which mandates FCCPC approval before members offer consumer‑lending services. WASPAN contends this provision in effect confers telecom‑licensing authority upon FCCPC. WASPAN warns that strict enforcement of DEON will expose operators to severe sanctions and disrupt lawful commercial activities.
