Federal court in Lagos has suspended the enforcement of Nigeria’s most comprehensive framework for regulating digital lending apps.
On April 15, Justice Ambrose Lewis-Allagoa of the Federal High Court in Lagos granted an interim injunction blocking the enforcement of the Digital, Electronic, Online, or Non-Traditional Consumer Lending Regulations 2025, better known as the DEON Regulations.
The order followed an urgent ex parte application filed the previous day by the Wireless Application Service Providers Association of Nigeria (WASPA Nigeria), the industry body representing wireless application service providers operating mainly within the telecoms ecosystem.
The suit targets twelve specific provisions of the text, covering licensing, sanctions, compliance obligations and data-handling rules, according to court documentation published by Lawyard.
Until the next hearing on April 27, 2026, the regulator cannot impose sanctions, enforce compliance directives, or issue new instructions to WASPA members.
The judge also barred the Federal Competition and Consumer Protection Commission (FCCPC) from interfering with the ongoing commercial operations of association members.
The case pits two actors whose respective mandates the Nigerian legal framework has never clearly separated.
On one side stands the FCCPC — the federal agency established in 2018 to enforce consumer protection and competition — which gazetted the DEON Regulations on July 21, 2025, under sections 17, 18 and 163 of its founding Act.
In a press statement dated September 3, 2025, Tunji Bello, executive vice chairman, FCCPC, justified the rules by citing “a long history of complaints” involving exploitative practices, data breaches, abusive debt recovery, and harassment.
On the other side, WASPA Nigeria contests the very legitimacy of the FCCPC’s intervention, arguing that services tied to telecoms — airtime credit, data loans, mobile-financing products — fall exclusively under the Nigerian Communications Commission (NCC), the telecoms regulator created by the Nigerian Communications Act of 2003.
In the affidavit deposed by Ayo Stuffman, the association contends that the FCCPC is acting ultra vires and creating a regulatory regime parallel to the NCC’s.
A jurisdictional war that stretches far beyond a procedural dispute
The conflict is not limited to a question of legal boundaries. It strikes at the commercial core of the market: who collects the licensing fees, who sets the operational conditions, who governs the financial products embedded in telecom networks.
Nigeria’s consumer credit stock reached 3.82 trillion naira at the end of December 2024, up 21.27% on September, according to Central Bank of Nigeria (CBN) data relayed by The Cable and AFP.
In the fourth quarter of 2024 alone, personal loans disbursed amounted to approximately 470 billion naira.
A growing share flows through mobile applications and telecom-embedded lending products — including MTN’s MoMo Airtime Lending, operated by the country’s largest telecom operator.
If the court validates WASPA’s position, these products fall outside the FCCPC’s scope and come under the sole authority of the NCC, a regulator historically less active on consumer protection issues.
Available data on demand illustrate the social stakes. Between 2021 and 2023, the FCCPC recorded more than 11,000 consumer complaints for harassment, data abuse and unethical debt recovery practices, according to the agency.
The number of lending applications approved by the FCCPC rose from 269 in September 2024 to 408 in March 2025, while 47 apps were delisted and 88 were placed on the watchlist, according to data compiled by AFP and OneSafe.
The DEON Regulations were meant to introduce interest-rate caps, precontractual disclosure obligations, continuous supervision of recovery practices and fines of up to 100 million naira per violation, according to Legit.ng. The compliance deadline was set for January 5, 2026, and the FCCPC had issued written compliance notices to operators with an April 16 deadline, according to WASPA’s affidavit.
It is precisely this enforcement pressure that triggered the legal challenge.
