November 26, 2025
The Federal Competition and Consumer Protection Commission, FCCPC, moves to restrict operators to a maximum of five lending applications is set to generate a structural shake-up on the nation’s digital lending sector.
Setting the stage for significant consolidation among lenders that currently operate far beyond the new cap, the new guidelines, form part of the Commission’s broader effort to sanitise the digital credit space, with a firm compliance deadline of January 5, 2026.
Currently, some of the approved digital lenders operate six to eight apps, often using multiple brand identities to widen market reach or evade regulatory scrutiny.
This has complicated oversight, especially in cases involving consumer data misuse, harassment in loan recovery, and opaque pricing.
The Commission, in the guidelines just released as a follow up to its Digital, Electronic, Online, or Non-traditional Consumer Lending Regulations 2025 released in July, said, “For the avoidance of doubt, where the applicants are in a joint venture for the provision of Consumer Lending Services, the aggregate number of Lending Applications to be used or controlled by the joint venture shall not exceed five (5), and in any case, each member of the joint venture shall not, nor shall it be permitted, to independently register, use, operate or control consumer lending apps or software for the provision of Consumer Lending Services unless and until the termination of the joint venture.”
By setting this threshold, the FCCPC, aims to reduce fragmentation in the market, ensure clearer accountability, and stop lenders from spreading their operations across numerous small platforms that are difficult to track.
READ MORE; New Digital Lending Regulations: FCCPC Sets January 5, 2026 As Compliance Deadline
Considering the Financial implications of app registration, the new guideline also redefines how lenders pay for app approvals.
The standard approval fee under Regulation 15(2)(a) and (b) covers registration of up to two lending applications.
For lenders seeking to register more than two apps, up to the limit of five, there is an additional fee of N500,000 per extra application.
This structure creates a financial disincentive for operators that historically relied on volume, encouraging them instead to streamline operations and invest in compliance, customer support, and responsible lending systems.
As part of licence renewal, digital lenders must now provide full disclosure of every app used in delivering consumer lending services.
The commission said failure to declare any active or intended lending application can result in denial of approval.
Where an approval has already been granted, undisclosed apps may lead to licence revocation or additional administrative penalties.
Beyond this, the Commission said it may direct app distribution platforms to immediately delist non-compliant lending apps, a tool it has used in previous enforcement waves in collaboration with Google and Apple.
Speaking on why lenders deploy multiple apps, the President of the Money Lenders Association (MLA), Gbemi Adelekan, digital lenders deploy them for different purposes.
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“The multiple apps are deployed based on target markets and businesses. A company can have an app for nano loan, business loan, insurance, savings, and all of that. But also understand that this makes it cumbersome for the FCCPC to monitor all of the apps, which is why they are coming up with a cap,” he said.
Adelekan said all the lenders with more than five apps will now have to consolidate them and move their customers to the ones they are permitted to use.
As for consumers who rely on digital credit, the new cap carries implications for quick, short-term credit, especially those underserved by traditional banking.
As lenders consolidate their app portfolios, consumers may notice:
Fewer app choices, especially among lenders that previously operated up to eight platforms.
Temporary service disruptions as operators merge apps, migrate users, or retire non-compliant platforms before the January 5 deadline.
Stronger data protection, with the FCCPC better positioned to track app ownership and enforce penalties for data misuse or harassment.
However, consumers may also face short-term access constraints if certain popular apps are delisted or discontinued during the compliance process.
The FCCPC had earlier fixed October 31, 2025, as the deadline for all digital lenders in the country to get registered or face a fine of N100 million.
The race to beat the deadline had led to a surge in the number of registered digital lenders in the country, with the number jumping to 492 in October.
Inorder to allow full compliance the Commission last week announced the extension of the deadline to January 5, 2026.
To that effect, the Commission released the Guidelines on the Digital, Electronic, Online and Non-Traditional Consumer Lending Regulations, 2025, as an additional instrument to guide compliance.
The guidelines, was made under Sections 17 and 163 of the FCCPA, providing detailed directions for digital lenders, including requirements for documentation.
