Digital Lending in Nigeria: A Legal Perspective

Digital lending is one of the most important developments in Nigeria's financial services landscape, offering unprecedented access to credit for millions of previously underserved Nigerians. However, for regulators, it presents urgent regulatory and consumer protection challenges. This article examines the legal framework governing digital lending in Nigeria, tracing its evolution from the general law of contract and the Money Lenders Act through the landmark intervention of the Federal Competition and Consumer Protection Commission in 2022 and the promulgation of the Digital, Electronic, Online or Non-Traditional Consumer Lending Regulations 2025. The article analyses the relationship between digital lending and data protection law under the Nigeria Data Protection Act 2023, the Cybercrimes (Prohibition, Prevention, etc.) Act 2015, and relevant constitutional provisions, paying particular attention to the predatory practices that have characterised much of the sector's growth. Drawing on recent judicial authorities, including the Supreme Court's decision in Anene v MTN (Nig.) Communications Plc [2025] 16 NWLR (Pt. 2010) 1 and the Federal High Court's affirmation of the FCCPC's regulatory mandate, the article argues that while Nigeria's regulatory architecture has matured considerably, significant gaps persist in enforcement, jurisdictional coherence, and credit infrastructure. Concrete legislative and policy recommendations are proffered to consolidate a framework that is simultaneously protective of borrowers, conducive for financial inclusion, and hospitable to responsible innovation.