Nigeria Data Protection News and Advisory

Data Protection and Privacy News and Advisory

FCCPC Mandatory Registration and Oversight

FCCPC REQUREMENT FOR DIGITAL LENDERS, Audit Trust mark from the Nigerian Data Protection Commission. Compliance Audit Report and Privacy Impact Assessment Report from a duly registered Data Protection Compliance Organisation.

Major requirements

  • Company’s Privacy Policy.
  • Company’s Code of Conduct.
  • A brief description of the business and where relevant, its groups,
    subsidiaries and affiliates.

You can commence the registration process while applying
for and awaiting the Audit Trust mark from the Nigerian Data Protection
Commission and the Compliance Audit Report and Privacy Impact Assessment
Report from a duly registered Data Protection Compliance Organisation
(DPCO).

Mandatory Registration and Oversight

  • Registration: All digital lenders and service providers in the lending value chain must register with the FCCPC.
  • Approval Process: Registration requires submitting a detailed application, including a Data Protection Impact Assessment (DPIA), a compliance audit report from a LICENSED DPCO IN NIGERIA, and a list of all apps used for lending. Approvals are valid for one year initially, then renewable every 36 months.
  • Exemptions: Licensed microfinance banks are exempt from the full registration process but must obtain a formal waiver from the FCCPC.
  • Partnerships: Lenders must get prior FCCPC approval for any partnership agreements related to consumer lending.
  • Compliance Deadline: The final deadline for full compliance with the regulations is January 5, 2026.