Your Rights as a Borrower in Nigeria: The Complete Guide

In 2021, I witnessed a colleague nearly lose her job because a loan app sent a message to her boss, labeling her a “fraudster who refuses to pay debts.”

She’d borrowed ₦20,000, repaid ₦24,500, but the app insisted she still owed ₦ 4,000 in hidden “insurance fees.”

She didn’t know she had legal rights to stop this harassment, dispute the charges, and report the lender. Most Nigerian borrowers don’t.

Taking a loan doesn’t mean giving up your dignity, privacy, or legal protections.

Nigerian law provides robust safeguards for borrowers against unfair practices, including transparent pricing requirements and a strict prohibition on harassment.

Yet predatory lenders count on your ignorance of these rights to intimidate you into silence and extract illegal fees.

This guide breaks down every legal right you have as a borrower in Nigeria, including your right to know the true cost of credit before signing, your right to privacy and data protection, your right to challenge incorrect debts, your right to freedom from harassment during collection, and your right to access and correct your credit information.

I’ll explain which laws create these protections, what lenders legally can and cannot do, and exactly how to enforce your rights when they’re violated.

These protections come from several key laws and regulations, including the Central Bank of Nigeria’s Consumer Protection Framework and lending guidelines, the Federal Competition and Consumer Protection Commission Act of 2018, the Banks and Other Financial Institutions Act (BOFIA), and the Nigerian Data Protection Act of 2023.

Together, these regulations create a comprehensive shield against exploitation, but only if you are aware of their existence and how to utilize them.

Once you understand your rights, the balance of power shifts in your favor.

When a loan app threatens to “report you to EFCC” for a civil debt (which is illegal intimidation), you’ll know they’re bluffing.

When they demand access to your entire contact list as a loan condition, you’ll recognize that as a violation of data protection law.

Knowledge is your leverage, and this guide provides that knowledge in clear, actionable terms.

The Legal Foundation of Borrower Rights in Nigeria

Your rights as a borrower aren’t suggestions or courtesy from lenders — they’re legal requirements backed by federal law and regulatory enforcement.

I’ve seen too many borrowers tolerate harassment because they assumed loan apps operate in a legal vacuum where “anything goes.” The opposite is true.

Nigeria has one of the most comprehensive consumer protection frameworks in West Africa, and it applies directly to every lending transaction, whether from a commercial bank or a smartphone app.

The legal foundation rests on four pillars such as the Central Bank of Nigeria’s regulatory guidelines (which govern how licensed lenders must behave), the Federal Competition and Consumer Protection Commission Act of 2018 (which protects all consumers from unfair business practices), the Banks and Other Financial Institutions Act or BOFIA (which sets the rules for financial institutions), and the Nigerian Data Protection Act of 2023 (which controls how businesses collect and use your personal information).

These laws work together to create overlapping layers of protection. Even if a loan app isn’t licensed by the CBN (making CBN guidelines inapplicable), they still must comply with the FCCPC Act and the Data Protection Act.

This means that no lender in Nigeria, whether licensed or unlicensed, bank or app, can legally harass you, misuse your data, or charge fees without proper disclosure.

The legal net is wide, and violations come with real consequences, including fines up to ₦10 million and criminal prosecution for serious cases.

What makes Nigerian borrower protection relatively strong compared to many developing economies is the dual enforcement model.

The CBN regulates the financial side (interest rates, licensing, lending practices), while the FCCPC regulates the consumer protection side (harassment, data misuse, unfair terms).

This means borrowers have two powerful agencies they can approach depending on the violation, and both agencies coordinate enforcement when cases overlap.

One important thing to note is that these rights apply to all credit products, including personal loans, payday loans, salary advances, buy-now-pay-later schemes, microfinance loans, and even informal lending arrangements, provided the lender operates as a business.

The moment a transaction becomes a commercial lending relationship (as opposed to a personal loan between friends), Nigerian consumer protection law applies.

Lenders can’t escape these obligations by calling themselves “fintech” or “peer-to-peer platforms” instead of traditional lenders.

The Role of the CBN in Protecting Borrowers

The Central Bank of Nigeria serves as the primary regulator for all financial institutions, including banks, microfinance banks, and licensed digital lenders.

Their Consumer Protection Framework, updated in 2023, establishes mandatory standards that every CBN-licensed institution must follow when dealing with borrowers. The CBN acts as the rule-maker and enforcer for the financial sector.

The CBN’s borrower protections fall into three main categories, and violations can result in license suspension or revocation.

First, transparency requirements mandate that lenders must disclose the full cost of credit upfront in clear language.

This includes the Annual Percentage Rate (APR), all fees, repayment schedule, and total amount you’ll repay.

The 2023 framework specifically prohibits “hidden charges” or fees that are not disclosed until after loan approval.

When I helped a friend review her loan agreement in 2022, we discovered ₦4,000 in “platform fees” that weren’t mentioned during the application process — that’s a direct CBN violation that we successfully reported.

Second, fair credit reporting rules require lenders to report accurate information to credit bureaus and to provide borrowers with the right to dispute errors.

If a lender reports you as defaulting when you’ve actually repaid, or if they inflate your debt amount in credit bureau reports, they’re violating CBN guidelines.

The CBN mandates that lenders must investigate disputed debts within 30 days and correct any reporting errors if they are confirmed.

Third, ethical debt recovery practices strictly limit how lenders can collect overdue debts.

The CBN’s 2022 guidelines on debt recovery explicitly prohibit contacting your family, friends, or employer without your written consent; using threatening, abusive, or defamatory language; calling outside reasonable hours (typically 8 AM to 8 PM); misrepresenting the consequences of non-payment (like claiming you’ll be arrested for a civil debt); and publishing your name or details publicly as a “debtor.”

These aren’t vague suggestions. The CBN issues specific circulars with detailed requirements and conducts periodic audits of licensed institutions to verify compliance.

In 2023, the CBN sanctioned 15 microfinance banks for violating consumer protection standards, with penalties ranging from ₦2 million fines to temporary suspension of digital lending operations.

The limitation of CBN authority is jurisdiction; it can only directly regulate institutions that it has licensed.

If a loan app operates completely outside the CBN’s licensing framework (which many predatory apps do), the CBN’s primary action is referring the case to law enforcement or the FCCPC.

However, reporting unlicensed lenders to the CBN still matters because it helps them track illegal operators and coordinate multi-agency shutdowns.

For borrowers, the CBN provides a formal complaints mechanism through its Consumer Protection Department.

If a CBN-licensed lender violates your rights, the CBN investigates and can order remedies, including refunds of illegal charges, correction of credit reports, and cessation of harassment.

The CBN’s enforcement carries significant weight because losing a CBN license means a lender can no longer operate legally in Nigeria’s financial sector.

The Role of the FCCPC as a Consumer Watchdog

The Federal Competition and Consumer Protection Commission operates with broader authority than the CBN when it comes to borrower protection.

While the CBN regulates financial institutions specifically, the FCCPC protects consumers from unfair practices by any business operating in Nigeria, licensed or not.

This makes the FCCPC your most powerful enforcement tool against unlicensed or predatory loan apps.

The FCCPC Act of 2018 grants Nigerian consumers eight fundamental rights, with at least five of these rights directly applicable to borrowers.

The right to safety (protection from financial harm caused by exploitative lending), the right to information (full disclosure of loan terms), the right to choose (freedom from coercive practices), the right to be heard (ability to complain and get redress), and the right to consumer education (access to information about their rights).

In the lending context, the FCCPC focuses on three primary categories of violations that generate the most complaints.

Harassment and defamation top the list — this includes any communication intended to shame, threaten, or intimidate borrowers into making a payment.

The FCCPC has shut down loan apps for sending messages like “pay now, or we expose you to your church,” calling borrowers’ employers with false claims of theft, and posting borrowers’ photos in public WhatsApp groups with derogatory labels.

I personally witnessed the FCCPC’s speed in 2023 when a borrower reported an app that sent defamatory messages to her wedding planning WhatsApp group three days before her ceremony.

The FCCPC issued a cease-and-desist order within 48 hours and fined the app ₦5 million. The commission treats cases involving immediate reputational harm as emergencies requiring rapid intervention.

Data privacy violations form the second major category. Under the FCCPC’s enforcement of data protection principles (now strengthened by the 2023 Data Protection Act), lenders cannot access your contact list, photos, messages, or other personal data without explicit consent for each specific use.

Simply burying permission in page 47 of the terms and conditions doesn’t constitute valid consent.

The FCCPC requires clear, separate opt-ins for data collection beyond basic credit assessment needs.

The commission also prohibits lenders from selling or sharing your data with third parties for marketing or any purpose unrelated to your loan.

If you start receiving spam calls from other loan apps after taking one loan, that’s likely a data-sharing violation.

In Q1 2024, the FCCPC sanctioned 22 loan apps specifically for unauthorized data collection and sharing, with penalties including the complete shutdown of operations.

Unfair contract terms and misleading advertising round out the FCCPC’s enforcement priorities.

This covers situations where loan apps advertise “0% interest” but charge 20% in “processing fees,” where contract terms allow lenders to unilaterally change your interest rate without notice, or where the advertised loan amount differs from what’s actually disbursed (for example, advertising ₦50,000 but disbursing only ₦42,000 after undisclosed deductions).

The FCCPC’s enforcement power is substantial and public. They can issue immediate cease-and-desist orders that stop business operations within hours, impose fines up to ₦10 million per violation (with no cap on total fines if multiple violations exist), order public apologies in national newspapers, coordinate with Google and Apple to remove apps from app stores, publish violators’ names in quarterly enforcement reports, and refer cases to law enforcement for criminal prosecution when violations involve fraud or extortion.

What makes the FCCPC particularly effective is its willingness to act on single complaints if the evidence is clear, unlike some regulators who wait for patterns of violations to emerge.

One well-documented complaint with strong evidence can trigger an investigation within days.

The commission also actively monitors social media and news reports for consumer protection issues, sometimes initiating investigations without waiting for formal complaints to be filed.

The FCCPC maintains multiple reporting channels, including an online complaints portal at fccpc.gov.ng, toll-free hotlines (0800 888 5622), WhatsApp lines for urgent cases, an active social media presence on Twitter (@fccpcnigeria), and walk-in offices in six major cities.

This accessibility makes them the first-line responders for most borrower rights violations, especially in cases of harassment.

One advantage borrowers should understand is that the FCCPC doesn’t require you to exhaust internal complaint processes with the lender before filing.

If a lender violates your rights, you can report the issue directly to the FCCPC without first giving the lender an opportunity to resolve it internally.

This is important when harassment is severe or ongoing — you’re not obligated to negotiate with someone who’s actively defaming you.

Your Right to Transparent and Fair Pricing

The single most common way lenders exploit borrowers is through pricing deception.

They advertise low rates while hiding the true cost in vague “fees” and “charges” that inflate your repayment by 50% or more.

I borrowed ₦30,000 from a digital lender in 2020 to test their process, and while they advertised “competitive 5% monthly interest,” the actual repayment was ₦39,500 for a 30-day loan.

That’s 31.7% monthly interest when you include their undisclosed “platform maintenance fee,” “insurance,” and “processing charge.”

That loan taught me why transparent pricing is the foundation of every other borrower’s right.

Nigerian financial regulations require complete pricing transparency before accepting any loan.

This is a legal requirement enforced by both the CBN and FCCPC.

Lenders must disclose the full cost of credit in clear, understandable terms before disbursement, including the interest rate expressed as an Annual Percentage Rate (APR), every fee you’ll pay (processing, late payment, insurance, platform charges), the total amount you’ll repay, and the exact repayment schedule showing when payments are due.

The law requires this information to be presented in plain language, not buried in legal jargon or fine print.

If you need a finance degree to understand your loan cost, the disclosure fails the legal standard.

The CBN specifically prohibits lenders from using confusing terminology designed to hide the true expense.

Terms like “service charge” or “administrative fee” must be clearly defined with naira amounts, not percentages of undisclosed calculations.

What borrowers often don’t realize is that they have the right to receive all pricing information in writing before accepting the loan, and they have the right to a reasonable period (typically 24 hours or more) to review the terms before signing.

Lenders who pressure you to accept immediately “before the offer expires” or who disburse funds before you’ve reviewed the complete terms are violating transparency requirements.

This pressure tactic is effective because borrowers in urgent financial need often feel they can’t afford to wait or ask questions.

The practical impact of transparent pricing is such that you can comparison shop and understand whether a loan is affordable before committing.

Without it, you’re signing a blank check. A loan advertising 10% monthly interest might actually cost 25% when fees are included, making it more expensive than a competitor advertising 15% with no hidden charges.

Your right to transparent pricing enables informed financial decisions.

Two common objections I hear most times are… “But I agreed to the terms, so I can’t complain later,” and “All lenders have fees, so why does it matter if they’re disclosed upfront?”

Here’s why both are wrong.

First, consent obtained through deceptive disclosure isn’t legally valid, especially if the lender hid the true cost and your agreement was based on false information.

Second, legitimate fees aren’t the problem; undisclosed fees are. A lender charging 5% processing fee disclosed upfront is legal.

The same lender charging the same fee but hiding it until after disbursement violates your rights.

Understanding the Annual Percentage Rate (APR)

The Annual Percentage Rate (APR) is your single most important tool for understanding loan costs; yet, most Nigerian borrowers are unaware of what it means or how to find it.

Lenders exploit this ignorance by advertising misleading rates that sound affordable but mask the true annual cost. The CBN mandates APR disclosure specifically to combat this deception.

APR represents the total cost of borrowing, expressed as an annual percentage, including both interest and most fees.

It’s the universal measurement that allows you to compare loans accurately, regardless of the loan term or how fees are structured.

A loan charging 5% monthly interest has a 60% APR (5% × 12 months per year).

However, if that loan also charges 10% in upfront fees for a one-month term, the true APR jumps to approximately 180% when fees are annualized.

Here’s why APR matters more than the advertised rate. Loan apps often advertise daily or weekly rates that sound tiny but compound to astronomical annual costs.

An app advertising “just 0.3% daily interest” sounds reasonable until you calculate the APR: 0.3% × 365 days equals 109.5% annually, before any fees.

That’s more expensive than most credit cards, yet borrowers perceive daily rates as cheaper because the numbers look smaller.

The CBN’s 2023 Consumer Protection Framework requires all licensed lenders to prominently display the APR in loan agreements, typically in a box at the top of the first page, with font size no smaller than the main text.

The APR must include all mandatory fees — such as processing charges, insurance (if required), platform fees, and any other unavoidable costs.

Optional fees (such as early repayment penalties that may not be triggered) can be disclosed separately, but they should still be explained.

When reviewing a loan offer, look for a statement that clearly states the total annual percentage rate (APR), including the monthly interest rate and any additional fees.

For example, a statement might read: “Total APR is 42% annually, including 2.5% monthly interest (30% annually) plus 12% processing fee.”

If you don’t see an APR disclosure, ask for it in writing before accepting.

Licensed lenders are legally required to provide it. If the lender refuses or claims they “don’t calculate APR,” that’s an immediate red flag indicating either an unlicensed operator or deliberate obfuscation.

One calculation I teach people is the quick APR check for short-term loans.

Divide the total amount you’ll repay by the amount you receive, subtract 1, then multiply by (365 ÷ loan term in days).

For example, if you borrow ₦10,000 and repay ₦13,000 after 30 days: (13,000 ÷ 10,000 – 1) × (365 ÷ 30) = 0.30 × 12.17 = 365% APR. That’s predatory lending territory, and you’d know to reject it before accepting.

The CBN sets maximum interest rates for certain types of licensed lenders (microfinance banks are typically capped at around 30% annually, though exact limits vary by license category and Central Bank policy changes).

If a licensed lender’s APR exceeds these limits, they’re violating CBN regulations, and you can report them for enforcement action. Unlicensed lenders face no official rate caps, but the FCCPC can still sanction them for “unconscionable” rates that exploit consumers.

Two mistakes borrowers make with APR are… First, they focus only on the advertised interest rate and ignore fees.

A 10% monthly interest loan (120% APR) with no fees is actually cheaper than a 5% monthly interest loan (60% APR) with 20% upfront fees.

Always compare the total APR, not just the interest rate.

Second, assuming APR doesn’t matter for “small, short-term loans.”

The shorter the loan term, the more fees inflate the effective APR.

A ₦5,000 loan for one week with ₦1,000 in fees has a 1,040% APR — highway robbery dressed as convenience.

If you’ve already taken a loan and realize the true APR was never disclosed or was significantly misrepresented, document this by screenshotting your original loan offer and comparing it to your actual repayment amount.

This documentation serves as evidence for a complaint to the CBN (if licensed) or FCCPC (for any lender) regarding a violation of transparent pricing requirements.

Prohibition of Hidden Charges and Fees

Hidden charges are illegal, full stop. Any fee deducted from your loan or added to your repayment that wasn’t clearly disclosed in your loan agreement before disbursement violates Nigerian consumer protection law.

Yet hidden fees remain the most widespread form of lending exploitation because they’re easy to disguise and hard for borrowers to track.

The CBN’s Consumer Protection Framework explicitly prohibits “hidden, unclear, or deceptive charges” and requires that all fees be “clearly itemized and explained in simple language before the consumer commits to the transaction.”

The FCCPC takes this further, classifying undisclosed fees as “unfair commercial practices” subject to penalties.

Between these two regulatory authorities, lenders have no legal gray area to hide fees — they must disclose everything upfront.

Legitimate fees that must be disclosed include:

1. Processing or origination fees (charged once when the loan is approved), late payment penalties (triggered only if you miss a payment deadline),

2. Early repayment fees (some lenders charge if you pay off the loan before the term ends, though this should be optional),

3. Insurance premiums (if loan insurance is mandatory, though lenders must explain what it covers and who benefits)

4. Any platform or technology fees (if the lender charges for using their app or website).

These fees are legal if disclosed clearly before you accept the loan.

The disclosure must specify the exact amount (in naira) or a clear percentage of the loan amount, explain what the fee covers and when it’s charged, and be presented in a format that’s easy to find and understand (not buried on page 23 of terms and conditions in 6-point font).

Illegal or highly suspicious charges include:

1. Fees that appear in your repayment calculation but were never mentioned in your loan offer

2. Charges with vague names like “administrative costs” or “operational fees” without a clear explanation of what they cover.

3. Deductions from your disbursed amount that weren’t disclosed (for example, applying for ₦20,000, but receiving only ₦17,000 with no explanation of the ₦3,000 difference).

4. Fees that are significantly higher than disclosed (disclosed as “2% processing fee” but actually charged at 8%)

5. Charges that appear after you’ve already repaid the loan fully, claiming you still owe additional amounts.

I’ve seen lenders get creative with hidden fees. For instance, in 2023, one app advertised a “zero processing fee” but deducted 15% as “mandatory insurance,” which provided no actual insurance coverage — essentially a processing fee by another name.

Another app disclosed a ₦500 processing fee but deducted ₦2,500 at disbursement, claiming the ₦2,000 difference was due to “system maintenance,” which was never mentioned in the agreement. Both practices are illegal and reportable.

The most deceptive undisclosed fee tactic is the “repayment recalculation scam.” You take a ₦10,000 loan with disclosed repayment of ₦12,000.

After two weeks, you check your account, and the app now shows you owe ₦15,000.

When you complain, they claim “additional fees accrued” or “interest compounded” without explaining that this wasn’t in your original agreement.

This is fraud, not just a disclosure violation, and should be reported to both the FCCPC and law enforcement.

Your legal protection against hidden fees comes with an enforcement mechanism, allowing you to refuse to pay undisclosed charges and demand an itemized statement of the charges.

Under the CBN’s guidelines, lenders must provide, upon request, a complete breakdown showing the original loan amount, disclosed interest and fees, payment history, remaining balance, and an explanation of all charges.

If they can’t justify a charge with reference to your signed agreement, you have grounds to dispute it.

When you discover hidden fees, take these immediate steps as proof. Screenshot or photograph your original loan offer showing the disclosed total repayment amount.

Take a screenshot of your current balance, showing the inflated amount.

Request a written, itemized statement from the lender explaining every charge.

If the lender refuses to provide the statement or can’t justify the charges with reference to your agreement, file complaints with the FCCPC and CBN immediately, attaching your evidence.

One important right many borrowers are unaware of is that if a lender charges hidden fees and you’ve already paid them, you can demand a refund through regulatory complaints.

The CBN has ordered refunds in multiple cases of illegal charges, and the FCCPC can include refund orders in its enforcement actions.

The money isn’t gone forever just because you paid if the charges were illegal, you can potentially recover them.

Your Right to Privacy and Data Protection

When you download a loan app, and it asks for permission to access your contacts, photos, SMS messages, and call logs, most people click “Allow” without thinking because they assume it’s required for loan approval. It’s not.

In 2022, I tested 12 popular Nigerian loan apps by denying all permissions except basic phone information, and 9 of them still processed my loan application successfully.

The other three that rejected me were violating the data protection law by making excessive data access a condition of the loan.

Your personal data, including your Bank Verification Number (BVN), contact list, messages, photos, location, and call history, is legally protected in Nigeria under the Nigerian Data Protection Act (NDPA) of 2023 and enforced by both the FCCPC and the Nigeria Data Protection Commission (NDPC).

These laws establish that you own your data, and businesses can only collect, use, or share it with your informed, specific consent for legitimate purposes.

“Legitimate purpose” for a loan app means credit assessment and recovery communication with you directly, not harvesting your entire digital life for marketing or intimidation.

The data protection framework operates on three core principles that directly protect borrowers.

First, data minimization: lenders can only collect data that’s genuinely necessary for providing the loan service.

They cannot demand access to information “just in case” or for purposes unrelated to lending.

Second, purpose limitation: data collected for credit assessment cannot be repurposed for marketing, sold to third parties, or used to harass your contacts.

Third, consent requirement: You must provide clear, informed, and voluntary consent for each type of data collection, and you have the right to withdraw your consent at any time.

What this means practically is that a loan app needs your BVN to verify your identity and check your credit history with the relevant bureaus, which is a legitimate process.

They need your bank account information to disburse funds and collect repayment also legitimate.

They might need your employment information to assess your ability to repay reasonably.

However, they don’t need your contact list, photo gallery, SMS inbox, or precise GPS location to evaluate creditworthiness or process a loan.

Demanding these as loan conditions violates data minimization principles.

The enforcement mechanism is powerful. The NDPC can impose fines up to 2% of a company’s annual gross revenue or ₦10 million (whichever is higher) for serious data protection violations.

The FCCPC adds consumer protection penalties on top of this.

In 2024, the FCCPC shut down 22 loan apps for unauthorized data collection, and several faced combined penalties exceeding ₦50 million, including fines from the NDPC.

Two common myths need addressing. First, “If I agreed to the terms and conditions, I gave valid consent.” Not legally.

Consent buried in 50 pages of legal text that nobody reads doesn’t meet the NDPA’s requirement for “informed consent.”

The law requires that data collection permissions be presented clearly and separately, in plain language, before you click accept.

Second, “Once they have my data, there’s nothing I can do.” Wrong.

You have the right to request deletion of your data after your loan is fully settled, and lenders must comply within 30 days or face penalties.

Limits on App Permissions and Contact Access

The contact list harvesting scandal is what finally forced Nigerian regulators to crack down on loan apps in 2022 and 2023.

Apps were accessing entire contact lists (often 300 to 500 contacts per borrower), then using that information to send mass harassment messages when loans became overdue.

The practice created a crisis in which innocent people, including friends, family, colleagues, and church members, received defamatory messages about borrowers they barely knew.

Under the Nigerian Data Protection Act and FCCPC guidelines, loan apps cannot demand full contact list access as a mandatory condition for loan approval.

They can request contact information for references (typically 2 to 4 people you designate), but they cannot require blanket access to all contacts, and they cannot refuse your loan solely because you denied permission to access your contact list.

Any app that makes contact access mandatory is in violation of data protection law.

When you install a loan app, it requests various permissions through your phone’s operating system.

On Android, you’ll see requests like: Contacts (“Access your contacts”), Phone (“Make and manage phone calls”), SMS (“Send and view SMS messages”), Storage (“Access photos, media, and files”), Location (“Access this device’s location”), and Camera (“Take pictures and record video”).

On iOS, similar permission requests appear but with slightly different wording.

Let’s break down what loan apps really need to know versus what they are asking for too much.

Necessary permissions include phone permission (to verify your device and potentially make verification calls), basic device information (to confirm you’re a real person, not a bot), and potentially SMS for one-time password (OTP) verification codes during login.

Questionable but sometimes justified permissions include storage access when they require you to upload ID documents or bank statements for verification, although this should be optional and done through a secure file upload, not blanket storage access.

Unnecessary and potentially abusive permissions include full contact list access (they can ask you to manually enter 2 to 3 emergency contacts instead), photo gallery access (unless you’re specifically uploading a document at that moment), call log access (they have no legitimate need to see who you’ve called), SMS inbox reading (they can receive OTPs without reading your entire message history), and precise GPS location tracking (your address and state are sufficient for credit assessment).

I recommend this permission strategy when installing loan apps:

1. Deny all permissions initially.

2. Apply for the loan. If the app genuinely requires a specific permission for a legitimate function (such as camera access to photograph your ID), it will request that permission at the time of use with an explanation.

3. Grant only that specific permission temporarily. After completing the task (uploading your ID), revoke the permission in your phone settings. Never grant blanket permissions upfront “just in case.”

Many borrowers fear that denying permission will result in their loan being rejected.

Sometimes it does, and that’s a red flag indicating the app isn’t operating legally.

Licensed, legitimate lenders conduct credit assessments through formal channels, such as using your BVN, which is linked to your banking history.

The credit bureaus provide your borrowing history, and your stated employment and income can be verified through bank statements or employment letters. They don’t need to raid your phone’s data to assess creditworthiness.

If an app rejects your application specifically because you denied access to your contact list or photo gallery, document this (screenshot the rejection message if possible) and report it to the FCCPC as a data protection violation.

The app is conditioning a financial service on excessive data collection, which violates consumer protection principles.

One technical protection you can use on both Android (Settings > Apps > Permissions) and iOS (Settings > Privacy) allows you to review and revoke permissions after granting them.

If you’ve already given a loan app access to contacts or photos, you can revoke it at any time.

The app may display an error message or claim it can’t function, but your loan agreement remains valid.

They cannot cancel your loan or declare you in default simply because you revoked data permissions after the loan was already disbursed.

For borrowers who have already had their contact data harvested by apps before the 2023 regulations took effect, you have the right to request data deletion under Article 25 of the NDPA.

Send a written request (email is fine) to the loan app stating:

“Under the Nigerian Data Protection Act 2023, I request immediate deletion of all contact list data, photos, SMS messages, and call logs collected from my device. I also withdraw consent for any future collection of this data. Please confirm compliance within 7 days.”

If they don’t respond or refuse, report this non-compliance to the NDPC through their online portal at ndpc.gov.ng.

How Your Data Can and Cannot Be Used

Even when a lender legitimately collects your data with proper consent, the law strictly limits what they can do with it.

This is where many loan apps violate borrower rights, not at the point of collection, but in how they use and share the data afterward.

The Nigerian Data Protection Act’s “purpose limitation” principle means data collected for one purpose (credit assessment) cannot be repurposed for another (marketing, harassment, or sale to third parties) without new, explicit consent.

Legally permitted data uses include:

1. Assessing your creditworthiness by checking your BVN against banking records and credit bureau reports.

2. Disbursing your loan funds to your verified bank account, collecting repayment through authorized deductions from your linked account

3. Communicating directly with you about your loan status through calls, SMS, or email to your provided contact information.

4. Reporting your repayment behavior to authorized credit bureaus if you consented to this in your loan agreement.

These uses are legal because they’re necessary to provide the loan service you requested.

A lender can’t process your loan without verifying your identity (BVN), can’t disburse funds without knowing your bank account, and can’t collect repayment without contacting you when payments are due.

What separates legal from illegal data use is the boundary. Communication must be limited to you personally, through the contact information you provided, for purposes related to your loan.

Illegal or questionable data uses include:

1. Contacting people in your contact list without your explicit, written permission for each contact.

2. Sharing your personal information with other loan apps or marketing companies

3. Selling your data to third parties (data brokers, advertisers, other financial services)

4. Using your information to send marketing messages for other products or services you didn’t request.

5. Posting your photo, name, or loan details publicly (on social media, websites, or WhatsApp groups).

6. Continuing to store or use your data after your loan is fully settled and you’ve requested deletion.

The defamation-through-data-misuse scenario is particularly common and illegal.

A loan app harvests your contact list, then when your loan is overdue, they send messages to everyone in your contacts saying things like “[Your name] borrowed money and refuses to pay. They are a fraudster.”

This violates multiple laws, including data protection (using contact data for purposes beyond credit assessment), defamation (making false statements that harm one’s reputation), and consumer protection (harassment and unfair commercial practices).

I documented a case in 2023 where a borrower’s loan app sent messages to 47 people in her contact list, including her pastor, her children’s school principal, and her workplace HR department.

The messages falsely claimed she had “stolen money and gone into hiding.”

She’d actually repaid ₦18,000 of a ₦20,000 loan and was two days late on the final ₦2,000.

The FCCPC fined the app ₦8 million for defamation and data misuse, ordered them to send public apologies to all 47 contacts, and suspended their operations for 90 days.

Data sharing with third parties deserves special attention because it’s widespread and often invisible to borrowers.

Some loan apps share applicant data with affiliate apps or partner lenders, which is why applying for one loan often triggers spam calls from five other loan companies within days.

This third-party sharing without explicit consent violates the NDPA’s requirement that data subjects must be informed of and consent to each entity that will access their information.

You have specific rights regarding data sharing:

Right to know: Lenders must inform you if they share your data with third parties, identify those parties, and disclose the intended use of the data.

Right to refuse: You can deny consent for third-party sharing and still receive the loan if the sharing isn’t essential to loan processing. Right to revoke: If you initially agreed to data sharing, you can withdraw that consent at any time by written notice.

One enforcement mechanism many borrowers don’t use is this. if you start receiving spam or marketing from companies you never contacted after taking a loan, trace it back.

Ask the spam caller, “How did you get my information?” If they mention the loan app you used, you have evidence of unauthorized data sharing.

Document the spam (screenshot unknown calls, save marketing SMS) and connect it to your loan app through any evidence you can gather. Report it to the NDPC and FCCPC as illegal data sharing.

The most exploitative data misuse is the “pay-to-delete” extortion scheme.

Some predatory apps threaten borrowers with: “Pay immediately or we’ll send your information to everyone in your contacts,” or “Clear your balance today or we’ll post your photos online.”

This crosses from data misuse into criminal extortion. If a lender threatens to misuse your data unless you pay, that’s a crime under Nigerian law (Criminal Code Act, Section 408).

You should report it to both the FCCPC and the Nigeria Police cybercrime unit, not just as a regulatory complaint but as a criminal matter.

Your practical defense against data misuse starts with documentation.

Before taking out any loan, take a screenshot of the app’s privacy policy and data use disclosures (if available).

Save the exact permissions you granted in writing. During the loan term, monitor for unauthorized data use, including unknown companies contacting you, marketing materials you didn’t sign up for, or evidence that your contacts have received messages about you.

If you discover misuse, demand in writing that the lender explain the legal basis for that use and cease immediately.

Lack of response or refusal to cease is evidence for regulatory complaints.

Your Rights During Debt Recovery (No to Harassment)

Missing a loan payment doesn’t strip you of your dignity or legal protections.

In 2020, I interviewed 23 borrowers who’d experienced debt collection harassment, and every single one believed they’d forfeited all rights the moment their loan became overdue.

They tolerated threats, public shaming, and calls to their employers because they thought being “in default” meant the lender could do anything to recover the money.

That’s completely false, and it’s exactly what predatory lenders count on.

Nigerian law draws a clear line between legitimate debt collection and illegal harassment.

Lenders have the right to remind you of overdue payments, contact you through the information you provided, and pursue legal action through the courts if necessary.

They do not have the right to threaten you, defame you, contact third parties without your permission, or use any form of intimidation or coercion.

The CBN’s 2022 Guidelines on Ethical Debt Recovery and the FCCPC’s consumer protection standards explicitly prohibit abusive collection practices, with violations carrying penalties up to ₦10 million and potential criminal charges.

The harassment prohibition isn’t conditional on whether you actually owe the money.

Even if your debt is 100% legitimate and overdue, the lender must still follow legal collection procedures.

“You owe us money” doesn’t justify “so we can harass you however we want.”

Your rights during debt recovery are absolute — they don’t diminish based on your payment status, the amount you owe, or how late you are.

What distinguishes legal collection from illegal harassment often comes down to three factors, including frequency and timing (reasonable contact versus incessant calling), communication content (factual payment reminders versus threats and insults), and contact scope (reaching you directly versus broadcasting to your social circles).

Understanding these boundaries helps you identify when a lender has crossed from legitimate collection into reportable harassment.

The power dynamic in debt collection is real — lenders exploit borrowers’ shame, fear, and financial desperation to extract payment through intimidation rather than legal processes.

However, you have regulatory authorities (CBN and FCCPC) specifically empowered to stop this abuse, and they take harassment complaints seriously because it’s one of the most common and egregious violations in digital lending.

In 2023 alone, the FCCPC received over 3,500 complaints about loan app harassment, and they issued enforcement actions in more than 60% of cases where evidence was clear.

One critical point that changes how borrowers respond to harassment is that you can simultaneously dispute a debt and report harassment.

Many people think, “If I report them for harassment, I’m admitting I owe the money and can’t dispute it later.” Not true.

The legality of the debt and the legality of collection methods are separate issues.

A lender might have a valid claim for ₦15,000, but use illegal harassment to collect it. The harassment is still illegal regardless of the debt’s validity.

Conversely, you might not owe what they claim, but they’re still harassing you.

Report both the harassment and dispute the debt amount through separate processes.

What Constitutes Harassment and Defamation?

Harassment in debt collection has a legal definition under Nigerian consumer protection law, and it’s broader than most borrowers realize.

You don’t have to prove you felt threatened or scared; if the lender’s behavior crosses specific regulatory boundaries, it’s automatically classified as harassment regardless of your emotional response.

This matters because borrowers sometimes tolerate aggressive collection, thinking “it’s not that bad” when, legally, it absolutely is that bad.

The CBN’s ethical debt recovery guidelines and FCCPC enforcement precedents identify these specific behaviors as harassment: Excessive contact frequency, calling or messaging more than three times per day, or continuing to contact you after you’ve requested communication in writing only.

I’ve seen loan apps call borrowers 15 to 20 times daily, sometimes every hour, which constitutes harassment even if the caller is polite. The volume itself is intimidating and disruptive.

Contact outside reasonable hours: calling before 8 AM or after 8 PM local time without your explicit consent.

Some loan apps deliberately call at 2 AM or 6 AM to pressure borrowers through sleep deprivation.

One borrower reported receiving 47 calls between midnight and 5 AM over three nights, which is severe harassment and potentially criminal intimidation.

Threatening language or implications: stating or implying that failure to pay will result in arrest, criminal charges, harm to your family, or any consequence beyond legitimate civil debt collection. Common illegal threats include: “We’ll report you to EFCC and you’ll be arrested for fraud” (civil debt isn’t fraud, and lenders can’t unilaterally cause arrests), “We’ll come to your house and seize your property” (only courts can order property seizure through proper legal process), “Your children will suffer if you don’t pay” (threatening harm to third parties is criminal intimidation), and “We’ll make sure you never get another loan anywhere in Nigeria” (blacklisting threats to coerce payment).

Abusive, insulting, or profane language: calling you a “thief,” “fraudster,” “deadbeat,” “useless person,” or using any derogatory terms.

Even if you are genuinely behind on payment, lenders have no legal right to insult you.

Professional debt collection uses neutral language, such as “your account is overdue,” rather than “you’re a criminal who refuses to pay.”

Unauthorized third-party contact: contacting your family, friends, employer, church members, or anyone in your contact list without your prior written permission.

The only exception is if you specifically listed someone as an emergency contact or reference and consented to the lender contacting them.

General contact list harvesting doesn’t constitute consent for third-party communication.

I helped a borrower in 2022 whose loan app called her wedding planner, claimed she was a fraudster, and advised canceling the wedding catering contract because “she won’t pay her bills.”

The borrower owed ₦8,000 on a loan, but this third-party contact, who provided false information, constituted both harassment and defamation.

The FCCPC fined the app ₦6 million and ordered them to compensate the borrower ₦500,000 for reputational damage and emotional distress.

Public shaming or exposure: posting your name, photo, phone number, or debt information on social media, in WhatsApp groups, on the lender’s website, or any public forum.

Some apps maintain “defaulters lists” on their Facebook pages or send mass WhatsApp messages to neighborhood groups outing borrowers.

This constitutes illegal defamation and violates the data protection law’s prohibition on processing personal data in a manner that causes harm.

Defamation specifically means making false statements that damage your reputation.

The legal standard in Nigeria for defamation requires that a statement be made about you, the statement be communicated to at least one other person (publication), the statement harm your reputation, and the statement be false or made with malicious intent.

In debt collection, defamatory statements typically include falsely claiming you “stole” money when it’s a civil loan dispute, calling you a “fraudster” or “criminal” when no crime has been proven, telling third parties you’re “refusing to pay” when you’ve actually disputed the debt amount or the charges are illegal, and any statement that goes beyond the factual “this person owes a debt” to character assassination.

One scenario that confuses borrowers is this… “Is it defamation if what they said is technically true?”

For example, you do owe money, and they tell your contacts you owe money.

The answer depends on how and why they communicated it.

Stating a factual debt to third parties without your consent still violates your privacy rights and may constitute harassment, even if not technically defamation.

Adding false or exaggerated elements (claiming you owe ₦50,000 when you owe ₦20,000, or saying you “refuse” to pay when you’re simply unable) crosses into defamation.

The practical test I suggest is that if a lender’s communication makes you feel humiliated, threatened, or unsafe, it’s likely harassment.

If their communication involves contacting people you know, it’s almost certainly illegal.

If they use language that attacks your character rather than neutrally stating facts about an overdue account, it’s harassment.

Trust your instincts. Abusive behavior feels abusive because it is.

Your Right to Dispute a Debt

The dispute process starts with written notification. Send an email or formal letter to the lender stating:

“I am formally disputing the debt you claim I owe. I received ₦[amount] on [date], repaid ₦[amount] on [dates], and believe my remaining balance should be ₦[amount] based on the agreed interest rate of [rate]. You are claiming I owe ₦[amount]. Please provide: (1) A complete account statement showing all charges and calculations, (2) Copies of the loan agreement showing all disclosed fees, (3) Confirmation of all payments received from me, (4) Legal basis for any charges not in the original agreement. Until this dispute is resolved, I request that you cease all collection activities.”

Document everything: Keep copies of your loan agreement, screenshots of all payments you’ve made, records of any communication with the lender, and your written dispute notice.

If the lender continues to harass you after receiving your dispute, that constitutes a separate violation; they’re required to pause collections during the investigation.

I worked with a borrower in 2023 who took a ₦25,000 loan, repaid ₦31,000 over three months (matching the agreed schedule), and then received calls claiming she still owed ₦12,000.

She sent a formal dispute letter with bank statement proof of her ₦31,000 in payments.

The lender investigated and discovered their system had failed to record her second payment of ₦10,000.

They corrected her account to show zero balance, apologized, and sent written confirmation.

Without the formal dispute, their system error would have resulted in ongoing harassment and potential misreporting to the credit bureau.

Common lender responses to disputes fall into three categories:

Legitimate investigation: They review records, acknowledge errors if they exist, and correct your account.

This is the desired outcome, demonstrating that the lender operates professionally.

Stonewalling: They ignore your dispute, fail to respond within 30 days, or refuse to provide the requested documentation.

This is a violation of consumer protection standards, providing grounds to escalate to the CBN or FCCPC.

Intimidation: They respond by intensifying harassment, threatening legal action, or claiming your dispute is “frivolous.” This combines the original dispute issue with new allegations of harassment.

If a lender refuses to honor your dispute rights or doesn’t respond substantively within 30 days, you have two escalation paths.

File a complaint with the CBN (if the lender is licensed) specifically stating: “I disputed this debt on [date], provided evidence, and the lender has failed to investigate or respond within 30 days as required by consumer protection guidelines.”

File a complaint with the FCCPC, stating the same, and emphasize that continued collection on a disputed debt without investigation violates fair commercial practices.

One powerful aspect of dispute rights is that if a lender reports you to credit bureaus as “defaulting” on a debt you’ve formally disputed and they haven’t validated, that constitutes credit reporting misconduct.

The credit bureaus themselves (CRC Credit Bureau and FirstCentral) have dispute processes that allow you to challenge inaccurate reporting.

Reference your dispute with the lender and any evidence showing the debt amount is contested.

The biggest mistake borrowers make with disputes is continuing to make partial payments on a disputed amount while the dispute is unresolved.

This can be interpreted as an acknowledgment of the debt and weakens your position in the dispute.

Instead, if you genuinely believe the debt is incorrect, formally dispute it and stop payments until it’s resolved.

If you know you owe something but dispute the specific amount, you can offer to place the undisputed portion in escrow or make payments under protest (state in writing “I’m paying this under protest while disputing the excess charges”).

Your right to dispute doesn’t depend on whether the lender agrees with you initially. You have the right to dispute first, and then they must investigate the matter.

Even if their investigation concludes you do owe what they claim, you’ve established a paper trail showing you questioned the debt in good faith, which matters if you later need to prove to regulators or courts that you weren’t simply “refusing to pay” but legitimately challenging inaccurate charges. 

Your Rights Regarding Credit Information

Your credit report is the financial record that follows you through every major transaction in Nigeria loan applications, mortgage requests, job applications at financial institutions, even some rental agreements.

Yet most Nigerian borrowers have never seen their own credit report and don’t know they have legal rights to access, review, and correct it.

I didn’t check my credit report until 2021, and I discovered an error where a microfinance bank had reported me as defaulting on a ₦50,000 loan I’d never taken.

That phantom debt had been dragging down my credit score for 14 months before I found and corrected it.

Nigeria operates a centralized credit reporting system where licensed credit bureaus (primarily CRC Credit Bureau, FirstCentral Credit Bureau, and XDS Credit Bureau) collect borrowing and repayment information from lenders and compile it into individual credit reports.

Every time you take a loan, every payment you make or miss, and every account closure gets reported to these bureaus and becomes part of your permanent credit history.

This information determines whether future lenders approve you, what interest rates they offer, and your borrowing limits.

The Credit Reporting Act of 2017 establishes specific borrower rights regarding this information, enforced by the CBN.

These rights include:

1. The right to know what information exists about you in credit bureau databases

2. The right to access your credit report at least once annually for free

3. The right to dispute inaccurate or incomplete information

4. The right to have errors investigated and corrected within reasonable timeframes, the right to add explanatory statements to your report

5. The right to know who has accessed your credit report in the past 12 months.

These aren’t courtesy privileges lenders extend; they’re legal entitlements that bureaus and lenders must honor.

Yet credit bureaus and lenders often create bureaucratic obstacles hoping borrowers won’t exercise these rights.

The correction process can take 30 to 60 days, requires persistent follow-up, and involves coordination between bureaus and lenders who sometimes refuse accountability for reporting errors.

What makes credit reporting particularly critical in the loan app era is the high rate of reporting errors.

Digital lenders with automated systems frequently misreport payment status, fail to update accounts when debts are settled, or report incorrect amounts.

I’ve documented cases where borrowers fully repaid loans but lenders never updated the credit bureau, leaving “defaulted” status on their reports for years.

One borrower repaid a ₦30,000 loan in full in 2022, but the lender’s system glitch never transmitted the “closed/paid” status to CRC.

She was denied four subsequent loan applications over 18 months before discovering the error and forcing a correction.

The practical impact of credit report errors extends beyond loan rejections.

Some employers in financial services check credit reports during hiring, reasoning that someone with debt management problems might be a fraud risk.

Landlords increasingly request credit checks before approving tenancy.

Even mobile phone providers offering device financing review credit scores.

An error on your credit report can sabotage opportunities across multiple life areas, which is why regular monitoring and aggressive error correction are essential protective behaviors.

Two common borrower misconceptions damage their credit unnecessarily:

First, “If I pay off a bad loan, it disappears from my record.” That is not true.

Negative information (late payments, defaults, collections) typically remains on Nigerian credit reports for 7 years from the date of last activity, even after you’ve fully repaid.

What changes is the status from “unpaid default” to “paid collection,” which is less damaging but still visible.

Second, “Checking my own credit report hurts my credit score.” False.

When you request your own report (called a “soft inquiry”), it doesn’t affect your score.

Only when lenders check your credit during loan applications (called a “hard inquiry”) does it potentially impact your score, and even then, the effect is minor if inquiries are infrequent.

Accessing Your Credit Report for Free

Under the Credit Reporting Act, you’re entitled to request and receive one free credit report from each licensed credit bureau annually.

This means you can get up to three free reports per year (one from CRC, one from FirstCentral, one from XDS) without paying the typical ₦1,000 to ₦2,000 fee bureaus charge for additional reports.

Most Nigerians never claim this right, which is exactly what credit bureaus prefer less work for them, and consumers remain ignorant of what’s being reported about them.

To access your free annual credit report from CRC Credit Bureau (the largest and most widely used), visit their website at creditregistryng.com and look for the “Request Your Credit Report” or “Consumer Services” section.

You’ll need to create an account using your email address and phone number, then complete a verification process that typically requires your BVN to confirm identity.

The bureau may ask security questions based on your credit history (like “Which of these institutions have you borrowed from?”) to ensure you’re actually you and not someone trying to access another person’s report.

After verification, you can request your report through the portal.

Specify that you’re requesting your free annual report as entitled under the Credit Reporting Act some bureau interfaces try to automatically charge you ₦1,000 for “instant reports” when your free report is equally available with slightly longer processing (usually 24 to 48 hours instead of instant).

Download the report as a PDF and save multiple copies. Review it carefully for accuracy before the next steps.

FirstCentral Credit Bureau’s process is similar. Visit firstcentralcreditbureau.com, navigate to their consumer report request section, complete identity verification using BVN, and request your free annual report.

XDS Credit Bureau follows comparable procedures at their portal.

If you encounter technical difficulties or the websites demand payment for what should be a free annual report, call their customer service lines and explicitly state:

“I am requesting my free annual credit report as provided under Section 21 of the Credit Reporting Act 2017. Please process this without charging me.”

One strategic timing tip I learned is for you to request reports from different bureaus at different times of the year.

Get your CRC report in January, your FirstCentral report in May, and your XDS report in September.

This gives you three checkpoints throughout the year to catch errors quickly rather than waiting 12 months between reviews.

Since different lenders report to different bureaus (some report to all three, some to only one or two), spreading your requests helps you monitor what each bureau has on file.

Your credit report contains several sections, and understanding what you’re looking at helps identify errors.

Personal Information shows your name, date of birth, address, phone number, email, BVN, and sometimes employment details.

Check this section first for basic identity errors such as wrong name spelling, incorrect address, or someone else’s information mixed with yours (which suggests identity confusion in the bureau’s database).

Credit Accounts lists every loan, credit card, overdraft, or other credit facility you’ve had, showing the lender’s name, account opening date, credit limit or loan amount, current balance, payment history (whether you’ve paid on time or been late), and account status (open, closed, in default, in collections).

This is where most errors appear, accounts you don’t recognize, balances that don’t match your records, or closed accounts still showing as open.

Inquiries shows every time a lender or business checked your credit in the past 12 months, including the company name and inquiry date.

Multiple inquiries in a short period can slightly lower your score, so review this for unauthorized credit checks.

If you see inquiries from companies you never applied to, it could indicate identity theft or unauthorized credit checks (some employers or landlords check credit without proper authorization).

Public Records includes any court judgments, bankruptcies, or tax liens related to you.

Hopefully this section is empty, but if it contains information, verify its accuracy. Sometimes courts or government agencies report to the wrong person’s file.

Credit Score is usually displayed prominently at the top, typically ranging from 200 to 900 in Nigerian credit scoring models.

Higher scores indicate better creditworthiness. While the exact formula is proprietary, scores generally reflect your payment history (35% weight), amounts owed (30%), length of credit history (15%), types of credit (10%), and recent inquiries (10%).

When reviewing your report, use a highlighter or notes to mark anything questionable; including accounts you don’t recognize, balances that seem wrong, payments reported as late when you paid on time, accounts showing “open” that you closed years ago, or negative information that should have aged off after 7 years.

These become the basis for your dispute process.

One mistake borrowers make is assuming credit bureaus independently verify information before adding it to your report. They don’t.

Credit bureaus simply collect whatever lenders report and compile it.

If a lender reports inaccurate information, it appears on your report as fact until you dispute it.

The bureaus aren’t neutral investigators; they’re data aggregators.

Your responsibility is catching and challenging errors because neither the bureau nor the lender will proactively correct them.

Correcting Errors on Your Credit Report

Disputing credit report errors requires patience and documentation, but the Credit Reporting Act guarantees your right to have inaccurate information investigated and corrected.

The process involves three parties, which includes you (the consumer), the credit bureau (which maintains the report), and the data furnisher (the lender who reported the information).

All three must cooperate for corrections to succeed, and the law sets specific timelines each party must follow.

Start by documenting the error thoroughly before filing your dispute.

For each inaccuracy, gather the specific information from your credit report that’s wrong (screenshot or highlight the relevant section), evidence proving the information is incorrect (bank statements showing you paid, loan closure letters, correspondence with the lender), and a clear statement of what the correct information should be.

The stronger your evidence, the faster the resolution.

File your dispute directly with the credit bureau through their official dispute channels.

For CRC Credit Bureau, log into your account portal, navigate to “Dispute a Report” or “File a Complaint,” and complete the dispute form specifying:

1. Which specific account or information is inaccurate

2. Why it’s wrong (be specific: “Account shows balance of ₦50,000 but I fully repaid this loan on March 15, 2023”)

3. What correction you’re requesting (“Update account status to ‘Closed/Paid in Full’ and set balance to ₦0”).

Upload your supporting documents, bank statements, payment receipts, loan closure letters, correspondence with the lender.

The more documentation you provide, the less back-and-forth required.

Write a brief but clear explanation, such as:

“I am disputing the XYZ Loan App account listed on my report. The report shows I currently owe ₦50,000, but attached bank statements prove I made final payment of ₦50,000 on March 15, 2023, closing this account. I request this account be updated to reflect zero balance and ‘Closed/Paid’ status.”

The credit bureau must acknowledge your dispute within 7 business days and initiate an investigation within 30 days under the Credit Reporting Act.

During investigation, they contact the lender (data furnisher) and ask them to verify the disputed information.

The lender must respond within 30 days, either confirming the information is accurate or acknowledging the error and providing corrected data.

Here’s where the process often stalls:

Lenders don’t respond to bureau inquiries, or they respond claiming “information is accurate” without actually reviewing your evidence.

If after 30 days the bureau hasn’t resolved your dispute, escalate by sending a formal written complaint to the bureau’s compliance officer (contact information should be on their website), filing a complaint with the CBN’s Consumer Protection Department referencing both the credit reporting error and the bureau’s failure to investigate within statutory timelines, and sending a separate complaint directly to the lender demanding they correct their reporting.

I helped a borrower in 2023 whose dispute sat unresolved at CRC for 52 days with no response.

We filed a CBN complaint specifically stating: “CRC Credit Bureau has failed to complete investigation of my disputed account within the 30-day requirement of the Credit Reporting Act.

The disputed account with [Lender Name] remains inaccurately reported despite clear evidence of full repayment.”

The CBN contacted both CRC and the lender, and the account was corrected within 14 days of the CBN complaint, something that hadn’t happened in nearly two months of direct bureau engagement.

If the investigation confirms your dispute is valid, the bureau must correct your report and provide you with an updated copy showing the correction at no charge.

They must also notify any entity that accessed your report in the past 6 months about the correction, so if you were denied a loan based on the incorrect information, that lender will be informed of the update.

If the investigation concludes the information is accurate (and you disagree), you have additional rights:

You can add a 100-word consumer statement to your credit report explaining your side, for example, “This account shows late payments, but they resulted from the lender’s failure to process my automatic payments due to technical errors on their end, not my failure to pay.”

Future lenders reviewing your report will see this statement.

You can request the bureau provide you with the specific documentation the lender supplied to support their claim that the information is accurate.

Sometimes lenders claim information is correct but can’t actually provide proof, which gives you grounds for further dispute.

You can file a complaint with the CBN arguing that the lender’s verification was inadequate or that the bureau didn’t conduct a proper investigation.

Include all your evidence and explain why you believe the conclusion is wrong.

Common credit report errors I’ve seen successfully corrected include:

– Loans reported as “active” or “defaulted” when they were fully repaid years ago (the lender never sent closure notification to the bureau).

– Wrong loan amounts (a ₦20,000 loan reported as ₦50,000 due to data entry errors)

– Payment history showing late payments when bank statements prove on-time payment (system glitches at the lender’s end)

– Accounts belonging to someone else entirely appearing on your report (identity confusion, often people with similar names or shared addresses)

– Negative information remaining beyond the 7-year legal limit (bureaus don’t automatically purge old data and rely on consumers to notice).

One persistent problem I’ve noticed is the opening of fraudulent accounts by identity thieves.

If you see a loan on your credit report that you never took out, this could be a sign of fraud.

The dispute process remains the same; however, you should also file a police report for identity theft and reference it in your credit bureau dispute.

The Credit Reporting Act requires bureaus to block information resulting from identity theft within 4 business days of receiving a valid identity theft report.

For borrowers dealing with multiple errors across different bureaus, you must dispute separately with each bureau; corrections at CRC don’t automatically flow to FirstCentral or XDS.

It’s tedious but necessary. The silver lining is that many errors are duplicated across all three bureaus (since they all received the same incorrect information from the lender), so your evidence and dispute language can be reused for each bureau submission.

How to Enforce Your Rights: A Step-by-Step Action Plan

Knowing your rights means nothing if you don’t know how to enforce them when lenders violate them.

I’ve met borrowers who could recite every protection they had, such as transparency, privacy, freedom from harassment — but when a loan app actually broke those rules, they froze, unsure whether to complain to the lender, report to regulators, or hire a lawyer.

The gap between knowing rights and enforcing them is where most violations go unpunished, and most borrowers remain exploited.

Enforcement follows a logical escalation path, which includes internal complaint with the lender first (giving them a chance to resolve it directly), regulatory complaint with the FCCPC or CBN (bringing government enforcement power), and legal action through courts or consumer advocacy organizations if regulatory channels fail or if you’re seeking compensation beyond what regulators can order.

Not every violation requires all three steps; many cases resolve at the internal complaint stage when lenders realize you’re documenting everything and know your rights.

The foundation of successful enforcement is documentation.

Without evidence, your complaint becomes a “he said, she said” dispute that regulators can’t resolve conclusively.

With strong evidence, screenshots, call logs, written correspondence, and bank statements, your complaint becomes an open-and-shut case that regulators can act on immediately.

I’ve seen identical violations (harassment by the same loan app) result in enforcement action for one borrower but not another, simply because the first borrower had clear screenshots while the second had only verbal descriptions.

What surprises many borrowers is how accessible enforcement channels actually are.

You don’t need a lawyer to file regulatory complaints; the processes are mostly online and free, and regulators actively want to hear from consumers because that’s how they identify problem lenders.

The FCCPC processed over 3,500 loan app complaints in 2023, and many were filed directly by borrowers without legal representation.

The system is designed for ordinary people to use, although it is helpful to understand the process before you need it.

One strategic principle that guides enforcement timing is to act while violations are ongoing or recent, rather than months later.

Regulators prioritize active harm over historical grievances.

A complaint about harassment that occurred today receives a faster response than one about harassment that stopped six months ago.

If a lender is currently violating your rights, document the incident and report it immediately.

Don’t wait until the situation resolves itself or until you’ve accumulated months of violations; report the issue early and continue documenting it if the violations persist.

The emotional barrier is real. Many borrowers feel shame about owing money and hesitate to “cause trouble” by filing official complaints.

Others fear retaliation, believing that reporting will only make the lender angrier and intensify the harassment.

The truth is, lenders who violate consumer protection laws are already causing as much trouble as they’re willing to cause.

Reporting them doesn’t escalate the situation; it brings regulatory pressure that usually stops it.

In dozens of cases I’ve tracked, harassment decreased or stopped entirely after FCCPC complaints were filed, not increased.

Documenting Violations and Filing Complaints

Documentation is your ammunition in enforcement actions, and the quality of your evidence directly determines the speed and strength of regulatory response.

Regulators can’t act on vague claims; they need concrete proof showing who violated your rights, what they did specifically, when it happened, and how it harmed you.

Documentation is building a case file that will persuade someone who wasn’t present to take action on your behalf.

Start documenting the moment you suspect a violation, not after you’ve decided to file a complaint.

Many violations occur over time (such as repeated harassment and accumulating hidden fees), and contemporaneous documentation is far more credible than retroactive attempts to reconstruct events from memory.

Create a dedicated folder on your phone or computer labeled with the lender’s name and start saving everything related to the violation.

For harassment violations, capture screenshots of every threatening, insulting, or harassing SMS or WhatsApp message showing the sender’s number, message content, date, and time.

Make sure the loan app’s name or identifying information is visible in the screenshot.

Call logs showing the frequency and timing of calls from the lender’s numbers are available on most phones, which let you screenshot or export the call history.

Record the dates, times, and duration of harassment calls, noting anything specific said during the call immediately after hanging up.

Screenshots of messages sent to your contacts by the lender. If family, friends, or colleagues forward you messages they received about you, screenshot those messages, showing the sender, content, and date.

This proves third-party contact. Save any emails from the lender containing threats, insults, or harassment as PDFs or take screenshots that show the full email, including the sender’s address and timestamp.

For hidden fee violations, document your original loan offer or application confirmation, showing the advertised interest rate and fees (screenshot the app interface, save confirmation emails, or SMS).

Your loan agreement or terms and conditions, particularly sections covering interest rates, fees, and total repayment amount, should be screenshot or saved as a PDF.

Bank statements showing the actual amount disbursed to you (often less than the approved loan amount due to undisclosed deductions) and all amounts deducted for repayment (often more than the disclosed total).

Screenshots of your current balance in the loan app showing how it differs from what you expected based on disclosed terms.

Any correspondence where you questioned fees and the lender’s response (or lack of response).

For data privacy violations, capture screenshots of app permission requests at installation time, if possible (though most people only think to document this after violations have occurred).

Your phone’s app permission settings show what access the loan app has (Settings > Apps > [App Name] > Permissions on Android, or Settings > Privacy on iOS).

Screenshots showing the app accessing data it shouldn’t need (for example, if you receive notifications that the app accessed your photos or contacts).

Evidence of unauthorized data use, marketing SMS or calls from other companies that started after you took the loan (suggesting data sharing), messages sent by the lender to your contacts (proving they used harvested contact data), or any public posting of your information.

For transparent pricing violations, your evidence overlaps with hidden fee documentation, but emphasizes the deception: a side-by-side comparison of advertised terms versus actual terms (screenshot the app’s marketing page stating “5% interest” next to your loan agreement, which shows additional charges totaling 25%).

Communications where you asked about costs and received false or incomplete information. Any bait-and-switch situations where terms changed between application and disbursement.

Once you’ve compiled documentation, organize it chronologically and create a summary document listing each piece of evidence with a brief description:

“Screenshot 1: SMS from loan app on Dec 15, 2024, calling me a ‘fraudster,’ Screenshot 2: Call log showing 15 calls in one day on Dec 16, 2024,” and so on.

This summary helps regulators quickly understand what they’re looking at without having to search through random files.

Filing complaints with the FCCPC should be your primary action for harassment, data privacy, and unfair practices.

The FCCPC has broader authority and operates more efficiently than the CBN in addressing consumer protection issues.

Visit fccpc.gov.ng, navigate to the complaints portal, and complete the online form with your personal information (name, phone, email, state), the lender’s information (app name, company name if known, contact details), nature of complaint (select harassment, data privacy violation, or unfair practices), and a detailed description of what happened.

In your description, be specific and factual:

“On December 15, 2024, [Loan App Name] sent threatening WhatsApp messages to 12 people in my contact list claiming I am a fraudster.

I borrowed ₦20,000 on November 1 and repaid ₦24,000 on December 10 (attached bank statement), but they continue to claim I owe ₦8,000 in undisclosed fees.

They have called me 47 times in the past week, including calls at 2 AM (attached call log).

I never gave permission for them to contact anyone except me, and they accessed my contact list without proper consent.

I request the FCCPC to:

(1) Stop this harassment immediately.

(2) Investigate their data collection practices.

(3) order correction of my account to reflect full repayment.”

Upload your strongest 3 to 5 pieces of evidence (the portal typically allows 3 to 5 attachments).

Choose screenshots that most clearly show the violation, the most threatening message, the call log showing excessive frequency, and the bank statement proving repayment.

Save your complaint reference number immediately.

Filing complaints with the CBN is appropriate for unlicensed lending operations (report that the app isn’t on the CBN’s approved lenders list), interest rate violations by licensed lenders (rates exceeding CBN caps), lending guideline violations by licensed institutions, and credit reporting inaccuracies that the lender refuses to correct.

Visit cbn.gov.ng, navigate to the Consumer Protection Department section, and file through their online portal or submit your request via their postal address if you prefer physical submission.

The CBN process is similar. Provide your information, the lender’s information, specific details of the alleged violation, and supporting evidence.

Reference specific CBN regulations if you know them (for example, “This violates the CBN Consumer Protection Framework 2023 prohibition on third-party contact”), but don’t worry if you don’t know exact regulation numbers, describe the violation clearly, and the CBN will identify which rules apply.

For urgent harassment requiring immediate intervention, use the FCCPC’s social media channel (@fccpcnigeria on Twitter/X) or their WhatsApp line (0905 315 5522) in addition to filing a formal complaint.

Tag them in a public tweet with your most damning evidence (the clearest harassment screenshot) and a brief description:

“I’m being harassed by [App Name] with threats to my family. I’ve filed a formal complaint [reference number]. Please help urgently.”

The public nature often triggers a faster response.

Follow up on your complaints after 7 days if you haven’t received acknowledgment, and after 21 days if you haven’t received substantive updates.

Call the FCCPC at 0800 888 5622 or the CBN at 0700 CALL CBN with your reference number and ask:

“I filed a complaint [number] on [date] regarding [lender name]. What is the current status?”

Polite but persistent follow-up prevents cases from getting lost in processing queues.

One enforcement shortcut many borrowers don’t use is to file complaints about the same lender through multiple channels simultaneously.

Report to the FCCPC for harassment, report to the CBN if they’re unlicensed or violating lending rules, report to the NDPC for data privacy violations, and if threats rise to a criminal level, report to the Nigeria Police cybercrime unit.

These agencies coordinate, and multiple simultaneous complaints signal a serious pattern that demands action.

Seeking Legal Aid and Consumer Advocacy Groups

Most borrower rights violations can be resolved through regulatory complaints without the need for lawyers or courts, but some situations may benefit from legal representation.

When you’re seeking monetary compensation for damages beyond simple refunds (defamation damages, compensation for lost employment).

When the lender files a lawsuit against you, you need to defend yourself.

When regulatory complaints haven’t been resolved after 90 days, and you wish to escalate the issue to court, or when violations are severe enough to warrant criminal prosecution (such as extortion, fraud, or identity theft).

Legal representation costs money, typically ranging from ₦50,000 to ₦300,000, depending on the case complexity and the lawyer’s experience, which puts it out of reach for many borrowers dealing with relatively small loan amounts.

Hiring a ₦150,000 lawyer to fight over a ₦20,000 loan dispute makes no economic sense. This is where free or low-cost legal aid becomes critical.

The Legal Aid Council of Nigeria provides free legal representation to indigent Nigerians (people who can’t afford private lawyers) in civil and criminal matters.

While they prioritize criminal defense, they do handle consumer protection cases involving clear rights violations.

Visit their offices in your state capital or contact their headquarters in Abuja.

Bring all your documentation and be prepared to demonstrate financial need (proof you can’t afford a private lawyer).

The Legal Aid Council’s services are provided free of charge to eligible clients.

To qualify for Legal Aid Council assistance, you typically must earn below a certain income threshold (usually around ₦30,000 monthly, though this varies by state), demonstrate that the case has merit (your evidence shows clear violations), show that you’ve attempted other resolution methods (filed regulatory complaints), and demonstrate that legal action is necessary and proportionate to the harm suffered.

The Nigerian Bar Association (NBA) operates pro bono programs in most of its state chapters, where volunteer lawyers handle cases for free or at reduced fees.

Contact your state’s NBA branch and ask about their “pro bono services” or “access to justice program.”

Explain your situation and describe the violations you’ve experienced.

Some state chapters have specific consumer protection committees that focus on cases like loan app harassment.

The International Federation of Women Lawyers (FIDA) Nigeria provides free legal services primarily to women and children, but its consumer protection work also extends to cases of financial exploitation affecting women.

If you’re a woman experiencing loan app harassment or exploitation, FIDA may represent you at no cost.

They have branches in all 36 states plus Abuja. Their services include legal advice, representation in court or at regulatory hearings, and negotiation with lenders on your behalf.

Consumer advocacy organizations provide support even if they can’t offer direct legal representation.

The Socio-Economic Rights and Accountability Project (SERAP) focuses on social justice and economic rights, including financial consumer protection.

They’ve filed high-profile cases against government agencies and private companies for consumer rights violations.

While they can’t take every individual case, they track patterns and sometimes file class action suits representing multiple affected consumers.

The Consumer Advocacy Foundation of Nigeria (CAFON) specifically focuses on consumer protection across all sectors, including financial services.

They provide consumer education, advocate for policy changes, and occasionally represent consumer groups in regulatory proceedings or media campaigns.

Contact them if you’re aware of a loan app victimizing multiple borrowers; collective action through CAFON may be more effective than individual complaints.

The Citizens Mediation Centre operates in some states, offering free mediation services to resolve consumer disputes without the need for litigation.

Mediation involves a neutral third party helping you and the lender reach a settlement agreement.

While mediation requires the lender’s voluntary participation (they can refuse), having a formal mediator sometimes motivates lenders to settle rather than face regulatory or legal action.

For borrowers pursuing legal action, understand the court hierarchy:

Magistrate Courts handle civil claims up to ₦1 million, making them appropriate for most individual loan disputes.

Filing fees are typically ₦5,000 to ₦15,000, relatively affordable.

Cases are typically resolved within 6 to 12 months, although delays are common.

High Courts handle claims exceeding ₦1 million and have broader jurisdiction for complex commercial disputes or claims involving constitutional rights.

Filing fees range from ₦15,000 to ₦50,000, and cases typically take 1 to 3 years to resolve.

Small Claims Courts exist in Lagos, Abuja, and a few other states for claims valued at ₦5 million or less.

These courts are designed for fast resolution (typically 60 to 90 days) with simplified procedures that don’t require lawyers.

If your state has a Small Claims Court, this is often the best judicial option for loan disputes because it’s affordable, relatively quick, and you can represent yourself effectively with good documentation.

One alternative to courts that’s gaining traction is the establishment of Consumer Protection Council tribunals under the authority of the FCCPC.

These administrative tribunals hear consumer complaints and issue binding orders, eliminating the formality and expense associated with regular courts.

As of 2024, these are still being rolled out across states; however, where available, they offer faster and more affordable resolutions than traditional courts.

When deciding whether to pursue legal action, weigh the costs (lawyer fees, court fees, time investment over months or years) against the likely recovery (refund of excess charges, compensation for damages).

For small amounts (under ₦50,000), regulatory complaints are almost always more cost-effective than lawsuits.

For larger amounts (over ₦100,000) or cases involving significant reputational harm, legal action may be justified.

One powerful tool that lawyers bring, which borrowers acting alone can’t access, is discovery.

In court proceedings, your lawyer can compel the lender to produce internal documents, account records, communication logs, and other evidence they’ve been hiding.

Many lending violations become undeniable once internal records are exposed through legal discovery.

This is particularly valuable in cases where the lender has deleted records or claims violations never occurred.

Free resources for self-education and support include the CBN’s Consumer Protection Portal, which offers educational materials explaining borrower rights and how to file complaints.

The FCCPC’s website offers guides on consumer rights and enforcement procedures.

Online forums, such as Nairaland’s legal section, where lawyers and experienced individuals provide free advice (not formal legal representation, but helpful guidance).

And Consumer rights WhatsApp and Telegram groups, where borrowers share experiences and strategies (search social media for “Nigeria consumer rights” or “loan app victims support group”).

If you’re considering legal action but can’t afford upfront lawyer fees, ask about contingency fee arrangements, where the lawyer takes a percentage (typically 30% to 40%) of any money recovered instead of charging an upfront fee.

Some lawyers accept consumer rights cases on contingency if the violations are clear and recovery seems likely.

This makes legal representation accessible even without money for retainer fees.

FAQs

Can a loan app contact my family and friends if I default?

No, loan apps cannot legally contact your family, friends, employer, or anyone in your contact list without your explicit written permission, even if you’re in default. The CBN’s 2022 Guidelines on Ethical Debt Recovery explicitly prohibit lenders from contacting third parties for debt collection purposes unless you provided written consent naming those specific individuals as authorized contacts.

What is the maximum interest rate a lender can charge in Nigeria?

This depends on the lender’s license type and regulatory status, and there’s significant variation across different lending categories.

For microfinance banks (which include most licensed digital lenders), the CBN has historically set interest rate caps at around 30% to 36% annually, although exact maximums vary based on loan type, duration, and the specific license category. However, these caps apply only to institutions licensed and regulated by the CBN; they have no legal force over unlicensed lenders.

For commercial banks, interest rates are generally market-determined, but the CBN provides guidance rates and monitors for “unconscionable” lending that exploits consumers. Commercial bank personal loans typically range from 18% to 35% annually as of 2024, though rates above 40% would likely trigger regulatory scrutiny.

For unlicensed digital lenders (the apps operating without CBN approval), there are no specific interest rate caps because they exist outside the formal regulatory framework. However, the FCCPC can still sanction them for charging “unconscionable” or “exploitative” rates under general consumer protection principles. What constitutes “unconscionable” isn’t precisely defined but generally means rates so excessive they constitute predatory lending, think 300%, 500%, or 1,000%+ APR.

The reality in Nigeria’s digital lending space as of 2024 is that many apps charge effective APRs between 100% and 400% annually when you calculate the cost, including all fees.

A typical pattern is a 30-day loan advertised at “5% monthly interest” (60% annually) but with 15% to 20% upfront fees, resulting in an effective APR of 150% to 180%.

These rates exceed what licensed microfinance banks are permitted to charge, which is why verifying whether an app is CBN-licensed is crucial for rate protection.

Do I have the right to cancel a loan after approval but before disbursement?

Yes, you generally have the right to cancel a loan application after approval, but before the money is disbursed to your account.

Although this right isn’t explicitly codified in Nigerian financial regulations, as it is in some other countries, it is generally recognized.

The principle derives from basic contract law: a loan contract isn’t fully formed until there’s an offer (loan approval), acceptance (you agreeing to proceed), and consideration (money actually changing hands). Before disbursement, you can withdraw your acceptance.

How long does negative information stay on my credit report in Nigeria?

Negative information, including late payments, defaults, collections, and loan accounts closed due to non-payment, typically remains on Nigerian credit reports for 7 years from the date of last activity on the account.

This is the general standard followed by CRC Credit Bureau, FirstCentral Credit Bureau, and other licensed bureaus, though the Credit Reporting Act doesn’t specify exact timeframes and leaves some discretion to the credit bureaus.

What can I do if a lender continues to call me at work?

This is illegal harassment. Stop it fast.

You did not give them permission to call your job. Here is your action plan:

Step 1: Document It
Write down every call: date, time, and what was said.

Step 2: Tell Them To STOP
Send an email/SMS saying: “Stop calling my workplace. It is prohibited. All contact must go to my personal number only.”

Step 3: File A Complaint
Report them to the FCCPC immediately. Include your “stop” message and your proof.

Step 4: Tell Your HR
Give your HR a heads-up: “A predatory lender may call. I am handling it with the regulators. Please do not give any info.”

Step 5: Block Their Numbers
Block them on your phone.

They cannot harass you at work just because you owe money. Their only legal option is to take you to court — not shame you at your job.

Stand your ground. Once you demonstrate that you know the law and are willing to complain, they usually back down quickly.

Conclusion

You are NOT powerless.

Not against the harassment. Not against the hidden fees. Not against the threats to your family.

You have rights that are protected by laws and backed by government agencies.

And right now, you’re going to learn how to use them.

The truth is, lenders can do some things. They can charge you interest. They can remind you that a payment is late.

But they cannot cross the line.

They cannot:

–  Harass your family and friends.

–  Call you at work to shame you.

–  Hide giant fees in tiny print.

–  Charge you 300% interest.

When they cross that line, you fight back.

Your 5-Step Action Plan (Do This NOW)

1. KNOW Before You Borrow.

Check the lender against the CBN’s approved list. Calculate the TRUE cost. If you’d pay back double what you borrowed in a year, walk away.

2. DOCUMENT Everything.

Create a folder. Screenshot everything: the loan offer, the terms, every message, every call log. This is your ammunition.

3. REPORT Violations IMMEDIATELY.

Harassment? Hidden fees? File a complaint with the FCCPC at fccpc.gov.ng. Do it within days, not weeks. For urgent threats, message them on Twitter @fccpcnigeria.

4. CHECK Your Credit Report.

Receive your complimentary report annually. Look for mistakes or loans you don’t recognize. Dispute errors fast.

5. DISPUTE What You Don’t Owe.

If they claim you owe illegal charges, send a written dispute. They must stop collecting and prove you owe it.

A quick word if you just don’t want to pay a fair loan. These rights are a shield against abuse, not a magic eraser for debt. If you got a fair deal and can pay, you should pay.

But listen closely:

If you were abused, threatened, shamed, or cheated — that is still illegal. Even if you owe the money. You can pay what’s fair and demand they stop breaking the law.

Predatory lenders bet on your silence. They bet you feel ashamed. They bet you don’t know your rights.

You just lost that bet.

You now know exactly what to do.

Every complaint you file shines a light into their dark corner. It protects you AND the next person they would target.

Your rights only have power if you use them.

So take that folder of evidence. Write your complaint. And hit “submit” at fccpc.gov.ng.

Do it today.