NIGERIA Trends and Developments Contributed by: Chiagozie Hilary-Nwokonko, Chukwuyere Ebere Izuogu and Priscilla Bidemi Ben-Okoh, Streamsowers & Köhn
ings, complaint handling mechanisms, compliance monitoring and treatment of digital evidence, reflect - ing the FCCPC’s increasing focus on technology-ena - bled commerce and digital consumer conduct. Similarly, the draft Authorisation, Exemption and Guid - ance Regulations introduce a more structured frame - work for obtaining exemptions or guidance in relation to agreements that may otherwise raise concerns under the FCCPA’s restrictive practices provisions. This development is particularly significant for merg - ers involving ancillary restraints, exclusivity obliga - tions, long-term supply arrangements or continuing commercial co-operation. Taken together, the exposure drafts reinforce several broader regulatory trends: • increasingly explicit conduct standards for con - sumer-facing businesses, particularly in digital markets; • greater convergence between competition law and consumer protection enforcement, especially where data practices and platform conduct affect user choice and market access; and • higher expectations regarding remedies, compli - ance systems and post-transaction monitoring. The accompanying guidance notes further indicate the FCCPC’s intention to provide greater interpre - tive clarity in emerging digital and technology-driven markets. Although the practical impact will ultimately depend on the final form of the legislation and future enforcement practice, the drafts provide a useful indi - cation of the FCCPC’s evolving regulatory priorities, namely transparency, accountability and consumer welfare in increasingly data-intensive markets. From a policy perspective, the significance of these developments lies in the fact that competition regula - tion, consumer protection and digital governance are increasingly operating as interconnected regulatory objectives rather than isolated legal silos. Federal and State Co-Ordination: FCCPC– LASCOPA Co-Operation In April 2026, it was reported that the FCCPC and the Lagos State Consumer Protection Agency (LASCOPA)
entered into a memorandum of understanding aimed at strengthening co-operation in consumer protection enforcement within Lagos State, including information sharing, complaint referrals and co-ordinated inter - ventions. Although the arrangement is not merger specific, it is significant for consumer-facing transactions because state level consumer complaints and market conduct concerns may increasingly inform or escalate into broader federal regulatory scrutiny. The broader policy implication is that transaction parties may increasingly need to treat regulatory mapping as extending beyond federal competition approval alone. Consumer-facing businesses may become exposed to a more layered regulatory environment involving federal regulators, sector regulators, state agencies and data protection authorities. The increasing overlap between competition regula - tion, consumer protection and sector-specific over - sight also raises broader questions concerning regu - latory co-ordination, procedural consistency and the management of parallel oversight mandates. How these institutional boundaries evolve may become one of the defining issues in the next phase of Nigerian competition law development. Consumer Protection Oversight in Financial Services The Federal High Court (Abuja Division) dismissed a challenge brought by United Bank for Africa Plc and affirmed that the FCCPC may receive and investigate consumer complaints involving banks and financial institutions in appropriate circumstances. Although the decision does not displace the Central Bank of Nigeria (CBN) as the primary financial sector regula - tor, nor conclusively resolve questions concerning the allocation of competition and merger control powers under BOFIA, it nevertheless reinforces the likelihood of overlapping consumer protection oversight within the financial services sector. For transactions involving banks, fintechs, payment service providers and embedded finance business - es, the decision highlights the growing importance of diligence concerning consumer complaints, pricing practices, refunds, dispute resolution mechanisms
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