The classification logic that shut down airtime credit for 40 million Nigerians can be applied to any value-added service involving deferred payment. Operators across the sector are asking whether their products could be next.
When the Federal Competition and Consumer Protection Commission (FCCPC) enforced its Digital, Electronic, Online, or Non-traditional Consumer Lending (DEON) Regulations against airtime credit in April 2026, the immediate fallout was the suspension of services by MTN, Airtel, Glo, and 9mobile. Approximately 40 million Nigerians lost access to products like XtraTime and Borrow Me Credit. An airtime credit market estimated at N300-N400 billion annually froze overnight.
But the disruption to airtime credit may only be the surface of a larger problem. The FCCPC's intervention rested on a classification decision: any arrangement in which a consumer receives value now and payment is collected later qualifies as lending. The FCCPC applied that test to airtime credit, a product licensed and regulated by the Nigerian Communications Commission (NCC) as a telecom service. The question now facing the industry is what else it applies to.
The answer covers more ground than most observers have considered. Nigeria's value-added services sector is one of the largest and fastest-growing segments of its telecommunications industry. The NCC itself projected the market at $500 million, and the ecosystem now encompasses over 200 licensed companies operating across mobile financial services, USSD-based applications, enterprise messaging, mobile insurance, transactional services, and mobile banking. All operate under the NCC's Value-Added Services and Aggregator Framework of 2018, which is governed by the Nigerian Communications Act of 2003.
The DEON classification introduces a parallel claim. Data bundles with rollover features allow a subscriber to receive value that carries over. Postpaid arrangements are services in which the subscriber uses the product before payment is collected. Mobile insurance sold through telecom platforms involves coverage in exchange for periodic deductions. Enterprise messaging with deferred billing operates on credit terms. In each case, the consumer receives value and pays later. The FCCPC may not move on all of these categories tomorrow. But the precedent has been set, and for the over 200 companies licensed by the NCC, the question of whether their products could be reclassified is no longer hypothetical. It has already happened once.
The VAS industry knows what regulatory disruption costs. When the NCC tightened VAS subscription rules in 2016 and 2018, Simon Aderinola of the Wireless Application Service Providers Association of Nigeria (WASPAN) estimated that 70% to 80% of monthly gross VAS revenue was lost. But that contraction happened within a single regulatory framework administered by a single regulator. What the DEON enforcement introduces is fundamentally different: a second framework, from a different agency, claiming concurrent authority over the same products.
The legal situation has also compounded the concern. Two Federal High Courts have issued orders in the dispute: a Lagos court restrained the FCCPC from enforcing DEON on 15 April, and an Abuja court issued a separate order on 24 April. The FCCPC sought to have the Lagos injunction discharged on 28 April, but the court refused. Despite both orders, services remain suspended. WASPAN's Osa Umweni noted publicly that the FCCPC approved five previously unknown companies to operate as licensed airtime lenders under the DEON framework on 22 April, seven days after the court had restrained the FCCPC from enforcing those same regulations. None of the five has launched operational services.
For the wider VAS industry, the concern is not the litigation itself but what it signals about regulatory predictability. Any operator considering a product involving credit, deferred billing, or post-consumption payment must now factor in the possibility that the FCCPC could claim jurisdiction regardless of an existing NCC licence. Gbenga Adebayo, chairman of the Association of Licensed Telecommunications Operators of Nigeria (ALTON), has warned that the situation represents a test of whether the structures that underpin business confidence in this country are functioning as they should.
If the jurisdictional boundary between the NCC and the FCCPC is unclear on airtime credit, it is unclear on every product at the intersection of telecommunications and financial services, precisely where growth in Nigeria's digital economy is concentrated. The underlying problem is structural. Both agencies operate under legitimate mandates: the NCC under the Nigerian Communications Act of 2003, the FCCPC under the Federal Competition and Consumer Protection Act of 2018. But when those mandates converge, as they inevitably do in a sector where telecoms and financial services are merging, there is no coordination protocol for determining which agency leads. Kenya solved this between its Central Bank and Communications Authority. The EU addressed it in its electronic communications regulations. Nigeria has not, and that gap is now costing 40 million consumers their access, an industry its ability to plan, and an economy the investor confidence it is actively courting.
The question is no longer whether the DEON classification of airtime credit was right or wrong. That is before the courts. The question is whether a regulation designed to address predatory loan apps has set a precedent that could reshape the regulatory landscape for every value-added service in Nigerian telecommunications. For an industry valued at half a billion dollars, the answer matters.
