A Tuesday Afternoon in Lagos;

Ada, a fictional Lagos shopper, orders a laptop from an online store. She tells the seller she needs it for graphic design work. When it arrives, it stutters on the simplest design software. She asks for a refund and is told to read the “No Refund” line in the terms and conditions.

Ada assumes she has lost. Under Nigerian law, she probably hasn’t.

The Law That Sits Behind Every Receipt

The main statute is the Federal Competition and Consumer Protection Act 2018 (FCCPA), which the Federal Competition and Consumer Protection Commission (FCCPC) enforces. Section 122 is the key provision for Ada. A consumer is entitled to a full refund where goods supplied for a purpose known to the supplier turn out to be unsuitable for it. The same applies where the buyer could not inspect the goods beforehand and rejects them within a reasonable time because they do not match the agreed description, sample or expected quality.

The seller’s “No Refund” sign matters less than it seems. Section 127 prevents businesses from enforcing terms that are manifestly unfair, unreasonable or unjust, and section 129 makes it illegal to include terms that waive or limit a consumer’s rights under the Act. In other words, a seller cannot contract out of your statutory rights with a sentence in fine print.

This is not only theory. In Anene v. MTN (Nig.) Comm. Plc (2025) 16 NWLR (Pt. 2010) 1, the Supreme Court held a “no refund of money after payment” policy illegal, null and void under the FCCPA, 2018. The court on what constitutes consumer rights explained that a consumer has the right to return goods. The older Sale of Goods Act also helps: it carries implied conditions that goods must be reasonably fit for their purpose and of merchantable quality.

The Act covers services too. A consumer has a right to timely, quality performance of a service, and if the provider falls short, the consumer can have defects remedied and a refund of a reasonable portion of the price.

When the Money Vanishes: Fintech and Bank Transfers

Later that week, Ada pays for a course through her banking app. Her account is debited, but the course platform says no payment was received. Her money is in limbo.

The Central Bank of Nigeria (CBN) set clear deadlines for this. Since June 8, 2020, failed transactions on a customer’s own bank’s ATM must be reversed instantly, or within 24 hours if there is a technical glitch, and refunds for failed transactions on another bank’s ATM must not exceed 48 hours. For Ada’s situation, disputed or failed POS or web transactions must be resolved within 72 hours.

The Loan App That Wouldn’t Stop Calling

Ada’s cousin Emeka has a different problem. He borrowed a small amount from a loan app, and now the app has messaged everyone in his phone contacts.

The government moved against this kind of conduct with the FCCPC’s Digital, Electronic, Online or Non-Traditional Consumer Lending Regulations, 2025 (the “DEON Regulations”). They came into force on 21 July 2025 and were issued under the FCCPA. They prohibit pre-authorized or automatic lending, require clear and accessible loan terms, and ban unethical marketing. Penalties could reach ₦100 million or 1% of turnover, with directors potentially disqualified for up to five years.

There is an important update. This is a fast-moving area, and Emeka should not assume the rules are being fully enforced. In Wireless Application Service Providers Association of Nigeria (WASPAN) v. FCCPC- Suit No. FHC/L/CS/760/2026, Justice Ambrose Lewis-Allagoa of the Federal High Court in Lagos temporarily stopped the FCCPC from enforcing key provisions, listing paragraphs 3, 7, 10, 12, 13, 14, 15, 16, 24, 27, 29 and 32. The FCCPC said in a May 22 notice that it had suspended enforcement. In a June 28, 2026 statement, it said it was complying with the order and had granted no new approvals under the regulations.

Emeka is not without protection in the meantime. The Nigeria Data Protection Act still applies, and the regulator has shifted from policy-making toward enforcement, with the implementation directive taking full effect on 19 September 2025. In Amadi v. Okash (Suit No. FHC/ABJ/CS/1563/2024), the Federal High Court in Abuja found that a loan provider’s relentless unsolicited automated calls violated the constitutional right to privacy, granted a perpetual injunction, and ordered a formal apology within 14 days. The court also confirmed that administrative remedies under the Data Protection Act do not bar direct court action. Contacting people in a borrower’s phone book without consent raises similar privacy questions

A Quick Checklist for Every Nigerian Consumer

• Before buying: Tell the seller in writing what you need the item for, and save the advert.
• On delivery: Inspect the item and report faults promptly.
• Blanket “no refund” signs: Do not accept them where the item is defective or not as described, but don’t assume they never apply to a simple change of mind.
• For fintech: Screenshot everything, note the time, and complain in writing the same day.
• For loan apps: Read the terms, check whether the lender is approved, and report harassment.
• Escalate: Go to the company first, then the FCCPC for goods and services or the CBN for banking issues.

Sources

• Federal Competition and Consumer Protection Act 2018, ss. 122, 127, 129
• CBN Press Release, “CBN Revises Timelines for Dispense Errors, Refund Complaints” (1 June 2020)
• FCCPC DEON Consumer Lending Regulations 2025
• Guardian Nigeria, AllAfrica, TechCabal and Nairametrics reports on the court order and FCCPC’s response (April to June 2026)
• TechHive Advisory, “Nigeria: A 2025 Retrospective and 2026 Outlook” (data protection)

 

The opinions in the articles are for general information purposes only and do not form a legal relationship or be taken as legal advice. To explore legal advice, please consult your solicitor or feel free to get in touch with us directly.