August 2025 - Adedeji Olowe

Consumer protection should not be weaponized

Borrowers need protection, but rules shouldn’t be a free pass to dodge responsibility. Digital lenders stepped in where banks wouldn’t, and if protections only favor borrowers without accountability, the people who actually rely on credit end up losing out.

I have no problem with consumer protection. In fact, it’s something I’ve been waiting to see for years in Nigeria and across other African countries. For the longest time, the lending industry here has been like the Wild West, with very little in the way of rules or safeguards for ordinary people. Kenya was one of the first to put clear regulations in place for digital lending, introducing the Digital Credit Providers Regulations in 2022, which set standards for licensing, fees, and borrower rights. So when Nigeria’s FCCPC rolled out its new law on lending practices, I genuinely felt some relief. It finally looked like someone was stepping in to bring order to the chaos and give borrowers the confidence that they weren’t completely on their own. And if you know anything about how Nigeria works, you’ll understand why this feels like such a big deal. We’re used to institutions looking the other way when it comes to the struggles of everyday people, so seeing a regulator actively plant itself in the corner of borrowers deserves some credit. The FCCPC earned its applause on that one.

But once the excitement settled, I had to pause and really think about what this all means in practice. I’ve spent enough time in this space to know that even the best-intentioned laws can take on a life of their own. Protecting borrowers makes sense, and there’s no debate about whether it is necessary, but the way people actually use those protections is where things start to get murky. What I’ve started to notice is a creeping attitude among some borrowers that these rules are now a shield to hide behind, almost like a get-out-of-jail-free card. Instead of seeing consumer protection as a safety net against abuse, some are treating it as a licence to misbehave. And to be clear, I’m not speculating here, I’ve seen it happening already.

This is the part that worries me, because once people realise that the system tilts heavily in their favour, the temptation to game it becomes too strong. Borrowers start defaulting with a straight face, brushing off their obligations as if the law has given them cover. They conveniently forget that every unpaid loan doesn’t just hurt a lender; it also makes credit harder and more expensive for everyone else who might genuinely need it. That’s the danger of a one-sided protection model. It begins with noble intentions, but if left unchecked, it ends with a broken system that serves no one well.

Africa is catching up on consumer protection finally

Nigeria is not the only country waking up to this conversation. Across the continent, regulators are starting to take a harder look at how lending works and what protections borrowers deserve. In Kenya, for example, the Central Bank of Kenya amended its regulations in 2021 to bring digital lenders under direct supervision, requiring them to disclose all fees upfront and banning the practice of debt shaming. South Africa has had its National Credit Act since 2005, which created the National Credit Regulator and set rules around affordability checks, fair interest rates, and even the right for borrowers to challenge unfair credit agreements. Ghana recently passed the Borrowers and Lenders Act in 2020, which established a legal framework for credit agreements and gave the Bank of Ghana authority to license and monitor lenders. Even in Tanzania and Uganda, where digital credit is newer, you now see requirements for lenders to register with central banks and follow rules on interest disclosures. For a region that has historically left borrowers at the mercy of whoever had the cash, this growing wave of credit-specific protections is a real shift, and it is encouraging to see it spreading.

Where the challenge begins, however, is in how these protections are interpreted once they leave the pages of regulation and meet real people on the ground. On paper, the goal is simple: defend borrowers from exploitation. Regulators are standing up and saying, “You will not be cheated, harassed, or bullied when you borrow money.” That is a noble and necessary message. But human behaviour is never that straightforward. Once borrowers realise that there is now a safety net that can shield them, some start to test the limits. I have personally seen situations where people take loans with no serious plan to repay, and when the lender comes knocking, the borrower boldly leans on the regulator’s rules as cover. Loan obligations suddenly become optional, something to get around if possible, since the law is assumed to be firmly on their side.

This is where I start to get uneasy, because protections that were designed to restore fairness can easily turn into weapons for irresponsibility. When borrowers begin to act like regulators are there to punish lenders on their behalf, the balance of the system gets lost. The slope is gradual but very real: a few defaults ignored here, some abuse of the rules there, and before long, borrowing culture itself becomes toxic. If this trend continues, it will not just be lenders who suffer. The very people these laws are meant to protect will find that credit dries up, because no one is willing to take the risk anymore.

Borrowers aren’t always the saints in this story

The uncomfortable truth is that many of the ugly practices we see in lending did not just appear out of thin air. When a lender blasts someone’s contact list or sends threatening messages to their relatives, as crude and damaging as those actions are, they usually stem from a borrower who has refused to repay what they owe. I am not excusing those tactics in any way, because they harm the industry, destroy trust, and ultimately push regulators to come down harder on everyone. But if we are going to have a serious conversation about consumer protection, we cannot skip over the fact that a huge number of these conflicts begin with a loan that was never repaid.

Yes, there are absolutely lenders who operate in bad faith. Some deliberately sneak in hidden fees, inflate interest rates, or design repayment schedules that they know will trip up the borrower. Those businesses are exploitative, and they deserve the scrutiny regulators throw at them. But focusing only on bad lenders tells only half the story. There is another reality, one that regulators rarely talk about: borrowers who collect loans with no genuine plan to pay back. Over the years and even more recently than you’d think, i’ve come across borrowers who take out multiple loans from different digital platforms in the same week, juggling them as if it were free cash. Some default the moment the funds hit their account, knowing that recovery is messy and regulators will step in if the lender pushes too hard. These are not isolated cases, they are patterns that chips away at the very foundation of credit.

If consumer protection is to be credible, it cannot just draw lines around lenders while leaving borrowers free of responsibility. A system where only one side is accountable is already broken. Borrowers need to understand that protections are meant to shield them from abuse, not from responsibility. If you take out a loan in good faith but run into genuine hardship, then yes, you deserve protection, mediation, and even restructuring options. But if you deliberately game the system, hiding behind regulations while treating repayment as optional, you poison the pool for everyone else. What eventually happens is that lenders start pulling back, tightening requirements, or leaving the market entirely, and the very people who lose out are the honest borrowers who suddenly have fewer or no options left.

This is why I believe consumer protection has to be framed as a two-way street. Borrowers cannot keep expecting regulators to fight their battles while ignoring their own obligations. If regulators really want to build a healthy credit culture, they need to make it clear that protection is earned through good faith. Those who exploit the system should face consequences, just as much as predatory lenders do. Otherwise, we are left with a system that rewards irresponsibility and punishes those who are actually trying to do the right thing.

Why digital lenders exist in the first place

The rise of digital lenders in Africa did not come out of nowhere. It was born out of a frustrating reality that traditional banks created and then ignored. Walk into a commercial bank in Senegal and try asking for a personal loan, and you’ll quickly discover that the system was never built with ordinary people in mind. First, you face a mountain of paperwork. Then, there’s the demand for collateral that you don’t have. After that comes the long back and forth that can drag on for weeks, with no guarantee that you’ll ever get the money. And most times, after all that trouble, the final answer is still no.

This story repeats itself across the continent. In Kenya, if you need cash urgently on a Saturday evening to rush someone to the hospital, you already know the bank will not even pick up your call. In Zambia, if a medical emergency strikes on a Friday night, you’re fucked. In Senegal, when school fees are due at the end of the month, banks are not lining up to help parents meet that deadline. For small businesses, it is even worse. An SME founder trying to raise quick capital to keep operations afloat in Nigeria is simply on their own.

The only people answering in those moments were digital lenders. They built a system that actually shows up when people need money the most, whether it’s for survival, school, or business. And that is why borrowers turned to them in their millions. Using mobile phones and tech, they made credit accessible to people who had never had the chance before. SMEs could buy inventory without waiting for a loan committee. Parents could pay fees at the very last moment. Families dealing with health emergencies could find help, even at night.

And this is why the conversation around consumer protection matters so much. When regulations lean too heavily toward shielding borrowers without balancing accountability, digital lenders start asking themselves whether the risk is even worth it. Running a lending business is not charity, and when repayment becomes uncertain while rules make recovery nearly impossible, many lenders eventually leave. Regulators may celebrate wins on paper, but the people who end up stranded are the same borrowers they wanted to protect. The parent looking for school fees will have no options. The small business needing working capital will be left to plead with banks that never wanted them in the first place. That is the irony: in trying to protect borrowers, we risk cutting them off from the only credit they have ever had access to.

If I were in charge

The harsh truth we must all come to terms with is how consumer protection should never be one-sided. It cannot work if it’s built on the assumption that lenders are always the predators and borrowers are always the prey. The reality is much more complicated. Borrowers absolutely need safeguards against lenders who charge outrageous fees, hide terms, or harass people during collections.

Those practices wear down trust and make credit dangerous instead of useful. But protection also comes with responsibility. If someone takes a loan, there has to be a clear understanding that repayment is not optional. You can put all the protective barriers in place for fairness, yet the foundation of credit still rests on the borrower keeping their word and paying back what they owe.

I would even go as far as saying regulators should create a mechanism for lenders to flag habitual defaulters. If lenders can be blacklisted for bad practices, why can’t serial defaulters face the same thing? Accountability should cut both ways. Otherwise, we are just encouraging a culture of irresponsibility that eventually destroys the credit system.

Now, don’t get me wrong. If I were running the FCCPC in Nigeria, or the equivalent bodies in Kenya, Ghana, or South Africa, I’d still enforce every single protection against abuse. Nobody deserves to be bullied, humiliated, or trapped in unfair loan terms. But alongside that, I’d add a firm and practical layer of borrower accountability. That means making sure consumer protection cannot be twisted into a free pass for irresponsibility. If lenders are expected to meet clear rules and standards, borrowers should too.

Because at the end of the day, the role of a regulator is to keep the system fair for both borrowers and lenders, not to tilt everything in favor of one side. Lenders will only continue to lend when there is confidence that what goes out will come back. And that requires telling borrowers, in no uncertain terms, that protection is available, but it comes with responsibility. If you take a loan, you must be ready to pay back.

A case for virtual phone numbers

Handing out your main phone number is like giving strangers a key to your front door. A virtual number fixes that; keeping you reachable without putting your primary line on the chopping block. This is my pitch to telcos to make it happen.

I’m not sure if it’s just me, but I’ve noticed that the moment someone asks for my phone number, I begin to calculate the cost of giving it out. And, no I am not referring to financial cost, but rather the mental and emotional burden that can follow. I have to consider whether sharing it will expose me to calls that arrive when I am in the middle of important work or during moments when I simply cannot be interrupted. I also have to weigh the possibility that it could mark the beginning of another round of those familiar “We’re calling from your bank” scams. This is not a matter of paranoia; I have seen how quickly a single phone number, once it reaches the wrong people, can turn into a constant stream of unsolicited calls and messages, with no easy way to stop them.

That is not to say I am overly protective about my number to the point where I never share it. My phone can handle two SIM cards, and it even supports eSIMs. The problem is that adding more lines inevitably increases the complexity of managing them. Keeping track of which SIM is for work, which is for family, and which is for online transactions is like carrying several keys that all look similar but open different doors. Over time, this becomes difficult to manage consistently, and from the conversations I have had with friends and colleagues, it is clear that I am not the only one who feels this way.

What makes this more frustrating is that the problem is not a new one. In the banking sector, a similar issue has already been addressed with the introduction of virtual accounts. The concept has been tested, proven, and widely adopted in many markets. Customers can now receive payments without exposing their primary account numbers, simply by using virtual accounts that can be created and deactivated at will. There is no reason why the same idea could not be applied in telecommunications. If telcos could move away from the narrow view that their role is limited to selling airtime and data, they could open the door to an entirely new way of managing personal and professional contact points. The opportunity to rethink how people manage their numbers has been there for years, and yet it remains untouched.

The lesson telcos could learn from virtual bank accounts

Let’s take a moment to really look at how virtual accounts function in banking. If you have a bank account, you have probably been told more than once to be careful about where and how you share your account number. The reasoning behind this is straightforward: once that number is widely circulated, you lose control over who has it and what they might attempt to do with it. Despite the need for caution, there will always be situations where you have to provide an account number so that someone can transfer money to you. This is the gap that virtual accounts were created to fill, offering a safe, alternative channel for receiving funds without directly exposing the number of your actual account.

When a bank sets up a virtual account for you, it assigns you a secondary account number that is linked to your main account. Any payment sent to this virtual account is deposited into your real account, but the sender never sees the actual number behind it. The advantage is that you can generate multiple virtual accounts and dedicate each one to a particular purpose. You might have one that you use exclusively for business transactions, another for family and personal matters, one for online purchases, and perhaps another for a side project that you want to keep separate from everything else. If at any point one of these numbers is compromised or begins attracting unwanted activity, you can deactivate it without affecting the integrity or operation of your main account.

This arrangement is both practical and effective because it allows the account holder to maintain control over how their details are distributed and who has access to them. It is for this reason that I find it surprising that telecommunications companies have not adapted the same idea for phone numbers. The principle is almost identical: one primary number that stays private, supported by multiple virtual numbers that you can hand out for specific purposes. If banks have been able to make this work for money, it is hard to see why telcos cannot make it work for calls and messages.

What a virtual phone number could look like in real life

Imagine walking into a telco office and going through the same verification process they use for regular lines. You would present your NIN in Nigeria, National ID in Kenya, DNI in Argentina and the list goes on. You could also be asked to present your passport, or whatever other forms of identification required, and in some places like Dubai, the process would be far more extensive and thorough. The difference is that instead of leaving with a physical SIM card or activating an eSIM, you would be assigned a phone number that exists entirely in the cloud.

This virtual number would not take up a SIM slot on your phone or require you to manage an eSIM profile. It would function purely as a forwarding number, routing calls and text messages directly to your main line. For example, I could obtain an Airtel virtual number, link it to my existing MTN line, and then decide that only a specific group of people would have access to that number. This setup would allow me to keep my primary number private while still being reachable on a dedicated line for certain contacts.

I could choose to have one virtual number strictly for family and close friends, another for professional use, and a third that I give out when registering on questionable e-commerce websites that advertise unrealistic discounts but rarely deliver on their promises. By assigning each virtual number to a specific purpose, I would always know where it was shared and who might be responsible if it was ever misused. If unwanted calls started coming through on one of those numbers, there would be no need for guesswork, no endless speculation, and no playing detective trying to figure out who leaked my number. The source would be clear, and I could simply deactivate that virtual number while keeping my main line unaffected.

Why this could be a win-win for everyone

The most immediate benefit would be for individuals like me who are tired of juggling multiple devices or SIM cards just to manage different aspects of our lives. A virtual phone number would make it possible to keep personal and work communications completely separate without physically carrying two phones or constantly swapping SIM cards. Travelling abroad would also be much easier, since I could keep my local virtual number active and simply have it forward calls to my foreign line. This means staying reachable to people at home without the inconvenience and expense of roaming or the hassle of maintaining multiple physical SIMs.

From the perspective of the telcos, the revenue potential is hard to ignore. Every forwarded call or text message generates activity on the network that can be billed. This allows telcos to earn money even when they are not the primary service provider for a customer’s main line. Just as banks make money from operating multiple virtual accounts without having to build more branches or expand their physical infrastructure, telcos could grow their earnings from virtual numbers without the cost of installing new towers or expanding coverage areas. The business model is straightforward, and the financial upside is clear.

Friends and family would also benefit from this arrangement. They would have the assurance that when they call the virtual number assigned to them, they are contacting a line dedicated to their relationship with you. They would not have to worry about their calls competing with unsolicited marketing calls or random strangers who somehow managed to get hold of your number. This creates a more direct and reliable communication channel, which works well for everyone involved.

The identity and security side of it

Some people will immediately raise concerns about fraud, as if fraudulent activity is exclusive to virtual numbers and not already a challenge with regular numbers. The reality is that the level of identity risk would be no greater than what exists today with standard SIM cards. Minimum KYC requirements would still be in place, and the same checks you already perform for traditional lines would apply to virtual numbers. Whether it is verifying a National Identification Number (NIN) in Nigeria, a Rwandan National ID, or a Colombian Cédula, the process for confirming identity would not change. In countries where passports or residency permits are the primary verification documents, those same procedures would continue to apply for virtual numbers. There would be no lowering of the bar for security or verification.

The real difference lies in the nature of the number itself. A virtual number is not tied to your entire communication ecosystem in the same rigid way a permanent line is. It is designed to be functionally disposable, which means that if it is ever compromised or begins to attract unwanted calls and messages, you can deactivate it without creating a chain reaction of disruption in your life. You can set up a new one quickly, update only the relevant parties, and move on. This is significantly easier than replacing your primary line, which often comes with the risk of losing access to two-factor authentication codes, interrupting business communication channels, missing important calls, or forcing you to notify a long list of personal and professional contacts.

And let’s not forget the diaspora

For people living abroad who still want to maintain a phone number back home, this option could be financially practical and far more convenient. Instead of paying the often high costs of roaming or struggling to keep a local SIM card active from thousands of miles away, you could simply retain a virtual number linked to your home country. All calls and messages to that number would be forwarded directly to your current foreign line, removing the need for multiple devices or complicated SIM card swaps.

Allowing your local caller to pay local rates ensures that people back home can reach you without worrying about expensive international tariffs. At the same time, telecommunication companies would still generate revenue from the international forwarding charges, while you maintain consistent accessibility to friends, family, and business contacts at home. This setup also avoids the awkward “this number is not reachable” message for callers in your home country, which can create the impression that you’ve disconnected or become difficult to reach. In this way, both sides benefit: the telcos keep a steady revenue stream, and you remain reliably connected.

So, telcos, what’s the hold-up?

The infrastructure for this kind of service already exists, and the demand for it is undeniable. Customers are constantly looking for ways to share contact details without exposing themselves to unnecessary risks, and the potential for revenue is clear to anyone paying attention. Yet, in 2025, we are still in a situation where people have to give their primary numbers to almost anyone who asks, from the mechanic fixing their car to strangers selling products online.

If banks could figure out virtual accounts years ago, telcos have no excuse. The banking industry has already shown that it is possible to roll out such a system in a way that balances customer convenience with strong fraud controls. Banking regulators require that virtual accounts be linked to a primary account, and they enforce KYC rules to verify identity, monitor suspicious transactions, and block bad actors. These measures have kept the system from becoming a free-for-all while allowing millions of customers to enjoy the flexibility of using dedicated account numbers for different purposes without risking their main account.

Telecom regulators could take a page from that playbook. They could require that every virtual phone number be tied to a verified SIM registration, with similar monitoring for misuse. Just as banks flag suspicious transfers, telcos could flag patterns of spam or fraudulent calls and shut them down quickly. The technology to monitor call patterns and message volumes already exists, and so does the regulatory framework to make it work without stifling innovation.

If the existing players are unwilling or unable to make this a reality, then perhaps the market is ready for a new entrant that is willing to act. Customers will naturally gravitate towards providers who understand their needs and are prepared to innovate in ways that make communication safer and more convenient.

Until that happens, I will keep hoping for the day I can share my phone number without also compromising my peace of mind.