As Nigeria’s regulatory battle over airtime lending heads toward a potentially precedent-setting court judgment on July 20, industry stakeholders are increasingly drawing attention to a critical but largely overlooked issue at the heart of the controversy: who bears the risk when millions of subscribers take airtime advances and fail to repay?

For years, airtime and data advances have evolved from a simple telecom convenience into one of Nigeria’s largest digital micro-credit ecosystems. Every day, millions of subscribers rely on emergency airtime and data services to stay connected for work, business, navigation, emergencies, and routine communication.

The scale is significant. According to figures cited by the Association of Licensed Telecommunications Operators of Nigeria (ALTON), the airtime credit ecosystem is valued at between ₦300 billion and ₦400 billion annually and serves an estimated 40 million subscribers nationwide.

While public discourse has largely focused on the legal dispute between the Federal Competition and Consumer Protection Commission (FCCPC) and telecommunications stakeholders over the classification of airtime lending services, industry experts say the more important question lies beneath the surface: how is the enormous credit risk generated by millions of airtime loans managed?

That question has become increasingly relevant following the temporary suspension of airtime lending services in April after directives linked to the FCCPC’s Digital Economy and Online Consumer Lending (DEON) Regulations. 

Although services have since resumed under an interim arrangement, the dispute remains before the Federal High Court in Lagos, where Justice Ambrose Lewis-Allagoa is expected to deliver judgment on July 20 in a suit filed by the Wireless Application Service Providers Association of Nigeria (WASPAN).

At the centre of the case is a jurisdictional debate. The FCCPC maintains that airtime advances are effectively consumer-credit products and should therefore fall within its regulatory framework. Telecommunications operators and value-added service providers, however, argue that airtime lending remains a telecommunications value-added service under the oversight of the Nigerian Communications Commission (NCC).

Yet beyond the legal arguments lies a complex financial infrastructure that makes airtime lending possible.

Unlike banks and traditional lenders, mobile network operators were never designed to function as credit institutions. Their business model is built on prepaid payments, where subscribers pay before consuming services. 

Extending millions of small-value advances daily would expose operators to significant bad-debt risks and create collection challenges that could quickly overwhelm telecom balance sheets.

To solve that problem, the industry developed a specialised risk-transfer model involving technology providers, credit-scoring platforms, payment infrastructure companies and banking partners.

Read also: Airtel Nigeria donates phones, SIMS, airtime to South Africa returnees

One of the most prominent players in that ecosystem is Nairtime Nigeria Limited, a Nigerian subsidiary of global fintech and financial infrastructure group Optasia. Nairtime has worked with telecommunications operators for more than a decade, powering platforms such as XtraTime and using proprietary analytics and credit-scoring systems to assess subscriber eligibility for airtime advances.

However, industry participants say the company’s most important role extends beyond technology.

Under the commercial arrangements that underpin many airtime lending platforms, specialised providers such as Nairtime assume responsibility for managing and underwriting subscriber default risk. If a subscriber fails to repay an airtime advance within the agreed recovery period, the risk partner absorbs the loss, shielding the telecom operator from direct bad-debt exposure.

“The real issue is not who provides the software,” said a telecom finance analyst familiar with the sector, adding”The key issue is who takes the hit when millions of subscribers default. That is where the actual financial risk resides.”

This credit-guarantee structure has enabled telecom operators to offer airtime advances without fundamentally altering their prepaid business model. By transferring default risk to specialised partners, operators can improve customer retention and grow average revenue per user without carrying large volumes of unsecured consumer debt.

The system is also more deeply connected to Nigeria’s financial sector than many consumers realise.

Industry stakeholders note that airtime-credit providers rely on liquidity facilities, invoice discounting arrangements and other funding structures sourced from Nigerian commercial banks to support the advances extended to subscribers. These financing arrangements ensure that the capital required to fund millions of micro-transactions remains available throughout the system.

The ecosystem extends further still.

Payment infrastructure providers such as Interswitch form part of the broader digital-finance architecture that enables the seamless movement of funds, settlements and transaction processing across the industry. 

Optasia publicly identifies Interswitch among its strategic partners, highlighting the interconnected relationship between telecommunications networks, payment systems and digital-credit infrastructure.

Together, these relationships reveal that airtime lending is far more than a simple telecom service. Behind every ₦100 or ₦500 emergency airtime advance sits a chain of infrastructure involving mobile operators, risk-management platforms, payment processors, financial institutions and credit-guarantee providers.

This complexity is one reason why stakeholders are paying close attention to discussions around the potential entry of new players into the market.

In June, reports emerged claiming that nine local fintech companies had received approval to participate in the airtime-credit sector, citing a market valuation of approximately ₦3 trillion. The FCCPC subsequently denied involvement in any such approvals and clarified that the regulatory framework under which the firms were reportedly approved remains suspended pending the court’s determination.

Industry groups also questioned the valuation figures, pointing to audited telecom data indicating that the market is worth between ₦300 billion and ₦400 billion annually.

The debate nevertheless raised broader questions about the financial capacity required to operate successfully in the airtime-credit business.

Analysts note that airtime lending is highly capital-intensive despite the relatively small size of individual advances. Providers must maintain sufficient liquidity to fund loans, sophisticated analytics to manage credit risk, and adequate reserves to absorb defaults.

The challenge is particularly evident in emerging markets where economic pressures can significantly affect repayment behaviour. 

Optasia’s global financial disclosures have shown that expected credit-loss provisions increased substantially in recent years, underscoring the scale of the default risks associated with digital micro-credit operations.

Industry stakeholders have expressed concerns about the importance of adequate capitalization and liquidity support for any operator participating in the airtime-credit market.

Should a provider struggle to honour credit guarantees or maintain liquidity, telecom operators could become exposed to losses they were never designed to carry observers say. Faced with that risk, operators may tighten eligibility criteria, reduce lending volumes or restrict access to emergency airtime services altogether.

Such outcomes would be particularly significant for low-income subscribers, who constitute a large portion of airtime-credit users and often depend on the service as a short-term financial buffer.

As the July 20 court date approaches, the debate continues to centre on consumer protection, competition and regulatory jurisdiction.

Yet industry experts say the future of airtime lending may ultimately depend on something less visible but equally important: preserving the financial plumbing that keeps the system functioning.

For regulators, operators and investors alike, the challenge is finding a balance between consumer safeguards and financial sustainability. 

While transparency, privacy protection and fair pricing remain essential objectives, the credit guarantees, liquidity arrangements and risk-management structures that underpin airtime lending are equally critical.

After all, every airtime loan begins as a simple request from a subscriber. What remains largely unseen is the intricate network of companies and capital standing behind it, absorbing billions of naira in risk to keep millions of Nigerians connected.

MONSURUDEEN OLOWOOPEJO is a journalist based in Lagos State, writing to educate the public.

Join BusinessDay whatsapp Channel, to stay up to date

Open In Whatsapp