Nigeria has a pattern. A government agency identifies a genuine problem, designs a policy response, and deploys it at national scale without conducting a serious assessment of the cost to the people it affects. The stated intention is almost always defensible. The execution is almost always devastating. And the Nigerians who absorb the consequences are almost always the ones furthest from the room where the policy was made.

The FCCPC’s enforcement of its DEON Consumer Lending Regulations against telecom airtime credit services is the latest iteration. The disruption it caused, six weeks of suspended services affecting an estimated 40 million users, was significant. But it is the pattern itself that should concern Nigerians more than any single episode, because the institutional tool designed to break it keeps being ignored.

That tool is the Regulatory Impact Assessment framework administered by the Presidential Enabling Business Environment Council (PEBEC). PEBEC’s mandate is straightforward: before a regulatory change of significant consequence is implemented, the sponsoring agency should assess its likely economic impact, identify who bears the cost, evaluate whether less disruptive alternatives exist, and publish its analysis for scrutiny.

The framework exists precisely to prevent the scenario that played out with DEON: a regulation designed for one problem (predatory digital lending) being applied to a different product (telecom airtime credit), with no published analysis of the impact of removing the second product from the market on the tens of millions of people who used it daily.

On 6 April 2026, PEBEC’s Director-General, Zahrah Mustapha-Audu, directed all ministries, departments, and agencies to suspend regulatory changes not grounded in the RIA framework. The FCCPC’s enforcement directive had arrived four days earlier. Whether the timing was coincidental or responsive, the directive confirmed what should have been obvious: significant regulatory interventions require prior assessment, and agencies that skip that step create exactly the kind of market disruption PEBEC was established to prevent.

Nigerians do not need to look far for precedent. The Naira redesign policy of late 2022 and early 2023 followed the same trajectory, but with far greater severity. The Central Bank announced the withdrawal of the existing N200, N500, and N1,000 banknotes, setting a compliance deadline that left the banking system insufficient time to distribute replacements and Nigerians insufficient time to exchange their holdings. 

The stated rationale was legitimate: combating counterfeiting and accelerating the transition to digital payments. The result was a currency crisis that paralysed the informal economy for months. Markets shut down. Nigerians queued for hours at banks and ATMs, and some died in the process. The Supreme Court eventually ruled the implementation unconstitutional. By then, the damage had already been absorbed by the people least equipped to withstand it. No credible regulatory impact assessment preceded any of it.

The Twitter suspension in June 2021 followed a similar pattern: seven months of blocked access, at an estimated cost exceeding $1.5 billion, borne disproportionately by businesses and creators who used the platform as a commercial channel. No impact assessment examined the cost to the digital economy before the suspension was imposed.

The DEON enforcement is smaller in scale than the Naira redesign and narrower in scope than the Twitter suspension, but it belongs to the same category: a regulatory intervention deployed without prior assessment of its economic consequences, with costs that fell disproportionately on the most vulnerable participants in the economy.

PEBEC’s RIA framework is designed to break this cycle. It requires agencies to think before they regulate: to quantify the cost, identify who bears it, consider alternatives, and publish their reasoning before enforcement begins. The Renewed Hope Agenda’s credibility as an economic programme depends, in part, on whether the government’s own agencies will submit to the disciplines it has established.

If PEBEC remains advisory rather than binding and agencies can bypass the RIA process without consequence, the framework exists only on paper, and the pattern will continue: good intentions, absent assessment, disproportionate harm, and a repair bill that ordinary Nigerians pay while policymakers move on.

Alice Asaju has spent over a decade researching the impact of government policy on vulnerable Nigerians; she writes from Osun State.