INTRODUCTION
In furtherance of the implementation of the Nigerian Electricity Regulatory Commission (“NERC”)’s Order No. NERC/183/2019, which mandates the migration of Industrial, Commercial and R3 (now Maximum Demand Residential) customers to cashless payment platforms and registration of collection agents and service providers in order to reduce collection losses within the Nigerian Electricity Supply Industry (“NESI”), NERC issued the Guidelines on the Registration and Engagement of Third‑Party Collection Service Providers (the “Guidelines”) on May 27, 2025.

The Guidelines introduces a clear framework for the engagement of Third‑party Collection Service Providers (“CSPs”) by
Distribution Companies (“DisCos”) and the registration of CSPs with NERC. CSPs are agents engaged by DisCos to facilitate billing and payment collection from the sale of electricity to non‑Maximum Demand end‑users. These include Super Agents, Sub‑Agents, Payment Solution Service Providers, and Payment Terminal Service Providers.

In this Newsletter, we examine the key highlights of the Guidelines as well as implications for relevant stakeholders.