Quoting full trip prices in Nigeria under the FCCPA
What a Nigerian travel agency must disclose when quoting a trip price under the FCCPA, where NANTA fits, and how an itemised invoice serves as the record.
By Achekam · · 5 min read · For Travel businesses in Nigeria
An advert on an agency's Instagram page offers a Dubai package "from" a tempting naira figure. A traveller in Port Harcourt messages to book, and the quote that comes back is noticeably higher: airport taxes, a visa fee, the agency's service charge and an exchange-rate adjustment have all been added. The traveller feels misled, and under Nigeria's consumer protection law, the traveller may have a point.
Nigeria's Federal Competition and Consumer Protection Act (FCCPA) sets out what businesses must tell consumers, and how. For a travel agency, whose prices are built from fares, taxes, supplier charges and its own fees, often in foreign currency, those rules shape how every quote is written. This article walks through the FCCPA provisions the Federal Competition and Consumer Protection Commission highlights, the role of NANTA, and how to make the invoice the itemised written record the law expects.
Plain language and full disclosure
The FCCPC states that section 114 of the FCCPA requires businesses to provide information about their products and services in plain language that consumers can easily understand. It also states that section 115 requires businesses to fully disclose material facts, including prices. The FCCPC's consumer rights and responsibilities page lists these and the other rights consumers hold under Part XV of the Act.
For a trip, the material facts go well beyond the headline fare:
- what is included and what is not (meals, transfers, excursions, visa);
- the taxes and charges that will be added, such as airport taxes;
- the agency's own service fee;
- cancellation and change conditions, in words a traveller understands;
- whether the price is fixed or can change before payment, for example with the exchange rate.
The price shown must be the price paid
The FCCPC states that under section 115, displayed prices must be equivalent to the point-of-payment or cash-out price. That is the provision the Instagram advert above runs into. If the price a traveller sees in an advert, on a website or in a first quote is not the price they are asked to pay, the gap is the problem.
Practical ways to stay on the right side of it:
- Quote all-in prices. Show the total the traveller will pay, with taxes and your fee included, rather than a fare with extras added later.
- Date every quote and say how long it holds. Fares and exchange rates move; a quote that states its validity period is a fair price for that period.
- Re-quote rather than surprise. If the price changes before payment, send a new quote showing the new total before taking money.
- Check adverts. "From" prices should be prices a traveller can actually book at, with all compulsory charges included.
Trips priced in dollars and invoiced in naira raise their own questions; invoicing dollar-priced trips locally covers the currency side.
Itemised written records on request
The FCCPC states that section 118 requires businesses, except where it is impracticable, to provide written records of transactions on a consumer's request, itemising the goods or services sold and any applicable taxes. For an agency, an itemised invoice is the natural record: each component of the trip on its own line, with taxes shown.
Terms that try to exclude liability are void
The FCCPC states that section 129 makes void and of no effect any notice or agreement that purports to limit, exclude or waive a business's liability for defective performance, fraud, negligence or misrepresentation, or to waive implied obligations. Booking terms copied from elsewhere often contain sweeping clauses that say the agency is "not responsible for anything". Under section 129, a clause that tries to exclude liability for the agency's own negligence or misrepresentation has no effect, so it gives false comfort. Review your booking terms with that provision in mind; a booking terms template is a starting point to adapt with your lawyer.
NANTA's role
The National Association of Nigeria Travel Agencies describes itself as the umbrella body for all licensed travel agents and tour operators in Nigeria, with 4,000+ registered agencies across 5 zones. It lists a "First-Level Regulatory Service (Downstream Aviation)" among its functions, and says its mission rests on three pillars: Fair Play (Equity), Consumer Protection and Strengthening NANTA.
Its website offers public agency and ID-card searches, so travellers can check that an agency, and the person they are dealing with, are registered. Membership and a searchable listing are a signal to customers; NANTA's consumer-protection pillar is also a reason to expect members to follow the FCCPA principles above.
An itemised invoice as the written record
In Achekam, a business creates customer invoices as drafts it can change or delete, and issuing one takes the next number in the sequence and posts it to the ledger as debtors, sales and output VAT. Put each component of the trip on its own line: flights, accommodation, transfers, excursions, visa assistance and your service fee. A Nigerian business picks a tax code on each line (standard, zero-rated, exempt, out of scope or reverse charge), and only standard lines carry VAT, so the taxes are shown line by line. Use the invoice form under Accounting, which follows Nigeria's tax codes; the New invoice form under Billing & Finance offers only 15% or 0% VAT and shows rand.
Once issued, the invoice can be downloaded as a PDF on your letterhead and e-mailed from the invoice, with or without a pay link, and a failed send is reported as not sent. With a pay link, the traveller pays on a public page that shows your business's name and branding. A link lasts 14 days by default, and there is no link for draft or voided invoices.
Because the pay link is created from the issued, itemised invoice, the traveller pays against the same document that shows the price, which keeps the price shown and the price paid together.
Before the next campaign
Read your current adverts, quote template and booking terms side by side, and check that the price a traveller first sees is the total they will be asked to pay.
General guidance only, not advice on your own circumstances. Tax and payroll rules change: check the current position with the authority or your adviser.
