If you're unmetered and your bill jumps every month with no explanation, you're not powerless — NERC has set a legal ceiling on what your DISCO is allowed to charge you, published feeder by feeder, every single month. This guide shows you exactly where to find your specific cap and how to push back when your bill exceeds it.

Quick Answer

Your DISCO cannot legally bill you more than the published Monthly Energy Cap for your specific feeder and tariff band, which NERC releases every month on nerc.gov.ng. To check your bill, find your DISCO's cap document for the relevant month, locate your feeder and band, multiply the capped kWh figure by your current tariff rate, and compare that ceiling to what you were actually billed. If your bill is higher than that ceiling, you have a valid dispute.

What "Estimated Billing" Actually Means

If you don't have a meter, your DISCO has to guess your consumption somehow, and historically that guess was often arbitrary and inflated. To fix this, NERC issued the Order on Capping of Estimated Bills (Order No. NERC/197/2020), which legally caps what unmetered residential and commercial customers can be charged, based on the actual measured consumption of metered customers on the same feeder and tariff class. In plain terms: your DISCO is supposed to look at what your metered neighbors on the same line are genuinely using, and bill you no more than that average — not whatever figure makes their revenue targets look better.

How Your Estimated Bill Is Supposed to Be Calculated

The methodology works like this: your DISCO takes the energy consumption of both prepaid and postpaid metered customers on your specific feeder and tariff class, calculates a weighted average, and that average becomes the basis for what unmetered customers on the same feeder can be billed. NERC then reviews and publishes this as a hard cap, expressed in kilowatt-hours (kWh), for every feeder in the country, every month. DISCOs that bill above this published cap are in direct violation of the order — and this isn't theoretical; NERC fined eight DISCOs over ₦628 million in 2025 specifically for breaching these caps and ordered credit adjustments to every affected customer.

How to Find Your Exact Cap

  1. Go to nerc.gov.ng and look for the "Monthly Energy Caps" section under Resources or Media — NERC publishes a fresh PDF for this every month.
  2. Open the document for your specific DISCO and the relevant month.
  3. Find your state and business unit (the local zone your DISCO operates, such as "Abaji" under AEDC or "Umuahia" under EEDC).
  4. Locate your specific feeder name — this is the technical name of the electrical line serving your transformer, not your street name. If you don't know which feeder serves your address, your DISCO's customer care unit can confirm it.
  5. Note your Service Band (A, B, C, D, or E) and the Cap figure shown in kWh next to your feeder.

If your DISCO's own bill or receipt already states your feeder name and band, that's the fastest way to skip straight to step 4.

Convert the Cap Into a Naira Ceiling

Once you have your cap in kWh, multiply it by your band's current tariff rate (₦ per kWh) to get the maximum your DISCO can legally bill you that month. Your band determines your rate under the Service-Based Tariff (SBT) framework:

Band Minimum Daily Supply Hours General Rate Tier
A 20 hours or more Highest — premium rate
B 16 to 19 hours High
C 12 to 15 hours Mid
D 8 to 11 hours Lower
E 4 to 7 hours Lowest

Exact naira-per-kWh figures change periodically through NERC's Multi-Year Tariff Order (MYTO) supplementary reviews, so don't rely on a fixed number from any article, including this one — check your most recent bill or your DISCO's published tariff schedule for your band's current exact rate. As a worked example using illustrative figures: if your feeder's published cap is 150 kWh and your band's current rate is ₦170/kWh, your legal ceiling for that month is 150 × 170 = ₦25,500. Anything billed above that figure for that period is a valid dispute.

A Few Terms You'll See on These Documents

The cap documents and NERC orders use some technical shorthand worth knowing before you dig in:

  • Non-MD (Non-Maximum Demand) — this is you, almost certainly, if you're a regular household or small shop. It covers customers billed on regular tariff classes rather than large-scale industrial demand metering.
  • MD (Maximum Demand) — larger commercial or industrial customers billed differently, based on peak demand rather than simple consumption. The capping rules still apply to MD customers, but the compensation and cap calculations use a different baseline.
  • R1, R2, C1 — these are the original tariff classification codes from the earlier billing methodology (R for residential, C for commercial), still referenced in some older documents and DISCO paperwork even though the Service-Based Tariff bands (A–E) are now the primary structure determining your rate.

If a document or your bill uses one of these terms and you're unsure which applies to you, your DISCO's CCU can confirm your exact classification in under a minute, since it's tied directly to your account.

Why Your Bill Can Rise Even If Your Usage Hasn't Changed

It's worth understanding that your monthly cap in kWh and your tariff rate in ₦/kWh are two separate, independently moving numbers. The cap reflects actual measured consumption patterns on your feeder and tends to move slowly. The rate, on the other hand, is set through NERC's Multi-Year Tariff Order and its supplementary reviews, which happen periodically in response to factors like generation costs, gas prices, and exchange rate movements — and these reviews have pushed rates upward more than once in recent years. So if your bill goes up while your actual consumption habits haven't changed, the more likely explanation is a rate adjustment at the regulatory level, not your DISCO arbitrarily padding your estimate. Checking the current rate for your band against what you were charged is just as important as checking the kWh cap itself.

Your Band Should Match Your Actual Hours of Supply

Bands aren't just a billing label — they're a service commitment. If you're billed as Band A (paying the highest rate for a guaranteed 20+ hours daily) but you're actually getting far less than that, you're not just overpaying, you're being billed for a service level you're not receiving at all. This is a live, enforced issue: in 2026, NERC issued Directive No. NERC/2026/002 specifically compensating Band A customers nationwide after gas supply shortages and infrastructure vandalism caused widespread shortfalls below the promised hours. Customers on affected feeders received credits equal to 20% of their feeder's energy cap for the period, delivered as token credits for prepaid customers and bill adjustments for postpaid customers — and DISCOs were explicitly barred from using those credits to offset any existing debt. This sets a clear precedent: if your actual supply hours consistently fall short of your band's promise, that's grounds for a service failure complaint, not just a billing dispute.

How to Dispute a Bill That's Above Your Cap or Doesn't Match Your Band

  1. Gather your last two or three bills or receipts.
  2. Pull the current Monthly Energy Cap document for your feeder, following the steps above.
  3. Calculate your legal ceiling (cap in kWh × your band's rate) for each of those months.
  4. Compare that ceiling to what you were actually billed. Write down the difference in plain figures — this is the exact amount you're disputing.
  5. Submit a written complaint to your DISCO's nearest Customer Complaints Unit (CCU), including your meter/account number, the feeder name and cap you found, your calculation, and copies of the disputed bills.
  6. Get a written acknowledgment of your complaint — you'll need this if you have to escalate further.
  7. If you also believe your actual supply hours don't match your billed band, state this separately and clearly in the same complaint, since it may entitle you to a service failure adjustment on top of any capping correction. Note down rough outage times over a week or two beforehand if you can, since specific timestamps make this part of the complaint far harder to dismiss than a general statement that supply has been poor.

Special Case — Your Meter Went Faulty and Wasn't Replaced Quickly

If your existing meter develops a fault, NERC requires your DISCO to replace it. If they fail to do so within two working days, the rule changes: rather than a fresh estimate, you should be billed an average of your last three months of actual billing or vending, in line with the MAP regulations, until the replacement happens. If you've been switched to a generic estimate instead of this three-month average after a meter fault, that's a separate and specific point to raise in your complaint.

Common Problems (If This Doesn't Work)

Your DISCO says the cap document doesn't apply to your feeder Ask them directly which feeder serves your specific address, since this is sometimes the actual source of confusion — your DISCO's technical team can confirm it even if it's not obvious to you from your bill. Once you have the correct feeder name, recheck the cap document against that.

You can't tell which "Business Unit" your area falls under Business units are internal zones your DISCO uses to organize service areas, and they don't always map neatly to local government names you'd recognize. Your DISCO's CCU or the same cap document's broader listing for your state can usually clarify this, or you can simply ask your DISCO directly for your feeder name rather than trying to reverse-engineer it yourself.

Your DISCO acknowledges the overbilling but is slow to credit it Put a reasonable timeline in writing in your complaint (for example, request resolution within the standard 15 working days NERC allows for CCU complaints) and keep a copy. If that window passes without action, you have clear grounds to escalate.

You believe your band classification itself is wrong, not just your bill This is a service classification issue, not purely a billing one. Raise it explicitly as a band/service complaint referencing your actual measured supply hours over a representative period (a week or two of noting outage times is a reasonable starting point), since vague complaints about "bad supply" without specifics are harder for a DISCO to act on quickly.

How to Escalate

  1. If your DISCO's CCU doesn't resolve your complaint within about 15 working days, or you're unsatisfied with their response, take it to the nearest NERC Consumer Forum office.
  2. If the Forum's resolution still doesn't satisfy you, escalate directly to NERC headquarters with your complaint and all supporting documents — your cap calculation, your bills, and any written correspondence with your DISCO so far.
  3. You can reach NERC headquarters by phone on 0201 344 4331 or 0908 899 9244, or by email at complaints@nerc.gov.ng.

Energy caps are republished monthly and tariff rates shift periodically through MYTO supplementary orders, so always pull the current month's documents rather than relying on older figures, including any examples used in this article. This is one area where being a few months out of date can genuinely cost you money, in either direction — either you're disputing against a stale cap that's since changed, or you're missing an overcharge because you're comparing against an outdated rate.

Bookmark this page — we update it whenever NERC changes the capping methodology or tariff structure. Still confused about your specific bill? Drop your DISCO, your band, and roughly how far over your calculated cap you are in the comments and we'll help you work through it. If you can also share your feeder name from your bill, that makes it much easier for us (or another reader on the same line) to confirm whether your specific cap was applied correctly.