The Lagos State Lotteries and Gaming Authority (LSLGA) is the regulatory body responsible for all gambling activities in Lagos State, Nigeria. Established by the Lagos State Lotteries and Gaming Authority Law of 2021, the LSLGA replaced the former Lagos State Lotteries Board and consolidated the regulation of lotteries, betting, casinos, gaming machines, promotional competitions, and related gaming categories within the state. The LSLGA's mandate extends to both land-based and online gaming operations, licensing operators for retail outlets as well as internet and mobile platforms. In effect, any company wishing to offer gambling services (betting, lottery, casino, etc.) in Lagos must be licensed by the LSLGA under Lagos State law.
Evolution of Gambling Laws in Nigeria
Federal vs. State Authority: Historically, there was a dual regulatory regime in Nigeria, with the federal National Lottery Regulatory Commission (NLRC) overseeing "national" gaming licenses alongside state regulators. This overlap led to conflicts, especially in Lagos. However, a landmark Supreme Court decision on 22 November 2024 resolved this conflict by nullifying the federal National Lottery Act 2005 (which had created the NLRC) and holding that the power to regulate lotteries and gaming lies exclusively with the states. In that case (Attorney General of Lagos State & Ors v. A.G. Federation & Ors), the Supreme Court determined that lotteries and gaming are not on the Exclusive or Concurrent Legislative Lists of the Nigerian Constitution, and thus fall under the residual legislative authority of state governments. As a result, the NLRC's authority in Lagos State (and other states) was invalidated, and the LSLGA is now the sole licensing authority for gambling within Lagos State. The LSLGA publicly applauded this judgment, noting that all reliefs sought by Lagos were granted in the unanimous verdict of the Supreme Court of Nigeria.
Implications: Practically, this means any operator wanting to enter the Lagos market must deal exclusively with the LSLGA for licensing. Federal licenses (such as the former "national" lottery or sports betting permits issued by the NLRC) are no longer recognised in Lagos. Indeed, the LSLGA has warned that operators holding such federal licenses "are in possession of mere paper without any legal backing", and must regularise their operations under the appropriate state licenses or face enforcement actions. In sum, Lagos State law governs gambling within Lagos, and compliance with LSLGA regulations is mandatory for both online and on-ground gaming businesses in the state.
Licensing Requirements and Eligibility Criteria for Operators
Prospective gambling operators (whether running an online platform or a physical establishment) must meet strict requirements set by the LSLGA before a license is granted. Key licensing requirements and eligibility criteria include:
- Incorporation and Share Capital: The operating entity must be a corporate body incorporated in Nigeria under the Companies and Allied Matters Act (CAMA) 2020. Lagos State requires a minimum paid-up share capital (equity) as proof of financial capacity. In fact, a minimum share capital of ₦30 million (Thirty million naira) is mandated for each gaming license category. This ensures the operator has a substantial financial base. The company's Certificate of Incorporation, Memorandum and Articles of Association, and other incorporation documents from the CAC must be submitted with the application. Where any foreigner is involved in the company, the minimum authorised share capital must be ₦100 million (One Hundred Million Naira), following the regulations of the Federal Ministry of Interior, which must issue a business permit to all foreign-owned companies before the commencement of operation.
- Local Ownership Requirement: Lagos State policy encourages local participation. Under the 2021 Law (as originally proposed), an applicant company is expected to have some Nigerian ownership in its shareholding structure. In practice, this means foreign investors need a local partner holding some equity or appointed as a director or both. This requirement aims to prevent entirely foreign-owned gambling operations and ensure Nigerians have a stake in the industry.
- Fit and Proper Persons: All directors and key persons of the company are subject to due diligence and must be "fit and proper" to hold a gambling license. The LSLGA may require, for example, that each Director provide a Tax Clearance Certificate for the past three years, demonstrating they are in good standing with tax authorities. (This also indirectly means directors should have no serious criminal or regulatory infractions, as such issues would typically surface during due diligence checks.) The background and profiles of directors and beneficial owners must be disclosed in the application, and the LSLGA will vet the management's integrity and competence as part of the process.
- Application Documentation: A comprehensive application dossier must be prepared. This starts with a formal application letter or cover letter addressed to the LSLGA, along with a completed application form (if provided by the Authority) and all supporting documents. Key documentation includes:
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- Corporate documents
- Business Plan / Proposal
- Technical and Operational Plans
- Financial Information
- Gaming Specifics
- Premises and Local Presence
- Due Diligence by LSLGA: Once an application is submitted, the LSLGA will conduct thorough due diligence. This includes verifying all documents and claims, checking the backgrounds of the company and its directors, and evaluating the business plan.
In summary, to be eligible for a gambling operator license in Lagos, one must have a duly registered Nigerian company with significant capital and local ownership, prepare a comprehensive dossier of plans and documents, and pass the LSLGA's fit-and-proper and due diligence scrutiny. The process is designed to screen out unserious or unscrupulous operators (as evidenced by the high capital requirements and fees, discussed below), thereby "aimed at stopping fraudsters from entering the lottery and gaming business".
Licensing Process for Online Gambling Operations
Obtaining an online gambling license (such as an online sports betting permit or an online lottery license) from LSLGA involves a multi-step procedure. The process is formal and must be followed in sequence by any operator seeking to offer internet or mobile-based gambling to customers in Lagos. The process includes the following stages:
- Application Submission: The first step is to compile all required documents (as outlined in the previous section) and submit a formal application to the LSLGA.
- Initial Review and Due Diligence: Upon receiving the application and fee, the LSLGA will review the materials for completeness and eligibility. The Authority will conduct due diligence checks as noted (verifying corporate status, directors' tax clearance, etc.).
- Presentation to the Regulator: If the written application passes the preliminary review, the LSLGA will invite the applicant to make an in-person presentation on the proposed gaming operation. The goal is to give regulators confidence in the operator's capabilities and preparedness.
- Approval in Principle (AIP): After the presentation and a satisfactory evaluation of the proposal, the LSLGA may grant an Approval in Principle (AIP) to the applicant. An AIP is essentially a provisional license or conditional approval. The authority may also decide to skip AIP to the final license if there is no outstanding requirement to be provided by the applicant and a license fee has been paid.
- Payment of License Fees: A license must be paid. For instance, the license fee for an Online Sports Betting operator in Lagos State is ₦50,000,000 (fifty million naira) for the first year.
- Issuance of Final License: Once LSLGA is satisfied that all AIP conditions have been met, including receipt of the full license fee, it will issue the final gambling license (permit). The license is usually a certificate specifying the type of gaming authorised (e.g. Online Sports Betting) and the duration. Under current Lagos regulations, an online sports betting license is valid for one year, renewable annually. (By contrast, a license for a public online lottery is valid for 5 years before renewal, reflecting the different category.) The newly licensed operator can then commence operations legally.
It should be noted that the procedure for other online gaming categories, such as online lotteries, interactive games, or pool betting, is very similar to the above but slightly varies. The documentation and technical requirements may vary slightly (for example, a lottery operator would need to show its random number generator and draw process). The emphasis throughout is on demonstrating robust systems and compliance capability before going live.
In summary, the cost of obtaining and maintaining a gambling license in Lagos is high. These financial barriers are deliberate – they ensure that only well-capitalised, serious operators enter the market, thereby protecting consumers and the industry's reputation. Any investor or company planning to enter the Lagos gambling market should budget for significant licensing fees and taxes as part of the cost of doing business legally.
Recent Regulatory Updates and Reforms Since the 2024 Supreme Court Ruling
The Supreme Court's nullification of the National Lottery Act in late 2024 has ushered in a new era of state-led regulation, and Lagos State has been at the forefront of adapting to this change. Here are some key updates and reforms in the Lagos gambling regulatory landscape following that decision:
- Clarification of Jurisdiction (Late 2024): In December 2024, the LSLGA issued public statements to clear up confusion in the industry. It emphasised that there are no valid "national" or federal remote gambling licenses in Nigeria and that any purported guide claiming such is misinformation. The Authority clarified that regulatory licensing for online gaming falls exclusively under state regulators as per the Constitution and the Supreme Court ruling. Consequently, the LSLGA reiterated that the NLRC (now defunct) can no longer issue or manage any gaming licenses. This was a direct message to operators: those who previously operated under an NLRC license across Nigeria must now secure licenses from each state they wish to operate in, Lagos included. The LSLGA even warned that operators with only an NLRC license risk being deemed illegal in Lagos and being subjected to shutdown if they do not obtain a Lagos State license.
- Transitional Arrangements for Former NLRC Licensees: Recognizing the potential disruption for operators who had federal licenses, the Federation of State Gaming Regulators of Nigeria (FSGRN) – a body comprising regulators from various states, including Lagos – took an important step in 2025. In May 2025, the FSGRN announced a "Subnational Reciprocity Licensing Framework", establishing a Universal Reciprocity License scheme. Under this framework, an operator can apply for a single URC license that is recognised across all member states of the federation (those that have signed onto the framework), instead of having to hold separate state licenses for each state. This was a significant reform aimed at easing the regulatory burden on operators post-NLRC. Lagos State, being a leading member, participates in this reciprocity arrangement.
As part of the URC rollout, the FSGRN also announced a one-time waiver of 2025 license fees for operators transitioning from an NLRC license to the new state system. In practical terms, if a company held a federal NLRC license that was rendered void by the Supreme Court, they could obtain a Universal Reciprocity License (covering Lagos and other states) in 2025 without paying the usual license fees for that year, provided they meet all requirements and apply through the FSGRN's process. They would then begin paying fees from 2026 onward. This concession was designed to encourage quick migration into compliance with state authorities like the LSLGA. It's worth noting that while the Universal Reciprocity License offers convenience, operators are still subject to each state's regulatory oversight – the framework harmonises the licensing, but not necessarily all tax or operational details, unless states agree on those as well.
- Market Impact: The clarification of state authority has arguably made Lagos even more attractive as a gaming market, since operators know exactly whom to deal with. Lagos, being Nigeria's commercial hub, continues to be the largest gambling market in the country. The LSLGA's processes, while rigorous, are now the definitive path to legality and certainty.
- Formation of FCTA- LRO: The Supreme Court's judgement that invalidated the federal gaming body (NLRC) clearly stipulates that the Federal Capital Territory Authority (FCTA) can also regulate the gaming activities within the Federal Capital Territory (FCT). Pursuant to this, the FCTA has established the FCTA- Lottery Regulatory Office to regulate the gaming activities within the FCT. The FCT is also one of the largest gaming markets in Nigeria, following Lagos State.
In conclusion, since the 2024 Supreme Court ruling, all eyes are on state regulators like the LSLGA for licensing and oversight of the gambling industry. For businesses and legal professionals looking to enter the Lagos gambling market in 2025 and beyond, the path is clearly defined: comply with the Lagos State Lotteries and Gaming Authority's requirements. By doing so – incorporating locally, meeting financial and ethical standards, and following the proper application procedure – operators can obtain the necessary licenses to operate either online, on land-based, or both, within Lagos. With diligent preparation and adherence to LSLGA regulations, applicants can navigate the process and tap into the opportunities of Lagos's vibrant gaming sector, now under an exclusively state-controlled regime.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
