Nigeria

Lagos State remains Nigeria's most developed gambling-regulatory environment, operating under the Lagos State Lotteries and Gaming Authority (LSLGA) Law 2021 with the Federation of State Gaming Regulators of Nigeria (FSGRN), comprising over twenty member states, coordinating licensing recognition across jurisdictions. The lead development is LSLGA's 12-13 October 2026 public notice extending licence-verification and record-disclosure duties to telecommunications operators, MNOs, VAS aggregators and VAS providers, building on the Authority's September 2026 declaration that a major offshore brand operates unlawfully across twenty-five states. At the federal level, President Bola Tinubu's continued refusal to assent to the Central Gaming Bill confirms the state-level licensing architecture remains the operative regime, with no near-term prospect of federal pre-emption or harmonisation.

Post SC/1/2008, gambling licensing in Nigeria is state-led. The LSLGA derives its powers from the Lagos State Lotteries and Gaming Authority Law 2021 and is now the sole regulator within Lagos State, licensing lotteries, sports betting, casino operations, promotional competitions, pool betting and skill-based games involving prizes, alongside gaming machines, scratch cards and B2B/gamification categories. Local incorporation with the Corporate Affairs Commission and a Lagos office are required. Minimum authorised share capital is NGN 30m for Nigerian companies and NGN 100m for companies with foreign involvement with Lagos requiring 15% local shareholding, ensuring domestic participation The FSGRN Universal Reciprocity (URC) framework offers multi-state coverage at NGN 100m per category per annum from 2026, with a one-time waiver of 2025 fees for operators transitioning from voided NLRC licences. The National Lottery Regulatory Commission (NLRC) was formally dissolved by the Federal Government in January 2025; its FCT licensing functions were transferred to a new body, the FCT Lottery Regulatory Office (FCT-LRO), which is now the sole licensing authority within the Federal Capital Territory. The NLRC no longer exists as an issuing authority and any operator relying on a legacy NLRC permit carries no legal backing anywhere in Nigeria. Poker is subsumed under the casino/gaming licence (no standalone poker statute exists in Lagos law). Application for full multi-state market entry typically takes 6 to 12 months. Application timeframe and phrases As there is variation across Nigerian States (except for those under FSGRN) and Gambling Products we have as a point of reference taken the example of Online Sports Betting Licence in Lagos State and FSGRN: As part of the application process, the applicant will be required to make a presentation · Where the applicant satisfactorily fulfils the pre-approval requirements, an Approval in Principle (AIP) will be granted for 90 days. The AIP is a temporary licence; the substantive licence will only be issued on fulfilment of ALL conditions highlighted in the AIP. LSLGA requires a minimum of 10 working days to conduct due diligence on every application before LSLGA. List of documents & type of information needed to support application Ordinarily, an application must be submitted to the concerned regulatory authority. This application shall consist of an application letter, a non-refundable fee, evidence of business incorporation in Nigeria, a detailed plan of the proposed gaming activity, the business structure, and evidence of financial capacity and technical structure. Expansion of Licensing Regime by the Lagos State Lotteries and Gaming Authority (LSLGA) The Lagos State Lotteries and Gaming Authority (LSLGA), widely regarded as the most developed gaming regulatory authority in Nigeria, has expanded its licensing framework to accommodate both Business-to-Consumer (B2C) operators and Business-to-Business (B2B) service providers. REQUIREMENTS FOR ONLINE SPORTS BETTING LICENCE IN LAGOS STATE & UNDER FSGRN 1. An application letter 2. Non-refundable application fee 3. Documentary Evidence of Business Incorporation (Certification of Incorporation and. Memorandum & Article of Incorporation) 4. Details of Directors 5. Address of registered office and administrative office (s) 6. Detailed business plan/proposal on the online sports betting scheme. The proposal should provide information and documentation on the following: Business Structure; ; Names and Profile of Directors; Tax Clearance Certificate of Directors in the last 3 (Three) Years; Description of Operations and Management Structure; A Sports Betting Industry Analysis that clearly demonstrates an understanding of the sports betting industry. The analysis must include names of major players and market share; Marketing and distribution plan; Address of planned location, branches and outlet(s). these must be lock-up shops – kiosks and mobile vendors are not allowed 7.Proposed Sports Betting Operation i. Details of Planned Games ii. Relevant Sport activity iii. Approximate odds to be used iv. Prizes & Price structure v. Number and frequency of sports/games vi. Operator's game rules and participants Code of Practice. 8. Financial information/projections i. Management account of your organization ii. Company's bank statement for the last 1 (One) year in support of financing plan iii. Five years projected Profit and Loss Account, Balance Sheet, Cash Flow analysis – this should provide for the annual licence fee and monthly. Please note that the licence fee is N150,000,000 (One Hundred and Fifty Million Naira) for the first year, while annual renewal is N100,000,000 (Hundred Million Naira). Monthly gaming tax is 2.5% of sales revenue iv. Nature and extent of financing and capital investment. Indicate if foreign investment is involved in the business and if any, terms of investment v. Capital budgets showing set up cost and asset schedule over 5 years 8. Detailed information about the applicant's bookmaker, betting sites and technical consultants. 9. Detailed information on proposed technical topography including a schematic diagram clearly illustrating the technical operational flow General: i. Architectural diagram clearly illustrating the technical operational flow ii. Proposed platform – self host or cloud based iii. If cloud based, the contact information of the hosting company Hardware: i. Detailed information on the type of servers to be used ii. Detailed information on firewall, routers etc iii. Redundancy implementations (if any) Software: i. Operating systems specifications ii. Database application specifications 9. Processes and System Quality Assurance. ## Infrastructure In practice, a licensed operator can provide mobile gambling services to Nigerian residents provided they meet the requirements of the telecommunications operator and the Nigerian Communications Commission (NCC).

LSLGA fees are material and NGN-denominated. A sports betting licence attracts an application fee of NGN 1m, a licence fee of NGN 100m and an annual renewal of NGN 50m, plus a 2.5% levy on sales revenue. An online casino licence is NGN 50m with NGN 10m renewal and a 10% monthly gaming tax on sales less winnings, plus NGN 20,000 per gaming machine annually. Discretionary fees can reach NGN 25m. FSGRN URC charges NGN 100m per category per annum from 2026 (2025 waived for NLRC transitioners). Minimum share capital is NGN 30m (Nigerian) / NGN 100m (foreign involvement). FLAG: all EUR equivalents are volatile due to NGN currency instability.

Nigeria applies a mixed tax basis. Withholding tax on player winnings is 5% for residents and 15% for non-residents under the Withholding Regulations 2024, with Lagos imposing an additional 5% WHT on net online betting winnings from 2026. Tax Act 2025 s.185(m) exempts player stakes from VAT from 2026-01-01, while standard VAT of 7.5% remains for other supplies. GGR-style levies include LSLGA's 2.5% sports betting sales levy, LSLGA's 10% monthly casino gaming tax, and the FSGRN 11% GGR Good Causes levy from 2026. Corporate income tax applies under Tax Act 2025. ## Application & License Fees The application fees are dependent on the type and class of application and further dependent on whether it is a National or State licence. For further details, see information in specific product sections B2C Gaming Operator Licenses in Lagos State: For operators intending to offer sports betting, casino games, or online gaming products directly to consumers, the licensing costs are significantly higher. Typical costs include: Application fee of ₦1,000,000 License fee: up to ₦100,000,000 – ₦200,000,000 depending on category Good Causes Levy: approximately 15% of Gross Gaming Revenue (GGR) ## FSGRN Licensing Structure and Costs for Market Entry For international operators entering Nigeria, the FSGRN framework has introduced a harmonized structure for multi-state gaming operations. Although licenses remain issued by state authorities, the FSGRN framework allows operators to access broader market recognition across multiple states. Typical Licensing Structure: Non-refundable application fee :₦5,000,000 Universal reciprocity license: ₦100,000,000 Mandatory security bond: ₦100,000,000 Annual renewal license Approximately: ₦10,000,000 – ₦20,000,000 Security Bond Requirement: Operators are typically required to maintain a ₦100 million security bond in favor of the regulator to ensure compliance with operational obligations, including: Player payout guarantees Regulatory penalties where applicable Responsible gaming compliance obligations

Bank transfer is the dominant rail (Flutterwave, Paystack, Interswitch), with mobile money (OPay, PalmPay), USSD banking and agent cash deposit/withdrawal widely used; debit cards (Visa, Mastercard) are accepted. MCC 7995 treatment by banks is not confirmed. Crypto payments are regulated for gambling. CBN VASP banking guidelines (2023-12-22) apply only to SEC-licensed VASPs. - Crypto and gaming: the regulatory perimeter is becoming clearer. The formalisation of Nigeria’s virtual-asset sector is another development that gaming businesses should not overlook. On 18 July 2026, the President of the Federal Republic of Nigeria signed the Presidential Executive Order on Virtual Assets Coordination 2026. The Order established a Virtual Asset Council chaired by the CBN, with the Nigeria Revenue Service and SEC as Vice-Chairs, alongside the NFIU and ONSA. It also established a Virtual Asset Office to coordinate applications, reporting and information sharing. - Importantly, the framework does not create a new omnibus crypto regulator. Instead, it coordinates existing institutional mandates. The State House explained that securities-related virtual-asset activities will remain within the SEC’s remit, while payment, settlement, custody and related services involving non-security virtual assets will be registered through the CBN framework, with the coordinating Council addressing areas of uncertainty. - For the gaming industry, this is highly relevant. Crypto-enabled gaming products, deposits, withdrawals, wallets, tokenised rewards and blockchain-based gaming platforms can sit at the intersection of gaming regulation and financial regulation. An operator cannot assume that a gaming licence alone authorises it to provide regulated virtual-asset or payment services. - The emergence of a coordinated virtual-asset framework also reinforces the need for stronger AML, KYC, transaction monitoring and source-of-funds controls. The regulatory direction is towards formalisation rather than regulatory vacuum. - Accordingly, operators considering crypto-enabled gaming should ask, at an early stage: - Is the proposed digital asset a security or another form of virtual asset? - Does the business provide custody, payment, settlement or exchange-related services? - Which entity in the group will perform the regulated activity? - What CBN, SEC, NFIU and tax obligations may arise? - How will crypto transactions be integrated into gaming AML/KYC controls? - How will customer funds and winnings be segregated, recorded and reported? The new framework also creates a broader policy signal: Nigeria is moving towards formal recognition and coordinated supervision of the crypto sector rather than treating digital assets as an unregulated parallel financial system. Gaming businesses operating at the intersection of the two sectors will need to adapt accordingly The DNFBP AML regime under MLPPA 2022 includes casinos, requires SCUML registration, and mandates STRs to the NFIU within 24 hours, with CTR and CBTR thresholds. A CBN PSP licence is required for payment processors.

LSLGA's 12-13 October 2026 public notice is the lead distribution development. It directs telecommunications operators, mobile network operators, VAS aggregators and VAS providers to verify that any gaming operator distributed through USSD, SMS, short code, mobile app or carrier-billing channels in Lagos State holds a valid LSLGA licence, and to surrender transaction, carrier-billing and revenue-share records covering the period since the 22 November 2024 Supreme Court judgment, within thirty days of the notice. The notice expressly clarifies that a licence, authorisation or approval issued by the Nigerian Communications Commission does not substitute for a gaming licence, closing a potential argument that telecoms-sector authorisation alone could legitimise facilitation of gaming services. This represents a material tightening of the distribution perimeter, placing an affirmative compliance burden directly on the intermediaries that carry gaming traffic rather than solely on the gaming operators themselves.

State authority is confirmed by the Tinubu veto of the Central Gaming Bill. Direction is mixed: liberalising signals include the Tax Act 2025 VAT exemption on stakes and the FATF grey-list exit, while tightening signals include the FSGRN 11% GGR levy from 2026, the ARCON enforcement push, and recentralisation risk should a future federal effort succeed. The Central Gaming Bill passed National Assembly readings but assent was declined; FSGRN has criticised it as a repackaged National Lottery Act. Many states still lack a gaming framework.