Licensing and regulation: Can we get a licence?

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).