In Nigeria, a shift in the regulatory landscape for gambling is unfolding. Since November 2024, when the Supreme Court ruled that the authority to regulate lotteries and games of chance resides with state governments rather than the federal government, various states have been advancing their own legal frameworks. This decision, which invalidated the National Lottery Act, concluded a protracted legal battle initiated by Lagos state 16 years prior and has significant implications for governance and market operations in Nigeria’s gambling sector.
The court’s ruling has prompted a varied response from the states. At least ten states, including Lagos, Delta, and Imo, had pre-existing regulations and have continued to operate under these frameworks, now unencumbered by federal oversight. Meanwhile, other states are still developing their regulatory responses. Legal experts, such as Adewumi Salami from DLA Piper Africa, highlight the uneven progress among states but note a growing momentum towards independent regulatory regimes. Lagos, with its established Lagos State Lotteries and Gaming Authority, exemplifies a jurisdiction that was prepared to assume regulatory duties immediately post-ruling.
In the wake of the court’s decision, certain states, like Osun, have swiftly enacted new laws. Osun passed the Lotteries and Gaming Bill in November 2024, creating the Osun State Lotteries and Gaming Board. Similarly, Anambra has advanced its legislative efforts by tabling new gaming bills. These developments underscore the active efforts by the states to formalize control over their respective gambling markets.
The Supreme Court’s decision underscores that regulation of lotteries is considered a “residual” matter under Nigerian law, meaning it is not part of the federal assembly’s 68-item exclusive legislative list. This clarification delineates federal and state responsibilities, asserting state-level jurisdiction over gambling, similar to other local concerns.
Nigeria’s gambling market, particularly sports betting, is significant, with a gross win nearing $1.6 billion in 2025 according to H2 Gambling Capital. Football betting remains dominant, driven by the popularity of the English Premier League and other international competitions. However, there is a noticeable shift towards online casinos, driven by improved internet access and payment systems, which now complement sports betting platforms.
In response to the regulatory changes, about 22 states have formed the Federation of State Gaming Regulators of Nigeria (FSGRN). This body has introduced a Subnational Reciprocity Licensing Framework, allowing operators to obtain a Universal Reciprocity Certificate (URC) that is valid across all member states, thus facilitating a streamlined licensing process for online gaming. The FSGRN has also waived 2025 licence fees for operators transitioning from the previous federal framework to the state-led structure.
Despite the progress, the landscape remains fragmented. Odunayo Ibitoye of Templars Law categorizes the states into those with clear gambling laws, those with unclear or prohibited frameworks, and those without any regulatory provisions, such as the Federal Capital Territory (FCT) around Abuja. In the north, states under Sharia law typically prohibit gambling, creating regional disparities in regulatory environments.
The implications of the Supreme Court ruling are multifaceted. Some experts, such as Ibitoye, argue that this shift empowers states to effectively harness the economic potential of their gambling sectors through tailored regulations. The FSGRN’s framework, although promising in reducing duplicative licensing burdens, currently applies only to online gaming, leaving offline operations subject to varied state laws.
The FSGRN’s reciprocal licensing approach, through the URC, offers a centralized solution but is still in its nascent stages and does not cover operators in non-member states. This leaves room for compliance challenges, particularly in regions where legal clarity is lacking. Additionally, the absence of uniform laws in the predominantly Muslim north, where gambling is generally prohibited, poses further compliance risks.
The unresolved status of online gambling remains a concern. While the Supreme Court has clarified jurisdiction over offline lotteries, the complexities of online and cross-border gaming involve additional legal interpretations. Salami points out the ongoing legal nuances when players from different states engage with operators licensed elsewhere, highlighting the need for a cohesive national approach to online gambling regulation.
Looking ahead, the focus will be on how states implement their respective laws and how the FSGRN framework evolves to potentially include offline gaming. The regulatory environment is expected to remain dynamic as states refine their approaches, influenced by socio-economic contexts and local governance structures. The developments will continue to shape Nigeria’s gambling industry, offering both challenges and opportunities for operators seeking to navigate this evolving market.
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