A Nigeria iGaming licence is a state licence. On 22 November 2024 the Supreme Court of Nigeria, in Attorney General of Lagos State and others versus Attorney General of the Federation and others (Suit No. SC/1/2008), held that lotteries and games of chance sit with the states. The National Lottery Act 2005 was nullified. The National Lottery Regulatory Commission no longer supplies a nationwide iGaming licence that operators can treat as cover for every state. This Sporty Africa briefing is for operators, suppliers, affiliates and readers who need that Nigerian map. It is not legal advice and it is not an application.
Nigeria is not one gambling desk. Lagos, the commercial centre, runs through the Lagos State Lotteries and Gaming Authority. Other states license on their own statutes, or through the reciprocity deal described below, or, in some cases, still without a settled public framework. Stakes are in naira. Players fund wallets by bank transfer, USSD, cards and local fintech apps. Any Nigeria iGaming licence conversation that starts in London or Malta and never opens a state gazette is the wrong conversation.
What the Supreme Court decided for a Nigeria iGaming licence
The judgment was unanimous, from a seven-member panel, with the lead judgment delivered by Justice Muhammed Baba Idris. The Court held that the National Assembly lacked power to legislate for lottery and games of chance. Those subjects are on neither the Exclusive Legislative List nor the Concurrent Legislative List, so they are residual matters for state Houses of Assembly. The Court granted the reliefs sought by Lagos and the other plaintiff states, including nullification of the National Lottery Act.
Lagos State Lotteries and Gaming Authority welcomed the ruling the same day and has since told the market, in its own words, that a so-called federal “remote gaming licence” has no backing. Operators holding paper from the old national commission were told to regularise with the Lagos State Lotteries and Gaming Authority or with the state regulator for the territory they actually serve. Enforcement language from Lagos includes shutdown of operations that skip that step.
For a reader outside Nigeria, the practical line is simple. A Nigeria iGaming licence means the licence of the state where the player is, or a state-level reciprocity certificate that truly includes that state. A federal letter dated before 22 November 2024 is a historical document. It is not a current passport to all 36 states and the Federal Capital Territory.
Lagos and the Lagos State Lotteries and Gaming Authority
Lagos is where most international operators meet Nigeria first. The Lagos State Lotteries and Gaming Authority is the body that publishes the state’s position, takes applications for activities under Lagos law, and has been the public voice on the Supreme Court case. A product aimed at customers in Lagos — sportsbook, online casino, public online lottery or a promotional competition — has to satisfy Lagos even when the brand’s holding company sits abroad.
Lagos also led the state side of the litigation. Treating Lagos as “one more stamp” after a foreign licence, or after an old NLRC permit, misreads the market. State rules cover who may offer the game, what the remote channel may do, what records are kept, and how the state expects tax and levies to be paid in naira. The Authority’s public notices are the starting text. Counsel in Lagos should confirm the current form, the current fee and whether a reciprocity certificate already answers the Lagos file or whether Lagos still wants its own exhibit.
Land-based shops, retail agents and products outside the online list are a further Lagos question. A certificate built for online sports betting does not silently authorise a shop in Ikeja or a retail lottery terminal. Walk-in premises follow the land-based rules of the state where the door opens.
The Universal Reciprocity Certificate across member states
After the judgment, states faced a practical problem: an operator serving many states could not sensibly collect 36 separate online licences for the same app, and companies that had already paid the old national commission wanted a transition. The Federation of State Gaming Regulators of Nigeria answered with a Subnational Reciprocity Licensing Framework. Aluko & Oyebode’s note of 23 June 2025 records that the framework had been signed and that an operator which qualifies receives a Universal Reciprocity Certificate.
That certificate, as described in the note, authorises online sports betting, online casino, public online lottery and promotional competitions across member states. It is a state-regulators’ certificate. It is not a new federal Nigeria iGaming licence, and it does not replace the Constitution. It reaches the states that are in the framework. A state outside the framework is outside the certificate until that state accedes or licenses the operator itself.
The same note says operators previously licensed by the National Lottery Regulatory Commission had to apply for the certificate. To ease that move, the Federation granted a full waiver of 2025 licensing fees for transitioning operators who met its criteria. Those operators were to renew and pay licence fees from 1 January 2026. Anyone still quoting a 2025 waiver in a 2026 budget should re-check. The waiver year has passed.
Member states named in June 2025
Aluko & Oyebode listed 22 member states at the date of that note: Lagos, Ekiti, Abia, Akwa Ibom, Anambra, Bayelsa, Benue, Cross River, Delta, Ebonyi, Edo, Enugu, Imo, Kogi, Nasarawa, Ogun, Ondo, Osun, Oyo, Plateau, Taraba and Kaduna. The Federal Capital Territory, Abuja, is not on that list. Neither are several large states. The note itself said more than ten states were, at that time, neither members nor holders of a full state licensing framework of their own.
Membership is a living list. A Nigeria iGaming licence plan that freezes the June 2025 names will go stale. Before you tell a board that one certificate covers “Nigeria”, ask the Federation of State Gaming Regulators of Nigeria, and ask the regulator in each state you will take naira from, whether that state is in, out, or running a parallel form. Non-member states can accede. They can also write their own statute and charge their own fee. Both outcomes change the model.
Products outside the four online heads still follow the state statute even inside a member state. Retail betting, land-based casino, and lottery formats the certificate does not name need a local reading. Promotional competitions that look like marketing — a telco draw, a retailer giveaway, a social-media jackpot — are on the certificate’s list and are also a favourite place for brands to assume “it is only marketing”. In Nigeria, a prize competition can be a licensed gaming activity. Check the state before the campaign goes live in Lagos, Kano or Port Harcourt.
What localisation looks like in a Nigerian file
Each state file has its own exhibits, and they share a family resemblance. Expect incorporation documents, the names of directors and beneficial owners, a business plan for the Nigerian product, game and platform descriptions, and evidence of anti-money-laundering controls. Where the state asks for it, that evidence includes registration with the Special Control Unit Against Money Laundering (SCUML) and procedures that would make sense to the Nigerian Financial Intelligence Unit. Policies written only for a European licence do not answer a Lagos question until someone maps them onto the state form.
Technical papers travel with the corporate papers. States that license remote play ask how the platform finds a player in that state, how self-exclusion works, how disputes are logged, and which legal entity holds the player balance in naira. An operator using the reciprocity certificate should still keep a schedule of any extra levy, report or technical test a member state adds on top. The certificate reduces duplicate online licences. It does not erase state tax offices.
Age and advertising rules are state-sensitive in practice even when the principle is the same. The licensing language is English. The ads that convert are often Pidgin, Yoruba, Igbo or Hausa, on Instagram, TikTok and radio. Those ads have to meet the same minimum-age and bonus rules as the English site. A Nigeria iGaming licence does not become optional because the creative is in Pidgin.
Naira, wallets and the player the licence is for
Nigerian players do not experience “iGaming” as a licence class. They experience a sportsbook that pays a football slip, a casino lobby that loads on a mid-range Android, and a withdrawal that lands in a bank account or a fintech wallet. Bank transfer, USSD pushes and apps such as OPay and PalmPay are the rails readers will recognise. A state licence does not appoint any of those wallets. Commercial access, name-matching on the account, and naira liquidity for payouts are operating work that sits next to the legal work.
Affiliates face the same map. A site that acquires Nigerian customers needs to know which state the traffic is in, which products the certificate or the state licence actually covers, and how to label a commercial relationship. Geo rules are not a footer slogan when the law itself is geo-based. Sending Kano traffic to a brand that has sorted only Lagos is a licensing problem, not a media-buying problem.
Currency volatility is part of the Nigerian product. Bonuses advertised in naira, odds that settle in naira, and a cashier that quotes a dollar balance without saying so, produce complaints the state regulator will see. Write the cashier in the currency the licence expects.
What to watch on the Nigeria iGaming licence
Watch four things. First, whether more states join the Federation of State Gaming Regulators of Nigeria, and whether any member leaves or adds a local condition. Second, how Lagos applies the certificate in real applications, because Lagos practice becomes the template other states copy. Third, any attempt to revive a federal gaming statute, which would have to live with the Supreme Court’s reading of the Constitution. Fourth, the renewal cycle for former national-commission operators, now on state fees from 2026.
A workable Nigeria iGaming licence file names the states, names the products, names the naira entity, and attaches the state or reciprocity document for each. It keeps the 23 June 2025 member list as history and the regulator’s current list as the live one. It treats Abuja as its own question until a document says otherwise.
Sporty Africa will update this Nigeria iGaming licence briefing when a state gazette, the Federation, or the courts move the map. Corrections and primary documents: editor@sporty.africa. More from the desk: Nigeria, West Africa and regulation. The Kenyan statute is covered in our Kenya iGaming licence explainer.
Sources: Supreme Court of Nigeria, Attorney General of Lagos State & Ors v Attorney General of the Federation & Ors, Suit No. SC/1/2008, 22 November 2024, as reported by the Lagos State Lotteries and Gaming Authority and by Legal 500; Lagos State Lotteries and Gaming Authority statement on remote gaming licences; Aluko & Oyebode, “The FSGRN Signs a Landmark Unified Subnational Reciprocity Licensing Framework”, 23 June 2025. Confirm member states and fees with the Federation and the relevant state regulator before you rely on them.
Sporty Africa reports. This article is not legal, tax or licensing advice.
