DIGITAL LENDING REGULATIONS 2025: FCCPC OVERSIGHT

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BY ADERONKE ALEX-ADEDIPE AND HILLARY OKOROTIE
Introduction

The Federal Competition and Consumer Protection Commission (the “Commission”) on July 24, 2025 introduced the Digital, Electronic, Online, or Non-Traditional Consumer Lending Regulation 2025 (the “Regulation”).

In 2022, the Commission had issued the Limited Interim Regulatory/Registration Framework and Guidelines for Digital Lending which sought to regulate the affairs of all digital lenders via registration with the Commission. Subsequently, the Commission issued the Regulation, which applies to consumer lending transactions involving cash, airtime, data, and other forms of barter in exchange for specific or verifiable monetary value. The Regulation provides comprehensive guidance on the requirement for registration of lending service providers, consumer protection measures and penalties for default or unethical practices.

In this newsletter, we highlight some of the key provisions of the new Regulation and their impact on consumer lending.

What is the Scope of the Regulation?

This Regulation applies to all transactions involving the provision of unsecured loans whether in the form of airtime or data advances, cash, cashback, or other services exchanged for specific or verifiable monetary value through any digital, electronic, online, or other non-traditional channels. It further extends to entities or individuals who derive, or undertake to derive, a share of the revenue generated from such consumer lending services, whether as primary or secondary lenders, partners, service providers, collaborators, or vendors.

More specifically, the Regulation requires that the following persons intending to provide or participate in a lending transaction, as described below, shall obtain the approval of the Commission:

  • Any entity providing consumer lending services directly to consumers, or offering ancillary services in support of such transactions, must register with the Commission.
  • Entities intending to partner for the purpose of offering consumer lending services, the proposed partnership agreement must be submitted to the Commission for prior review and approval.
  • Entities providing or intending to provide consumer lending services are prohibited from entering into any agreement, joint venture, or similar arrangement with an entity regulated by another regulator, except where such entity holds a valid license or approval authorizing it to carry out such activities.
  • Where collaboration involves fee-sharing, joint operations, strategic alliances, or similar arrangements with an entity licensed by another regulator for the purpose of consumer lending, the parties must execute a Consumer Lending Service Agreement and obtain the Commission’s approval before commencing operations.

In addition, the Regulation exempts Banks and other financial institutions licensed under the Banks and Other Financial Institutions Act from its scope.

Registration by Providers of Consumer Lending Services

Under the Regulation, entities to which the Regulation applies are required to register with the FCCPC within 90 days from its commencement date.

To register with the Commission, an entity is required to submit the following documents:

  1. consumer lending service agreement or other ancillary agreements;
  2. completed application forms as prescribed by the Commission;
  3. incorporation documents;
  4. details of directors and key management personnel;
  5. list of shareholders, including beneficial owners;
  6. financial statements for at least the three (3) years preceding the application;
  7. standard terms for the provision of lending services to borrowers;
  8. proof of payment of the applicable fees, including a non-refundable application fee of ₦100,000 and an approval fee of ₦1,000,000 payable upon the Commission’s approval, or such other amounts as the Commission may prescribe from time to time; and
  9. any other documents as may be requested by the Commission.

An approval issued by the Commission shall expire on December 31 of the third year from the date of issuance and must be renewed no later than March 31 of the following year. Subsequent renewals shall be carried out 36 months from the date of the first renewal.

Consumer Protection

The Regulation contains some salient provisions which seek to protect consumers of lending services. Some of the key provisions are highlighted below;

  • Lending service providers are required to clearly display the terms of their services on their apps, websites, or other digital platforms. These terms must expressly disclose to borrowers the applicable interest rates, repayment conditions, and any other applicable fees.
  • With respect to advertising, the Regulation mandates that all promotional content must be factual and free from misleading claims or exaggerated representations of the benefits of the lending service.
  • In delivering their services, providers must adhere strictly to the terms offered and may not vary these terms from one borrower to another, except where such variations are expressly provided for. The Regulation further prohibits unfair contract terms particularly those that create a significant imbalance between the rights of the provider and the borrower.
  • As is now standard practice, lending service providers must ensure full compliance with the Nigeria Data Protection Act when processing customer data.

Reporting Requirement by Lending Service Providers.

Once registered and approved by the Commission, lending service providers are required to comply with the following reporting requirements:

  • Maintaining comprehensive records of all consumer lending transactions, including complaints of consumers received and their resolution.
  • Submitting biannual reports to the Commission detailing consumer transactions, transaction values, interest rates charged, and records of complaints and their resolution.
  • Filing annual returns with the Commission no later than March 31 of each year, covering the provider’s lending activities, consumer complaints, and audited financial statements.

Penalties for infringement of the Provision of the Regulation.

The Regulation has also introduced clear and standardized sanctions for unethical practices and non-compliance with the provisions of the Regulation.

For instance, any entity found in breach of the Regulation shall be subject to penalties, which may include monetary fines, revocation of approval, or suspension of operations. Where a fine is imposed, the defaulting entity shall be liable to pay ₦100,000,000 or 1% of its annual turnover, whichever is greater. In addition, each director of a defaulting lending service provider shall be liable to pay a fine of ₦50,000,000 and/or disqualification from serving as a director for a period of five (5) years.

Conclusion

The introduction of the Digital, Electronic, Online, or Non-Traditional Consumer Lending Regulation 2025 marks a significant step in strengthening oversight of Nigeria’s fast-growing digital lending sector. However, the Regulation is notably silent on the status of approvals previously granted under the 2022 Limited Interim Regulatory/Registration Framework and Guidelines for Digital Lending. It is unclear whether such approvals will automatically transition into the new regime or if affected entities will be required to undergo a fresh application process.

At its core, the Regulation seeks to promote transparency, curb unethical practices, safeguard consumers and provides clarity for service providers by setting standardized compliance obligations.

REGULATORY UPDATE: THE NIGERIAN INSURANCE INDUSTRY REFORM ACT 2025 – NAVIGATING COMPLIANCE

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BY SEUN TIMI-KOLEOLU AND ENIOLA SOGBESAN

Introduction.

On Tuesday, August 5, 2025, the Nigerian President, Bola Ahmed Tinubu signed into law the Nigerian Insurance Industry Reform Act (NIIRA or the “Act”) 2025. The Act represents a significant milestone in the development of a robust regulatory framework designed to support the goal of growing the Nigerian economy to the tune of one trillion US dollars by 2030. The Nigerian Insurance sector faces a historic transition as the Act replaces old regulations and unifies disparate insurance laws into a single, contemporary framework.

This newsletter highlights key provisions of the Act such as scope and license categorization, capital requirements, consumer protection and regional policy integration through the introduction of the ECOWAS Brown Card Scheme.

A. Scope & License Categorization

The Act is applicable to all insurance businesses and insurers in Nigeria except:

  1. an association of persons with no share formed for the purpose of aiding its members or their dependents;
  2. a corporate or unincorporated body whose business is established outside Nigeria and engaged solely in re-insurance transactions with insurers licensed under the Act;
  3. deposit insurance carried out by the Nigerian Deposit Insurance Corporation under the Nigerian Deposit Insurance Corporation Act.

Furthermore, the Act broadly provides for two (2) license categories – life insurance and non-life insurance. While the life insurance license category is divided into four (4) classes which are: individual life assurance, group life assurance, annuity and health insurance businesses’, the non-life insurance license include: fire insurance, general accident insurance, motor vehicle insurance, marine and aviation insurance, energy (oil, gas and power) insurance, engineering insurance, bonds credit guarantee and suretyship insurance and agricultural insurance other than those covered by the Nigerian Agricultural Insurance Corporation Act.

Notwithstanding the above, the Act authorizes the National Insurance Commission (the “Commission”) to publish additional insurance classes in the Federal Government Gazette.

B. Capital Requirements

To improve operators’ financial stability, the Act stipulates the minimum share capital requirement for insurers licensed under the Act. This new share capital requirement is the first recapitalization in over two decades in the insurance industry.

The minimum capital requirements are listed below:

  1. Non-Life Insurance Business: The higher of fifteen billion naira (N15,000,000,000) or the risk-based capital determined by the Commission.
  2. Life Insurance Business: The higher of ten billion naira (N10,000,000,000) or the risk-based capital determined by the Commission.
  3. Reinsurance Business: The higher of thirty-five billion naira (N35,000,000,000) or the risk-based capital determined by the Commission.

Also, the Act requires all insurers registered before the commencement of the Act to comply with the minimum share capital requirements within 12 months of the commencement of the Act. Furthermore, the Act empowers the Commission to require an insurer to increase its capital beyond the minimum capital requirement where the Commission considers appropriate having regard to the nature, size and complexity of the insurance business of the insurer.

C. Regulatory Filings

The Act requires every insurer not later than June 30 of each year, to submit in writing to the Commission its duly audited financial statements, revenue account and statement of investments before presentation at its annual general meeting. Following the approval of the Commission; the insurer must publish its general annual statement of financial position, statement of profit or loss and other comprehensive income in at least two widely circulated newspapers in Nigeria. The Act also requires all insurers to submit quarterly returns in the form prescribed to the Commission not later than 10 days after the last day of each quarter or such other interval as the Commission may specify.

D. Consumer Protection Mechanisms

Section 212 of the Act introduces the Insurance Policyholders’ Protection Fund (the “Fund”) to give policyholders financial security in the event that an insurer goes bankrupt or is unable to fulfill its responsibilities.

The Fund shall comprise of:

  1. 0.25% of the gross premium of income of every insurer and reinsurer; and
  2. 0.25% of the balance standing in the Security and Insurance Development Fund as of December 31 of the preceding year.

The goal of the Fund is to safeguard consumers, preserve stability in the insurance sector, and boost public trust by ensuring that legitimate claims are paid in the event of an insurer’s default. Other funds in the Act include Fire Services Maintenance Fund and Road Accidents Victims Compensation Fund.

E. ECOWAS Brown Card Scheme

To ensure Nigeria’s seamless integration into the Economic Community of West African States Brown Card Scheme (the “Scheme”), the Act creates the National Bureau on the ECOWAS Brown Card Scheme (the “Bureau”). The Scheme is a motor insurance scheme that provides prompt and fair compensation to victims of motor accidents caused by visiting motorists. In line with objectives of the Scheme, the Bureau is responsible for maintaining claims for cross-border auto accidents in West Africa, ensuring adherence to ECOWAS procedures and implementing the Scheme.

F. Quicker Claim Assessment and Disbursement

The Act aims to improve the responsiveness of insurers in claims disbursement by setting out strict deadlines to ensure that policy holders promptly receive financial relief, which is often critical in emergencies such as accidents or property losses. In more specific terms, Section 210 of the Act requires all insurers to settle all claims in writing by the insured or entitled parties within the timelines specified in the Commission’s Service Charter, not later than 60 days of notification. The failure by any insurer to comply with these requirements will attract a penalty in addition to compound interest on the claim amount.

G. The Insurtech Guidelines and the Act.

In our newsletter on the Guidelines for Insurtech Operations in Nigeria, we highlighted the regulatory framework governing insurtech operations in Nigeria. While the Guidelines set out the minimum requirements for insurtechs’, the Act expands their regulatory compliance obligations. Therefore, both regulations serve as the regulatory framework for Insurtech’s in Nigeria.

H. Sanctions

Where a person transacts insurance business without holding a valid license, the Act prescribes a penalty of twenty-five million Naira (N25,000,000), two years imprisonment or both for individuals.  While in the case of companies, firms or such other combination of persons, each principal officer of the company, firm or such other combination of persons responsible shall be sanctioned to pay a fine of fifty million Naira (N50,000,000), two years imprisonment or both.

Conclusion

With the enactment of the Nigerian Insurance Industry Reform Act 2025, the Nigerian insurance industry is about to experience a massive transformation. The Act provides the much-needed regulatory clarity by establishing comprehensive consumer protection procedures, precise claim processing timelines, and stricter regulatory standards. However, the onus of compliance and enforcement of the Act rests with insurers and the Commission

Their ability to enforce compliance, embrace innovation, and deliver on the overarching objectives of the Act will ultimately determine whether the Act achieves its goal of building a stronger, more inclusive, and trustworthy insurance sector in Nigeria.

CAPITAL MARKET TRENDS IN NIGERIA: NAVIGATING SEC RULES ON BOARD APPOINTMENTS & TENURE

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BY ADERONKE ALEX-ADEDIPE AND PROMISE ITAH

Intoduction

On June 19, 2025, the Securities and Exchange Commission (SEC) issued the Circular to All Public Companies and Capital Market Operators on the Transmutation of Independent Non-Executive Directors and Tenure of Directors (the “Circular”), introducing significant updates to board appointments and director tenure in response to governance trends observed in the Nigerian capital market. This was followed by the Guidance Note to Capital Market Operators and Public Companies on the Circular Regarding Board Appointments and Director Tenure (the “Guidance Note”) issued on July 1, 2025, which clarifies the practical application of these new requirements.

According to the SEC, these measures are intended to address the growing movement of Independent Non-Executive Directors (INEDs) into executive positions within the same corporate group, which the regulator considers capable of weakening board independence. The SEC has stated that the changes aim to support orderly and transparent board succession planning, ensure continuity and independence in oversight, and promote effective corporate governance aligned with global regulatory expectations.

In this Newsletter, we highlight the key provisions of the Circular and the Guidance Note (together, the “New Rules”) and outline practical steps to navigate them.

1. Scope of Application

The New Rules apply to:

  1. Public Liability Companies (PLCs); and
  2. Capital Market Operators (CMOs) that are designated by the SEC as Significant Public Interest Entities (PIEs) — typically those providing essential financial market infrastructure such as exchanges, central securities depositories, clearing houses, and trade repositories.

Other CMOs and private companies are not bound by the New Rules but may find it valuable to adopt them as part of their journey towards stronger corporate governance.

2. Key Provisions of the New Rules

a. Preserving Independence

INEDs in PLCs and PIEs can no longer be appointed as Executive Directors or Chief Executive Officers (CEOs), within the same company or group. This change protects the neutrality of the INED role and ensures oversight functions remain independent.

b. Tenure Limits for Directors

Directors in PIEs may serve:

  • A maximum of 10 consecutive years in the same company; and
  • No more than 12 consecutive years in total within the same corporate group.

For the purpose of determining a director’s tenure, number of years served before the New Rules came into effect will be counted. Organisations should therefore review the tenure of their current directors to ensure compliance.

PLCs that are not classified as PIEs must continue to comply with the provisions of the Nigerian Code of Corporate Governance 2018 (NCCG), which currently limits the tenure of INEDs to a maximum of three terms of three years each (total 9 years), while the tenure of Non-Executive Directors (NEDs), CEOs and Executive Directors remains at the discretion of the board.

c. Cooling-Off Before Chairmanship

  • A CEO or Executive Director in a PIE who has served the maximum tenure on the board must not be appointed as Chairman until after a mandatory three-year cool-off period. Where such a former CEO or Executive Director is appointed as Chairman following this period, their tenure shall not exceed four years
  • PLCs that are not classified as PIEs must continue to comply with the applicable provisions of the NCCG, which mandates a three-year cool-off period. The NCCG does not however impose a four-year maximum tenure of chairmanship after the cool-off period.

A Cool-Off Period as defined under the Guidance Note is a regulatory interval during which a former executive must abstain from assuming a leadership or oversight role to ensure independence and prevent conflicts of interest.

3. Practical Steps for Compliance

To navigate these New Rules effectively, organisations should take a proactive approach. This includes:

  1. immediately reviewing board composition and director tenure to identify any potential compliance gaps;
  2. updating governance and succession policies to reflect the new SEC requirements, and planning leadership transitions well in advance to maintain stability and continuity;
  3. engaging proactively with the SEC for clarification or guidance to ensure compliance.

By taking these actions now, organisations will not only meet their regulatory obligations but also demonstrate their commitment to the highest governance standards.

Conclusion

The SEC’s Circular and Guidance Note introduce new requirements for board appointments and director tenure that affect public companies and CMOs designated as PIEs by the SEC. Early review and careful planning can help boards identify potential compliance gaps, manage leadership transitions, and update governance policies in line with the rules. For other market operators, considering these standards voluntarily may provide clarity and signal alignment with the evolving governance landscape.

Regulatory Update: 2025 Guidelines for Insurtech Operations in Nigeria – Navigating Compliance

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Seun Timi-Koleolu and Eniola Sogbesan

Introduction

In furtherance of its regulatory powers, the National Insurance Commission (the “Commission”) in its circular dated July 30, 2025 issued the Guidelines for Insurtech Operations in Nigeria 2025 (the “Guidelines”). The Guidelines provide a comprehensive regulatory framework for the safe, responsible, and efficient deployment of Insurtech solutions by licensed insurance entities and technology-driven firms operating in Nigeria.

Effective August 1, 2025, these Guidelines introduce key provisions—including licence categorization, minimum capital requirements, and the scope of permissible activities. which this newsletter sets out.

1.    What is Insurtech?

The Guidelines define Insurtech as follows – “Insurtech is a combination of the words “insurance” and “technology”. Insurtech refers to an institution that uses technological innovations to provide insurance services efficiently and effectively”. Accordingly, it may be inferred from the Guidelines that where technology is actively used in the delivery of insurance services, such service provider may be considered to be an Insurtech service provider.

2.   License Categorization and Permissible Activities

The Guidelines require all Insurtech service providers to obtain a license from the Commission. Under the Guidelines, Insurtech licenses are categorised into two namely; Standalone Insurtech and Partnering Insurtech.

  1. Standalone Insurtech: These are entities that operate independently and offer insurance products or services directly to consumers. The Guidelines permit Standalone Insurtech to provide certain types of insurance including Health insurance, Term assurance, Motor insurance, Agric insurance and such other insurance that may be specified in its licence. The Guidelines, however, specifically exclude special risk products such as Oil and Gas Insurance, Marine and Aviation Insurance, Retire Life Annuity, and Insurances of Government Assets and Liabilities for Ministries, Departments, and Agencies from the permissible activities of Standalone Insurtech.
  2. Partnering Insurtech: A Partnering Insurtech is a corporate entity that collaborates with insurance institutions to improve or complement existing operations. The scope of permissible activities for a Partnering Insurtech under the Guidelines include the following:
  1. marketing and distribution of insurance products and services
  2. customer services
  3. policy administration
  4. product management
  5. claims management
  6. insurance business aggregation
  7. crop cutting, data collection and yield calculation
  8. such other services as may be stipulated by the Commission from time to time.

While a Partnering Insurtech license is valid for 4 years, the Guidelines are silent on the duration of the license of a Standalone Insurtech. It is hoped that the Commission will proffer clarity in this respect.

3. Impermissible Activities

The Guidelines expressly prohibit an Insurtech from engaging in the following activities:

  1. unlicensed insurance operations.
  2. ineligible insurance business.
  3. unapproved products and pricing models.
  4. unsupervised automated claims rejections.
  5. misleading marketing and sales practices.
  6. crypto based transactions.
  7. data privacy violations.
  8. unapproved cross-border digital sales.
  9. manipulative platform design.
  10. physical marketing of insurance products and other activities that may be prohibited by extant regulations and directives of the Commission.

4. Minimum Share Capital Requirements & Annual Levy

a. Standalone Insurtech

Under the Guidelines, a Standalone Insurtech is required to maintain a minimum share capital of, the higher of:

  1. N1,500,000,000 per category of general or non-life insurance business or risk-based capital determined from time to time by the Commission
  2. N1,000,000,000 per category of life insurance business or risk-based capital determined from time to time by the Commission; or
  3. such other amount as may be prescribed by the Commission from time to time.

b. Partnering Insurtech

In accordance with the Guidelines, a Partnering Insurtech must maintain a minimum share capital of:

  1. N10,000,000 as at the date of application and shall continue to maintain the same throughout the license period and
  2. professional Indemnity of not less than N100,000,000 or as may be prescribed by the Commission from time to time.

c.  Annual Levy

In addition to the share capital requirements, upon approval by the Commission, a Standalone Insurtech is required to pay an annual levy of 1% of its annual gross premium income or N5,000,000 whichever is higher. While a Partnering Insurtech is required to pay an annual levy of 1% of its annual gross commission income and remuneration fee or N500,000 whichever is higher.

5. Corporate Governance Requirements.

In line with global best practices, the Guidelines outline specific educational and professional qualifications required of senior management of Insurtechs.

a. Managing Director/Chief Executive Officer

In more specific terms, the Managing Director/Chief Executive Officer of a Standalone Insurtech is to have the following qualifications:

  1. first degree in insurance or Computer Science or related fields from a recognized academic institution, or
  2. proficiency certification in technology or related field from accredited training institutions, or
  3. professional qualification in insurance from a recognized institution, and
  4. 5 years cognate work experience or as the Commission may prescribe from time to time.

In addition, the MD/CEO is to satisfy the conditions of fit and proper persons set by the Commission and the appointment of the MD/CEO is subject to the prior approval of the Commission.

b. CTO/COO/Executive Director, Technology

The CTO/COO/Executive Director, Technology of a Standalone Insurtech is to satisfy the following qualifications:

  1. hold a recognized professional qualification in insurance with not less than 10 years post qualification experience in the insurance industry, 7 of which must be at a senior management level, or
  2. hold a first degree or its equivalent from a recognized institution and with not less than 15 years post qualification experience, 10 of which must be at senior management level in the Technical Department of an insurance or reinsurance company.

Additionally, the CTO/COO/ED. Tech is to fulfil the conditions of fit and proper persons set by the Commission and the appointment is subject to the prior approval of the Commission.

6. Remedial Measures & Sanctions

In accordance with its regulatory powers, the Guidelines empower the Commission to undertake remedial measures against an erring Insurtech. In more specific terms, some remedial measures the Commission may take include – intervention measures, inspection and investigation.

The Commission is also empowered to sanction any Insurtech that is in violation of the Guidelines. Some sanctions the Commission may take include:

  1. cancellation of the licence granted to an Insurtech on the observation of any infraction or non-compliance with the Guidelines.
  2. imposition of administrative sanctions on an Insurtech for inappropriate actions/inactions or corporate misconduct.
  3. in cases of violation of the provisions of extant laws, impose administrative penalties depending on the nature and gravity of the infraction.
  4. initiation of criminal proceedings against an Insurtech or any insurance institution who partners with an unlicensed Insurtech.

7. Additional Requirements

In addition to the foregoing, the Guidelines make robust provisions on matters related to standards for computer network and internet, prudential and market conduct requirements, business obligations, financial reporting and customer complaints redress mechanism.  The continuous compliance with these requirements is essential for an Insurtech to maintain its license with the Commission.

Conclusion

By recognizing the expanding role of technology and innovation in the delivery of insurance services, the Guidelines represent a proactive regulatory approach in addressing potential market expansion opportunities. With appropriate interaction between the Commission and prospective Insurtech companies, it is hoped that the Guidelines will fulfill the overarching objective of supporting Nigeria’s digital ecosystem, business and economy.

To read more on related articles, click here.

NAVIGATING NIGERIA’S GAMING LAWS: THE START OF A NEW CHAPTER

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BY ADERONKE ALEX-ADEDIPE AND OMODELE FATODU

INTRODUCTION

On 22 November 2024, the Supreme Court of Nigeria delivered a significant judgment in Attorney-General of Lagos State & Ors v. Attorney-General of the Federation & Ors (SC/1/2008), which effectively curtailed the application of the National Lottery Act 2005 to the Federal Capital Territory alone. The apex court held that lotteries, betting, and gaming do not fall within the scope of the federal government’s legislative competence under the Exclusive Legislative List. Rather, they are matters within the residual legislative powers of the states under the Nigerian Constitution.

In its decision, the Court concluded that lotteries and Games of Chance are not among the 68 items in the Exclusive Legislative List and are not incidental or supplementary to any matter mentioned in the list. Consequently, the National Lottery Regulatory Commission, established under the National Lottery Act, has no jurisdiction beyond the Federal Capital Territory, and any regulation, licensing, or enforcement activity it undertakes in other states is unconstitutional.

Going forward, any person or entity seeking to carry on lottery, betting, or gaming operations in Nigeria (outside of the FCT) must comply with the laws of the individual state in which they operate. In the case of Lagos State, for instance, this means adherence to the Lagos State Lotteries and Gaming Authority Law 2021, as well as all subsidiary regulations and guidelines issued by the Lagos State Lotteries and Gaming Authority (LSLGA).

Lagos State Licensing Requirements and Fees

The LSLGA is now the sole regulatory body empowered to license, monitor, and supervise gaming and betting operations within Lagos State. The categories of gaming activities regulated by the Authority include lotteries, sports betting, casino operations, promotional competitions, pool betting, and skill-based games involving prizes.

Operators are required to obtain the appropriate category of licence from the Authority before commencing operations in Lagos. Although documentary requirements vary slightly depending on the nature of the licence, all applicants must typically provide the following information:

  1. Certificate of incorporation with the Corporate Affairs Commission
  2. Memorandum and Articles of Association
  3. Details of directors, shareholders, and beneficial owners
  4. Valid tax clearance certificate
  5. AML/CFT compliance documentation and KYC protocols
  6. Evidence of a registered office within Lagos State
  7. A detailed business plan and operational proposal
  8. Financial projections and statement of source of funds
  9. Technical documentation, including software certifications

The applicable licensing and renewal fees depend on the category of licence. For example, a sports betting licence in Lagos attracts an application fee of ₦1 million, a licence fee of ₦100 million, and an annual renewal fee of ₦50 million. In addition, licensees must remit a 2.5% levy on their sales revenue. For online casinos, the licence fee is ₦50 million, with a renewal fee of ₦10 million and a monthly gaming tax of 10% on sales (less winnings). An annual gaming machine tax of ₦20,000 per machine also applies. Other discretionary fees charged by the LSLGA can be as high as N25,000,000.

The Central Gaming Bill

Despite the Supreme Court’s decision, the National Assembly is currently considering a Central Gaming Bill intended to centralise the licensing and regulation of online and remote gaming activities in Nigeria. The proposed Bill seeks to establish a National Gaming Commission with the authority to issue licences, regulate technology providers, and supervise gaming operators nationwide.

However, the Bill has sparked strong resistance from the Federation of State Gaming Regulators in Nigeria (FSGRN), representing regulators from over 20 states in Nigeria, including Lagos State. In a formal response, the FSGRN criticised the Bill as “a repackaged version of the now-nullified National Lottery Act 2005.” The FSGRN has called on the National Assembly to withdraw the Bill, citing its apparent conflict with the 2024 Supreme Court judgment, which held that lotteries and gaming are state matters. According to the FSGRN, the proposed Bill would be unconstitutional, undermine the fiscal autonomy of states, and create legal uncertainty for existing operators already licensed by state authorities.

As of July 2025, the Bill has passed its third reading in the National Assembly but awaits concurrence and presidential assent. State regulators have pledged to continue resisting any federal attempt to override their jurisdiction in the gaming sector.

Conclusion
The 2024 Supreme Court decision reaffirmed that the power to regulate lotteries and gaming resides with Nigeria’s state governments. This development provides much-needed legal clarity and strengthens the role of state-level regulators such as the LSLGA, which now holds exclusive jurisdiction over gaming operations within the state.

While the proposed Central Gaming Bill aims to streamline regulation nationwide, its current form risks reintroducing an overlap under a different guise. Rather than centralising control, a more collaborative approach that fosters coordination among state regulators while still ensuring regulatory clarity and consistency without encroaching on constitutionally guaranteed state powers may offer a more sustainable path forward.