Following a landmark Supreme Court ruling in 2024, Nigeria’s gambling industry is being reshaped, but religious regions have caused grey areas for regulation.
Eighteen months after the Supreme Court in Nigeria ruled that the regulation of lotteries and games of chance falls under the authority of state governments rather than the federal government, states are continuing to move forward with efforts to establish legal frameworks governing the gambling industry within their respective jurisdictions.
In November 2024, the court voided the National Lottery Act of Nigeria and decided that state legislative assemblies should regulate gambling activity in their respective areas. The ruling put to rest a case that had been brought to the courts by the Lagos state government 16 years earlier, which sought a determination on which level of government must oversee the gambling industry in the 36-state federal nation.
At least 10 states, including Lagos, Delta and Imo, already had relevant laws before the 22 November 2024 court decision, thus they just moved on without the uncertainty of dual regulatory regimes. However, those that didn’t come up with laws immediately after the ruling are still in the process of doing so.
“The Supreme Court’s decision was constitutionally seismic,” Adewumi Salami, the legal director at DLA Piper Africa, a law firm based in Nigeria’s commercial capital of Lagos, tells iGB.
“In terms of state legislative response, the picture is uneven, but there is growing momentum. A number of states were already ahead of the curve, having maintained their own regulatory frameworks even before the ruling – notably, Lagos, Akwa Ibom, Anambra, Cross River, Delta, Imo, Ogun, Ondo, Oyo and Rivers states. These jurisdictions, particularly Lagos through the Lagos State Lotteries and Gaming Authority (LSLGA), were positioned to immediately exercise exclusive regulatory authority post-ruling,” Salami adds.
States taking steps to implement regulation
Among those that reacted after the court ruling was Osun state, which passed the Lotteries and Gaming Bill into law in November 2024. This piece of legislation established the Osun State Lotteries and Gaming Board. The state of Anambra is among those that have similarly tabled Gaming Bills.
A seven-member jury, which heard the Lagos state government case, agreed with the appellant that the National Assembly did not have the power to control or regulate lotteries in Nigeria because “lottery” is, according to Nigerian law, a “residual” matter.
This means that lottery and gambling in Africa’s most populous country are not included in the federal administration’s exclusive list of 68 items reserved for the national parliament to legislate upon. Key items on that list include defence and security, the creation of new states and banking.
Nigeria’s gambling market
According to H2 Gambling Capital, Nigeria’s gambling industry reached a total gross win of nearly $1.6 billion in 2025.
Football betting accounts for the bulk of sports wagering activity in the football-mad nation. The centres of interest are mainly the English Premier League, which features several Nigerian players, the UEFA Champions League and some local matches.
Brands such as Bet9ja and SportyBet have, via mobile applications and robust advertising, built enormous audiences in the country. However, according to Premium Times on 28 May, football betting’s position is coming under increased threat from online casinos.
“With mobile internet becoming cheaper and payment systems improving, players are no longer limited to traditional sportsbook betting alone,” the article states. “Online casino products, including slots, live dealer games and crash-style games, are now appearing directly alongside sports betting apps. Many operators increasingly treat casino gaming as an additional entertainment layer rather than a completely separate category.”
The FSGRN and reciprocal licensing
While some states enacted local laws, about 22 others have established the Federation of State Gaming Regulators of Nigeria (FSGRN), which, in May 2025, introduced a Subnational Reciprocity Licensing Framework, under which gaming operators may obtain a single licence known as the Universal Reciprocity Certificate (URC) valid across all FSGRN member states. For now, the FSGRN is issuing licences for online gaming operations.
The FSGRN waived 2025 licence fees for operators transitioning from the regulatory framework of the National Lottery Regulatory Commission – established under the National Lottery Act – to the FSGRN.
A patchwork of state laws
Odunayo Ibitoye, an associate at Templars Law, also based in Lagos, categorises Nigeria’s 36 states into four units – those that have gambling laws, those with unclear ones, those in which gambling is prohibited and the Federal Capital Territory (FCT) around Abuja, the administrative capital, which does not have legislation to govern the industry.
He cited Abia, Akwa Ibom, Anambra, Bayelsa, Benue, Cross River, Delta, Edo, Ekiti, Enugu, the Federal Capital Territory, Imo, Kaduna, Kogi, Kwara, Lagos, Nasarawa, Niger, Ogun, Ondo, Oyo, Plateau and Rivers as falling in the first category and five – Bauchi, Borno, Jigawa, Yobe and Katsina – as being in the second.
Muslim states which follow Sharia law, especially in the north of the country, do not allow lottery and games of chance. These include Adamawa, Ebonyi, Gombe, Kano (where enforcement practices create practical restrictions despite the existence of revenue provisions), Kebbi, Osun, Sokoto, Taraba and Zamfara.
While the Abuja region does not have a law on gambling, it has an FCT Lottery Regulatory Office (FCT-LRO), which regulates gaming operations in the area. In Abuja, lottery operators are required to obtain a licence from the FCT-LRO before commencing operations.
Has the ruling improved the ease of doing business?
“In our opinion, the judgment appears to be helping state regulators like the Lagos State Lotteries and Gaming Authority maximise the revenue potential of the lottery and gaming sector,” Ibitoye highlights.
“States are now empowered to tailor their regulatory frameworks to local realities and socio-economic contexts, which should enable more effective oversight and revenue collection by respective state tax authorities, such as the Lagos State Internal Revenue Service and Oyo State Internal Revenue Service operating within Lagos and Oyo states, respectively.”
On the ease of doing business, she adds that the FSGRN’s proposed unified structure has the potential to remove duplicative licensing burdens and enhance regulatory coordination. This has created a more coherent and investor-friendly environment.
“However, this implementation is still in its early phases and is currently applicable only to online gaming licences,” she further notes. “This means that offline gaming operations would still encounter duplicative licensing processes depending on the applicable state laws in the jurisdiction of operation.”
Salami adds his voice on how the FSGRN framework is improving the ease of doing business. “Essentially, the FSGRN’s centralised, single-window approach through the URC framework has greatly reduced what could otherwise have been a 36-state licensing nightmare,” he notes.
“The most challenging aspect was operational uncertainty in the period between November 2024 and May 2025 – the months before the FSGRN framework was formalised. During this period, many operators were in a legal grey zone, operating on the basis of their NLRC licences while state regulators were still defining their enforcement posture.”
The religious aspect
However, he observes that the absence of laws in the mainly Muslim north “creates a legal grey zone that poses compliance risks for operators seeking to operate nationally”.
Pew Research Centre, which is based in Washington DC, says Muslims comprised 56.1% of Nigeria’s population as of November 2025. About 43.4% were Christian. Between 2010 and 2020, the country’s Muslim population increased by 32% to 120 million people while its Christian population expanded by 25% to 93 million.
Whereas the FSGRN’s Subnational Reciprocity Framework goes some way to filling this vacuum for online gaming purposes, it does not substitute for enacted state law and cannot bind states that are not members, Salami tells iGB. “In practice, operators are typically advised to conduct careful jurisdiction-by-jurisdiction due diligence before commencing operations in any given state.”
The unresolved issue of online gambling
According to Salami, although the Supreme Court ruling resolved the offline lottery question, the question of online gambling remains unanswered.
“The constitutional position of online and cross-border gaming where a player in Kano accesses a platform licensed in Lagos remains an area of legal nuance,” he tells iGB.
“Each state arguably has jurisdiction over its own residents and can regulate operators targeting those residents. The FSGRN’s URC framework is the pragmatic solution to this, but it does not have the force of statutory law in states that are not members. This creates compliance complexity for operators seeking to achieve genuine nationwide reach.”
