States Move to Define Gambling Rules After Supreme Court Ruling
Eighteen months after Nigeria’s Supreme Court ruled that lotteries and games of chance fall under state rather than federal authority, states across the country are continuing to develop legal frameworks for gambling within their jurisdictions.
In November 2024, the court voided the National Lottery Act and held that state legislative assemblies should regulate gambling activity in their respective areas. The decision settled a case brought by the Lagos state government 16 years earlier over which level of government should oversee the industry in Nigeria’s 36-state federation.
At least 10 states, including Lagos, Delta and Imo, already had relevant laws before the 22 November 2024 ruling and were able to move forward without the uncertainty of dual regulatory regimes. States that did not have laws in place immediately after the decision are still working to introduce them.
An Uneven but Growing State Response
Adewumi Salami, legal director at DLA Piper Africa in Lagos, described the Supreme Court decision as “constitutionally seismic.”
“In terms of state legislative response, the picture is uneven, but there is growing momentum,” he said. “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.”
Salami added that these jurisdictions, particularly Lagos through the Lagos State Lotteries and Gaming Authority (LSLGA), were positioned to exercise exclusive regulatory authority immediately after the ruling.
Among states that acted after the court decision, Osun passed the Lotteries and Gaming Bill into law in November 2024, establishing the Osun State Lotteries and Gaming Board. Anambra is among those that have similarly tabled gaming bills.
A seven-member panel hearing the Lagos case agreed that the National Assembly did not have power to control or regulate lotteries nationwide because “lottery” is a “residual” matter under Nigerian law. Lottery and gambling are therefore not included in the federal administration’s exclusive list of 68 items reserved for national legislation, which covers areas such as defence, security, state creation and banking.
Nigeria’s Gambling Market Landscape
According to H2 Gambling Capital, Nigeria’s gambling industry reached total gross win of nearly $1.6 billion in 2025.
Football betting accounts for the bulk of sports wagering in the football-focused nation, with the English Premier League, UEFA Champions League and some local matches among the main draws.
Brands such as Bet9ja and SportyBet have built large audiences through mobile applications and heavy advertising. However, according to Premium Times on 28 May, football betting is facing growing competition from online casinos.
“With mobile internet becoming cheaper and payment systems improving, players are no longer limited to traditional sportsbook betting alone,” the article stated. “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.”
FSGRN and Reciprocal Licensing
While some states enacted local laws, about 22 others established the Federation of State Gaming Regulators of Nigeria (FSGRN). In May 2025, the body introduced a Subnational Reciprocity Licensing Framework, allowing operators to obtain a single Universal Reciprocity Certificate (URC) valid across 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 former National Lottery Act.
A Patchwork of State Laws
Odunayo Ibitoye, an associate at Templars Law in Lagos, categorises Nigeria’s 36 states into four groups: those with gambling laws, those with unclear frameworks, those where gambling is prohibited, and the Federal Capital Territory (FCT) around Abuja, which lacks dedicated industry legislation.
She cited Abia, Akwa Ibom, Anambra, Bayelsa, Benue, Cross River, Delta, Edo, Ekiti, Enugu, the FCT, Imo, Kaduna, Kogi, Kwara, Lagos, Nasarawa, Niger, Ogun, Ondo, Oyo, Plateau and Rivers in the first category, and Bauchi, Borno, Jigawa, Yobe and Katsina in the second.
Muslim states that follow Sharia law, especially in the north, do not permit lottery and games of chance. These include Adamawa, Ebonyi, Gombe, Kano, Kebbi, Osun, Sokoto, Taraba and Zamfara. In Kano, enforcement practices create practical restrictions despite the existence of revenue provisions.
Although Abuja does not have a gambling law, it operates an FCT Lottery Regulatory Office (FCT-LRO), which regulates gaming activity in the area. Lottery operators in Abuja are required to obtain a licence from the FCT-LRO before commencing operations.
Has the Ruling Improved the Ease of Doing Business?
Ibitoye said the judgment appears to be helping state regulators such as the Lagos State Lotteries and Gaming Authority maximise revenue potential in the lottery and gaming sector.
“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,” she said, citing bodies such as the Lagos State Internal Revenue Service and Oyo State Internal Revenue Service.
On ease of doing business, she added that the FSGRN’s proposed unified structure has the potential to remove duplicative licensing burdens and improve regulatory coordination, creating a more coherent environment for investors.
“However, this implementation is still in its early phases and is currently applicable only to online gaming licences,” she noted. “Offline gaming operations would still encounter duplicative licensing processes depending on the applicable state laws in the jurisdiction of operation.”
Salami said the FSGRN’s centralised single-window approach through the URC framework has greatly reduced what could otherwise have been a 36-state licensing challenge.
He added that the most difficult period was the operational uncertainty between November 2024 and May 2025, before the FSGRN framework was formalised. During that time, many operators remained in a legal grey zone, operating on National Lottery Regulatory Commission licences while state regulators were still defining enforcement positions.
Religious and Regional Complications
Salami observed that the absence of laws in mainly Muslim northern states “creates a legal grey zone that poses compliance risks for operators seeking to operate nationally.”
According to Pew Research Centre, Muslims comprised 56.1% of Nigeria’s population as of November 2025, while about 43.4% were Christian. Between 2010 and 2020, the Muslim population increased by 32% to 120 million people, while the Christian population grew by 25% to 93 million.
While the FSGRN’s Subnational Reciprocity Framework helps address the gap for online gaming, it does not substitute for enacted state law and cannot bind non-member states. Salami said operators are typically advised to conduct careful jurisdiction-by-jurisdiction due diligence before commencing operations in any given state.
Online Gambling Remains Unresolved
Salami said that although the Supreme Court ruling resolved the offline lottery question, the position of online gambling remains less clear.
“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 said.
“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.”