Nigeria’s Post-Supreme Court Gambling Landscape Evolves Amid Regulatory Progress and Regional Uncertainty

Nigeria’s gambling sector continues to undergo significant transformation nearly eighteen months after a landmark ruling by the Supreme Court fundamentally altered the regulatory structure governing lotteries and games of chance across the country. The decision, delivered in November 2024, transferred regulatory authority from the federal government to individual state governments, triggering a wave of legislative and administrative activity as states move to establish or strengthen their own gambling frameworks.

The judgment struck down the National Lottery Act and clarified that responsibility for regulating gambling activities rests with state governments rather than federal authorities. The ruling concluded a legal dispute that had originated sixteen years earlier when the Lagos State Government sought judicial clarification regarding which level of government possessed constitutional authority over gambling regulation within Nigeria’s federal system of thirty-six states.

For several states, including Lagos, Delta, and Imo, the decision largely removed longstanding regulatory uncertainty because local gambling laws were already in place before the court delivered its verdict on 22 November 2024. These jurisdictions were therefore able to continue operating under existing frameworks without the complications associated with overlapping federal and state oversight. However, many states that lacked dedicated legislation at the time of the ruling have since been working to develop their own legal structures.

Commenting on the significance of the judgment, Adewumi Salami, legal director at DLA Piper Africa in Lagos, described the ruling’s constitutional implications in striking terms. “The Supreme Court’s decision was constitutionally seismic,” Salami told iGB.

He noted that the response from state legislatures has varied considerably but emphasized that momentum toward state-level regulation continues to build. “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.

Among the states that moved swiftly after the court decision was Osun State, which enacted the Lotteries and Gaming Bill in November 2024. The legislation established the Osun State Lotteries and Gaming Board and created a formal framework for regulating gambling activities within the state. Anambra State has similarly advanced its own Gaming Bill as part of broader efforts to establish state-level oversight.

The Supreme Court’s seven-member panel unanimously agreed with the arguments presented by Lagos State, concluding that the National Assembly lacked constitutional authority to regulate lotteries nationwide because gambling and lottery activities are categorized as residual matters under Nigerian law. As residual matters, lotteries and gambling do not appear among the sixty-eight subjects reserved exclusively for federal legislative authority. Areas such as defense, national security, banking, and the creation of states remain under federal jurisdiction, while gambling regulation now falls squarely within state control.

Despite the regulatory transition, Nigeria’s gambling market continues to expand rapidly. Data from H2 Gambling Capital indicates that the country’s gambling industry generated nearly $1.6 billion in gross gaming revenue during 2025. Sports betting remains the dominant segment of the market, driven primarily by widespread interest in football. Nigerian bettors continue to focus heavily on competitions such as the English Premier League, which features several Nigerian players, as well as the UEFA Champions League and domestic football matches.

Major operators including Bet9ja and SportyBet have built extensive customer bases through mobile technology and aggressive marketing campaigns. However, emerging trends suggest that online casino gaming is beginning to challenge the dominance of sports betting. Reporting by Premium Times on 28 May highlighted the growing popularity of casino products among Nigerian players.

The publication observed, “With mobile internet becoming cheaper and payment systems improving, players are no longer limited to traditional sportsbook betting alone. 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.”

While some states focused on developing local regulatory systems, approximately twenty-two states joined together to form the Federation of State Gaming Regulators of Nigeria (FSGRN). In May 2025, the organization introduced the Subnational Reciprocity Licensing Framework, an initiative designed to simplify regulatory compliance across participating jurisdictions. Under this framework, operators can obtain a Universal Reciprocity Certificate (URC), a single license recognized by all member states of the FSGRN. At present, the framework applies specifically to online gaming activities.

To facilitate the transition from the previous federal regulatory system administered by the National Lottery Regulatory Commission, the FSGRN waived licensing fees for 2025 for operators migrating from the former regime to the new state-based framework.

Despite these developments, Nigeria’s regulatory landscape remains highly fragmented. Odunayo Ibitoye, an associate at Templars Law in Lagos, categorizes the country’s states into four distinct groups based on their approach to gambling regulation. The first category includes states with established gambling laws. According to Ibitoye, these jurisdictions include 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.

A second category consists of states where the legal position remains unclear, including Bauchi, Borno, Jigawa, Yobe, and Katsina. The third group comprises states where gambling is prohibited, largely reflecting the influence of Islamic law in northern Nigeria. These states include Adamawa, Ebonyi, Gombe, Kano, Kebbi, Osun, Sokoto, Taraba, and Zamfara. In some areas, particularly Kano, enforcement practices create practical barriers to gambling operations despite the existence of certain revenue-related provisions.

The Federal Capital Territory occupies a unique position. Although Abuja lacks a comprehensive gambling statute, gaming activities are regulated through the Federal Capital Territory Lottery Regulatory Office (FCT-LRO). Operators wishing to conduct lottery or gaming activities within the territory must obtain licenses from the FCT-LRO before commencing operations.

The shift toward state-based regulation has generated debate regarding its impact on business conditions within the industry. Ibitoye believes the Supreme Court’s ruling has strengthened the ability of state regulators to maximize economic opportunities within the sector.

“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.

She explained that the new framework allows states to create regulatory structures tailored to local conditions. “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.”

Ibitoye also expressed optimism regarding the FSGRN’s efforts to streamline licensing requirements. She argued that the reciprocity framework could reduce duplication, improve regulatory coordination, and foster a more attractive environment for investors.

“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 similarly praised the role of the FSGRN framework in reducing administrative burdens. “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.

He pointed out that uncertainty was particularly acute during the months immediately following the Supreme Court judgment and before the FSGRN formally launched its framework. “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.”

Religious considerations continue to complicate the regulatory landscape. According to Salami, the absence of formal gambling legislation in many predominantly Muslim northern states has created significant compliance challenges for operators seeking nationwide coverage.

Data from the Pew Research Center indicates that Muslims represented 56.1% of Nigeria’s population as of November 2025, while Christians accounted for approximately 43.4%. Between 2010 and 2020, Nigeria’s Muslim population increased by 32%, reaching roughly 120 million people, while the Christian population grew by 25% to approximately 93 million.

Salami noted that while the FSGRN’s reciprocity framework helps address certain regulatory gaps for online gaming, it cannot replace state legislation or impose obligations on jurisdictions that choose not to participate. “In practice, operators are typically advised to conduct careful jurisdiction-by-jurisdiction due diligence before commencing operations in any given state,” he told iGB.

One of the most significant unresolved issues concerns the regulation of online gambling across state boundaries. According to Salami, the Supreme Court’s ruling resolved questions surrounding traditional lottery regulation but left important constitutional questions unanswered regarding internet-based gaming.

“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.

He explained that states may claim authority over gambling activity involving their residents, even when the operator is licensed elsewhere. “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.”

As Nigeria’s gambling sector continues its transition toward a decentralized regulatory model, operators, regulators, and lawmakers are navigating a rapidly evolving environment shaped by constitutional change, economic opportunity, regional differences, religious considerations, and unresolved questions surrounding digital gaming. While substantial progress has been made since the Supreme Court’s landmark ruling, the path toward a fully harmonized national market remains a work in progress.

By fLEXI tEAM