Nigeria's Post-Ruling Regulatory Maze: One Market, 37 Rulebooks

A New Era of Fragmentation

Nigeria, home to an estimated 60 million sports bettors and roughly 242.2 million people, has long been Africa’s largest betting market. But the regulatory landscape shifted dramatically after the Supreme Court’s November 2024 decision stripped the National Lottery Regulatory Commission (NLRC) of its nationwide authority, placing gambling oversight firmly in the hands of individual states. Operators that once secured a single federal licence now face 37 separate jurisdictions (36 states plus the Federal Capital Territory), each with its own rules, fees and compliance demands.

Industry data underscores both the scale and the regulatory gap. According to Gaming Compliance International, Africa’s online gambling market generated US$23 billion in revenue during 2025, yet only US$5.2 billion flowed through licensed operators. Nigeria recorded the lowest proportion of unregulated activity in West Africa at 56%, against a regional average of 69%, pointing to a still-substantial grey market.

The Reciprocity Workaround

In response to the fragmentation, the newly formed Federation of State Gaming Regulators of Nigeria (FSGRN) – now with over 20 member states – launched a Subnational Reciprocity Licensing Framework in May 2025. Its Universal Reciprocity Certificate allows an operator to apply once and operate across all participating states. However, this is a voluntary arrangement, not a legal mandate, and tensions persist.

“Since 2024, while it brought clarity to the industry, it also created a lot of fragmentation issues that we needed to address,” said Fisayo Oke, CEO of Gamble Alert and former Head of Operations at the Oyo State Gaming Board. He noted that only about six to eight states have robust regulatory structures in place. Oke added that the fragmentation has not deterred investment, as operators weigh Nigeria’s youthful population and long-term opportunity against the regulatory complexity.

Adewumi Salami, legal director at DLA Piper Africa in Lagos, described the period between November 2024 and May 2025 as one of “operational uncertainty,” when many firms relied on expired NLRC paperwork while states determined how to enforce their new authority.

Revenue, Tax and Enforcement Challenges

Financial disputes have also surfaced. Lagos State, which hosts most industry headquarters, has argued for a larger share of the pooled licensing fees. Meanwhile, northern states that previously collected as little as ₦500,000 (approximately £242 or US$327) annually are now guaranteed a portion simply for joining the reciprocity framework.

The FSGRN proposed a flat 11% gross gaming revenue tax and a withholding tax on player winnings. Bet9ja’s Head of Legal and Compliance, Adewale Akande, objected, arguing that requiring punters’ tax identification numbers breaches privacy terms and that the tax would ultimately harm the states it is meant to fund. FSGRN President Bashir Are acknowledged these concerns, suggesting that tax might only apply to winnings exceeding ₦5 million or even ₦10 million, rather than every payout.

Player protection remains uneven. Lagos operates SafePlay, a system that flags self-excluded players across all licensed operators in the state instantly. But “the day I travel to Ibadan, I can do all I want,” Oke noted, highlighting the lack of cross-state exclusion mechanisms. He added that enforcement capacity is thin, with some state gaming boards covering dozens of local government areas with only a handful of staff and limited travel budgets.

Regional Comparisons and Lessons

Nigeria is not alone in facing regulatory fragmentation. John Mutua, CEO of the Association of Gaming Operators Kenya, pointed to Kenya’s split oversight across five separate bodies, describing a setup with “no single owner accountable for the whole.” He urged regulators to build institutions before markets outgrow them.

Robin Bennett, head of compliance at the Western Cape Gambling and Racing Board, emphasised that effective regulation rests on “clarity, certainty and consistency,” backed by practical enforcement. Musa Mngadi of the African Lotteries and Gaming Association cautioned against measuring regulatory success solely by gross gaming revenue.

The Unsettled Question

Despite the upheaval, Nigeria’s betting industry continues to grow. Local brands such as SportyBet, Bet9ja and BetKing account for over 86% of branded demand, demonstrating the resilience of domestic operators. International entrants, meanwhile, remain less dominant, suggesting that mastering the regulatory terrain is as important as customer acquisition.

The Supreme Court may have resolved the constitutional question of jurisdiction, but the industry now faces a deeper challenge: can dozens of state regulators convince operators that they are still operating in one unified market rather than 37 separate ones?