HOW TO OBTAIN B2B GAMING LICENCE IN LAGOS STATE

The Lagos State Government has stepped up its game on the licensing and regulation of lottery and gaming activities within its territory following the recent Supreme Court’s decision in Attorney-General of Lagos v. Attorney-General of the Federation & Ors. (2025) 5 NWLR (Pt. 1984) 43, in which the apex court held that the Federal Government of Nigeria lacks the powers to regulate lotteries activities in Nigeria and that such regulation is within the powers of the subnational states.

Lagos State is open for online gaming business promising huge potentials for investors in terms of population, internet penetration and other technological infrastructure.

One of the categories of licence for gaming operations is the Business to Business Licence (B2B). The B2B licence was created to accommodate providers of comprehensive platform solutions to sports betting, lottery, casino and related games in the Lagos gaming industry. The B2B license covers all aspects of the gaming transactions, including companies providing support services to the games and betting activities. These businesses are required to apply to Lagos State Lottery and Gaming Authority’s (“LSLGA”) for B2B license.

WHO SHOULD APPLY FOR A B2B GAMING LICENCE?

Any Organization offering the following services should request a B2B Gaming licence from the LSLGA:

• Manufacturing, assembling, placing on the market, distributing, supplying, selling, leasing, or transferring a gaming device;
• Providing risk management services for the operation of a licensable game;
• Providing event content and, or adds;
• Providing fraud management services for the operation of a licensable game;
• Holding and, or managing player funds;
• Providing services relating to customer due diligence;
• Providing services related to player identity verification;
• Providing co-location services and other managed information technology services, including cloud computing services and, or decentralized hosting protocols where the latter do not amount to a critical gaming supply; and
• Providing back up and disaster recovery services.

THE REQUIREMENTS FOR OBTAINING B2B GAMING LICENCE?

The requirements for obtaining B2B gaming licence are as follows:

1. An application Letter to the LSLGA
2. Non-refundable application fee of N1,000,000.00 (One Million Naira)
3. Documentary evidence of company incorporation & Registration which includes: Certificate of Incorporation, Memorandum & Article of Incorporation and Status Report showing a minimum share capital of 20,000,000.00, details of the directors, and shareholders
4. Detailed Business plan/proposal on the online sports betting scheme. The proposal should provide information on the following: Business Structure, including Address of Registered Office, Branches and Planned locations, Names and Profile of Directors, Marketing Distribution Plan,
5. Proof of tax registration or exemption & incentives (as the case may be);
6. Evidence of trademark registration & brand protection;
7. Tax Clearance Certificate of Directors for the last 3years preceding the date of application for B2B licence;
8. Description of Operations and Management Structure;
9. Details of proposed solution/product(s)
10. Financial information/projections detailing the management account of your organisation, the company’s bank statement for the last one (1)year in support of financing plan, Five years projected profit and Loss Account, Balance Sheet, Cash Flow analysis- this should provide for the annual licence fee and monthly, the nature and extent of financing and capital investment, indicating if foreign investment is involved in the business and if any, terms of investment, the capital budgets showing set up cost and asset schedule over 5years.

Please note that the licence fee is (5,000,000.00 (Five Million Naira) per annum.

11. Technical Information, which includes:

1. Detailed information of technical partners/providers specifying the services rendered with supporting documents.
2. Contracts and Service Level Agreements (SLA) documents between applicant and all 3^rd party contractors e.g.. gaming platform provider; data hosting company.
3. Detailed information on proposed technical topography including a schematic diagram clearly illustrating the technical operational flow.
4. Proposed platform-self host or cloud based; if cloud based, the contract information of the hosting company.
5. Detailed information of Hardware (server, firewall, routers, redundancy implementation).
6. Detailed information of software (operating systems/Database applications specifications).
7. Back up Policy and Business Continuity Policy
8. Data Protection and Recovery Policy
9. Processes and system Quality Issuance.
10. Copy of products/platform certifications from a certified laboratory and/or certification body for the services rendered.

NOTE:

• LSLGA requires a minimum of 15 working days to conduct due diligence on every application. In practice however it takes about a month before receiving any approval;
• As part of the application process, the applicant will be required to make a presentation before LSLGA with regard to its proposed products and services;
• Where the applicant satisfactorily fulfills the pre-approval requirements, an Approval in Principle (AIP) will be granted. This AIP is valid for 90days.
• The AIP is a temporary licence: a Final Licence will only be issued on fulfillment of ALL conditions highlighted in the AIP.