The Lagos State Lotteries and Gaming Authority (LSLGA), acting under the powers granted by the Lagos State Lotteries and Gaming Authority Law 2021 (“the Law”), has issued a public notice to telecommunications operators, mobile network operators (MNOs), licensed value-added service (VAS) aggregators, and VAS providers facilitating lottery, betting, and gaming services in Lagos State. This directive stems from the landmark Supreme Court judgment in Attorney-General of Lagos State & 22 Ors v. Attorney-General of the Federation & 13 Ors (2025) 5 NWLR (Pt. 1984) 43, which affirmed that lotteries, betting, and gaming are residual matters under the exclusive legislative competence of states, except in the Federal Capital Territory. The judgment empowers Lagos State to regulate gaming activities within its jurisdiction, and the circular marks a decisive step in implementing that authority.
The notice requires all telecommunications operators, MNOs, VAS aggregators, and VAS providers facilitating lottery, betting, and gaming services in Lagos State to immediately comply with Lagos State licensing and tax regulations.
- LICENSING OBLIGATIONS OF MNOS, VAS AGGREGATORS AND VAS PROVIDERS FACILITATING LOTTERY, BETTING AND GAMING SERVICES IN LAGOS STATE
The LSLGA clarified that approval from the Nigerian Communications Commission (NCC) does not constitute a gaming licence. While telecommunications operators and VAS providers may obtain approval from the NCC to operate their platforms, such approvals do not extend to the regulation of gaming activities. Any entity facilitating gaming services through USSD codes, SMS platforms, mobile applications, or other telecommunications channels must obtain a valid license from the LSLGA. This clarification is critical because it eliminates any ambiguity regarding the scope of regulatory authority and reinforces the state’s jurisdiction over gaming activities, in line with the Supreme Court’s pronouncement.
The notice underscores the Authority’s commitment to operational oversight. LSLGA will actively monitor activities across telecommunications platforms to ensure that gaming services are facilitated lawfully. This monitoring extends to the verification of licenses, the tracking of tax payments, and the enforcement of compliance with the Law.
- RECOVERY OF TAX ARREARS
In addition to licensing, operators must settle outstanding tax arrears and ensure ongoing compliance with statutory obligations. The notice requires all gaming operators that have offered services in Lagos State through telecom or VAS channels to remit taxes, levies, and other fiscal obligations due from 22nd November 2024 to the date of the notice (“the Arrears Period”).
Outstanding liabilities for the Arrears Period shall be assessed by the Authority on the basis of verified transaction and revenue data, together with such penalties and interest as are applicable under the Law.
This requirement is not merely administrative; it is a fundamental aspect of ensuring that gaming activities contribute to the state’s revenue base and that operators act responsibly within the legal framework. By insisting on tax compliance, the Authority is signaling its determination to close loopholes that have historically allowed some operators to evade their fiscal responsibilities.
- 30 DAYS NOTICE FOR COMPLIANCE WITH THE REQUIREMENTS
According to the notice, operators have 30 days to comply with the outlined requirements. Within this period, MNOs, VAS aggregators, and VAS providers must:
- Verify with the Authority the licencing and gaming tax compliance status of every gaming operator utilising their platforms to offer services within Lagos State;
- Provide the Authority with transaction, carrier-billing and revenue-share records for every gaming operator or gaming service hosted on their platforms during the Arrears Period, to enable the assessment of outstanding liabilities;
- Cease onboarding any gaming operator that cannot evidence a valid licence or authorization issued or recognized by the Authority; and
- Suspend facilitation of any existing gaming service that is not so licensed or authorized.
This grace period is intended to give stakeholders sufficient time to regularise their operations, obtain the necessary licences, and settle outstanding tax obligations.
- EFFECT OF NON-COMPLIANCE, OFFENCES, LIABILITIES AND PENALTIES
The Authority has warned that non-compliance constitutes an offence under Section 33(3) and Section 101(f) of the Lagos State Lotteries and Gaming Authority Law 2021 (“the Law”), and violators will face sanctions ranging from suspension of operations to liability for tax recovery.
Section 33(3) of the Law, provides that a person without a subsisting licence or authorization from the Authority shall not operate, conduct or deploy any equipment, manage or accept wagers, rent a property, employ any person or make advertisements for any gaming activity in Lagos State.
Section 101(5) of the Law, provides that where an offence committed by a company is proved to have been committed with the consent or connivance of, or to be attributable to the neglect of, a director, manager, secretary or other principal officer of the company, that officer, as well as the company, shall be deemed to be guilty of the offence and shall be liable to be proceeded against and punished accordingly.
LSLGA has stated clearly that they would not hesitate to impose sanctions on defaulting operators. Enforcement measures include:
- Suspension of Services: Telecoms and VAS platforms found facilitating unlicensed gaming will be ordered to suspend such services immediately.
- Tax Recovery Actions: The Authority will initiate recovery proceedings to collect outstanding taxes, levies, and penalties from operators who fail to remit dues. This may involve audits, demands for payment, and legal enforcement.
- Criminal Liability: Where offences are attributable to the actions or neglect of company officers, those individuals will be held personally liable. This ensures accountability at both corporate and managerial levels.
- Prosecution and Penalties: Offenders may face prosecution under the Law, with penalties ranging from fines to imprisonment, depending on the gravity of the offence.
Directors and officers of telecom operators, VAS aggregators, and VAS providers are therefore urged to exercise due diligence to prevent unlawful gaming activities on their platforms.
For stakeholders, the effect of the notice is significant. Telecommunications operators and VAS providers must align their operations with the licensing framework established by LSLGA and ensure that they are fully compliant with tax obligations to Lagos State.
In conclusion, the LSLGA notice, grounded in the Supreme Court’s landmark judgment, represents a decisive step in strengthening governance within Lagos State’s gaming ecosystem. By clarifying the scope of licensing authority, enforcing tax compliance, providing a 30-day compliance window, and outlining sanctions for violations, the Authority is reinforcing its role as the primary regulator of gaming activities in the state. Stakeholders are advised to promptly regularise their operations to avoid enforcement actions, as the era of lax compliance in the gaming sector has clearly come to an end.
