Sports betting is one of the categories of permissible lotteries in Nigeria under the National Lottery Act 2005 (“NLA 2005”) which applies to the Federal Capital Territory Abuja and, of course, each State has its own law regulating sports betting activities within each State (e.g. the Lagos State Lotteries (Amendment) Law 2008 (“LSLL 2008”) for those seeking to operate in Lagos).
There was a long jurisdictional contest between Federal Government of Nigeria and the Lagos State Government over who has constitutional powers to regulate and oversee lotteries operators in Lagos State. That contest has now been resolved by the Supreme Court 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.
Effective from 2025, the Federal Licence granted by the National Lottery Regulatory Commission (“NLRC”) is only applicable to the Federal Capital Territory and no longer apply across the country as was the case before the judgment of the supreme court in Attorney-General of Lagos v. Attorney-General of the Federation & Ors. (2025) 5 NWLR (Pt. 1984) 43.
Whilst the NLA 2005 deals with national license for operation of lottery business within Abuja, the LSLL 2004 regulates all lottery businesses operating within Lagos State (see https://lslb.lg.gov.ng/rejoinderresponse-national-lottery-regulatory-commissions-publication/ in which Lagos State Lottery And Gaming Authority’s (“LSLGA”) has regained its constitutional mandate to regulate and oversee all online sports betting operators within Lagos State.
So, a prospective sports betting company seeking to operate in Lagos no longer requires the Federal licence. Only licence of the LSLGA, which is an agency of the Lagos State Government, is required to operate sports betting in Lagos.
This article is about the federal licence required to operate sports betting business within the Federal Capital Territory, Abuja. You can also read about the Lagos Sports Betting Licence here.
Procedure for Setting up a Sports Betting Company in Lagos
1. Incorporation of the Sports Betting Company with CAC: A prospective sports betting company in Abuja is required to be incorporated by the CAC. But before the incorporation, the applicants would need to obtain the AIP from the NLRC, which is a precondition for incorporation.
(i) Incorporation Requirements: A sports betting company must have a minimum of paid up share capital of 30,000,000 fully subscribed by the shareholders (although the LSLGA requires a lesser share capital of 20,000,000, it is advisable to register the company with 30 million share capital). The other requirements for the registration include:
- Two (2) proposed names for the sports betting company,
- The proposed registered address of the company: this may be virtual address. At Koriat & Co., we offer our offices as virtual address for client’s use as registered address and mailing purposes;
- E-mail of the sports betting company,
- Particulars of subscribers/shareholders, directors and company secretary: the names, particulars, curriculum vitae, government-issued means of identification and specimen of signatures of the subscribers/shareholders, the directors and the company secretary (Koriat & Co. offers support services as company secretary); and the number of shares to be allotted to each shareholder.
Please note that persons below the age of 18 years or persons holding public office or working in the civil service are prohibited from being directors of a sports betting company. Public officers or civil servants cannot be shareholders of sports betting company in Nigeria.
Please note also that directors and shareholders can hide their personal information from the public members who may later conduct search into the company using the CAC online portal. This costs N25,000 (about US$50) per person.
Finally, please note that where a foreigner with a Nigerian address is a director, proof of his or her Combined Expatriate Residence Permit and aliens Card (CERPAC) must be uploaded into the CAC portal. CERPAC is obtained from the Nigerian Immigration Service (NIS) for $2000.
(ii) Incorporation Costs: The registration cost/expense is (about US$1000). The foregoing entails the CAC Registration Fee, Stamp duty payable on the N30 million share capital at 0.75% (charged by the Federal Inland Revenue Service).
As already stated above, where a foreigner with a Nigerian address is a director, a CERPAC card obtainable at $2,000 must be uploaded into the CAC portal.
Please note, also, that if the directors and shareholders desire to hide their personal information (other than names) from the public record, then each of the interested person will pay N25,000 (about US$50).
2. Application for AIP to Set up a Sports Betting Company from the NLRC: the promoters are expected to apply to the NLRC for AIP immediately the company’s name has been reserved with the CAC but where the company has already been registered, different considerations apply.
(i) Application for AIP to NLRC By a New Company: Where the applicant company is a new company, an AIP must be sought and obtained from the NLRC before completing its incorporation with CAC. The requirements for application for AIP to the NLRC are as follows:
(a) A duly completed application form in capital letters (except the signature and email address);
(b) An application letter stating the intention of the applicant and seeking approval to register a sports betting company, addressed to the Director General of NLRC, Plot 640, Cadastral Zone B4, Musa Yar’Adua Way, Jabi District, FCT, Abuja, Nigeria;
(c) Copy of Name Reservation Approval issued by the CAC;
(d) Proof of payment of Application fee in favour of the NLRC through Remita platform; and
(e) A business proposal or feasibility study report detailing the general business information, operational information, financial information and technical information, covering specifically the following:
- The proposed sports betting game events (live betting, sports book, virtual games and so on) and comprehensive modalities for each game events;
- The proposed investment in the sports betting scheme;
- The address of administrative office and locations across Nigeria;
- Source of funding and financial plans (equity, foreign investment, loans and applicable terms of investment);
- Five (5) year financial projection for the betting scheme (profit and loss account showing investment, sales/income, winnings/prize money, tax obligation, operating expenses, third party suppliers, etc.);
- Details of technical and payment solution providers, partners, telecoms providers and suppliers (web developer, odds providers, virtual providers, if applicable, hosting providers (whether self-hosting or cloud hosting), database/back up service providers, manufacturer of hardware and software technologies, servers, decoders and terminals, etc.);
- Security system (information on types, cloud, firewalls, routers and security features, redundancy implementation (where applicable);
- Documentation on process and system quality assurance;
- Architectural representation of technical operation flow for the sports betting scheme;
- Software certification from approved and recognized testing labs;
- Proposed brand, colour or logo;
- Proposed Organizational Structure.
(f) Proposed Service Level Agreement, Partnership/Joint Venture with providers and suppliers. Please note that all third-party agreements/contracts will be subject to the NLRC’s approval.
(ii) Costs of the NLRC’s AIP: The NLRC charges N10,000 (about US$20) to process the AIP. The cost of the Feasibility Study Report is about US$2,000. Other costs are associated with the drafting of the proposed service level agreement, partnership/joint venture agreement and virtual office address, if necessary.
Upon the receipt of the above, the NLRC may invite the applicants to make presentation to the NLRC. Thereafter, a review of the application will be done by the NLRC, usually for about 10 working days. Thereafter, the NLRC may grant an AIP with which the applicant company is expected to complete its incorporation at the CAC.
(iii) Application for AIP: upon incorporation of the sports betting company by the CAC, an application for provisional approval is then made to the NLRC. The grant of the provisional approval is subject to the following conditions:
(a.) Payment of Application Fee for Sports Betting of N2,000,000 (US$4,000);
(b.) Payment of Permit Fee of N50,000,000 (US$100,000) for five (5) years.
(c.) Bank guarantee of at least N25,000,000 (about $50,000) of not less than 1-year validity;
(d.) Submission of incorporation documents (certificate of incorporation, CAC Application Form 1.1 or other CAC Form showing the list and particulars of shareholders and directors);
(e.) Evidence of trademark registration (if any) with the Federal Ministry of Trade and Investment;
(f.) Satisfactory inspection of the company’s technical and operational facilities including administrative office and data center(s);
(g.) Connection to the NLRC’s monitoring and reporting platform;
(h.) Website advert materials (if any) in hard and soft copy including picture frame of the sports betting company’s trade name or logo (Frame size is 16/12);
(i.) Companies with foreign shareholders and directors are required to provide business quota, residence/work permit issued by the Nigerian Immigration Service (“NIS”);
(j.) Investment certificate from Nigerian Investment Promotions Commission (“NIPC”);
(k.) Execution of Terms and Conditions of operation of Sports Betting;
(l.) Copies of duly executed Service Level Agreement with third-party providers;
(m.) Signed undertaking from all technical providers;
(n.) Evidence of domain name registration with (.ng);
(o.) Evidence of registration with the Special Control Unit on Money Laundering (SCUML);
(p.) Profiles, addresses, phone numbers, occupation, nationality of all Directors, shareholders and key personnel (with their respective means of identification, qualifications and relevant gaming industry experiences) including Company Secretary, Compliance Officer, Accountant, ICT Manager, Operations Manager, Agency Manager(s) and Customer Care Manager;
(q.) Evidence of tax payment of the directors and key management staff for the preceding year (for existing company, not for newly incorporated company);
(r.) Copy of the Organogram;
(s.) Evidence of filing Annual Returns to date with the CAC (for existing company only, not for newly incorporated company);
(t.) Contact details of key personnel in charge of the sports betting game;
Please Note: Applicants will be notified of the status (approved or rejected) of the application at the end of the review period. Successful applicants will proceed to the licensing stage with the issuance of a Provisional Approval. A Provisional Approval, if granted, will last for 90 days during which the above conditions stated therein must be fulfilled.
(iv) Inspection by the NLRC: NLRC delegates will conduct inspection of the applicant’s facilities –server centre, providers, head office, model outlets— to ensure compliance with approved standards in sports betting. During the approval period, the applicant may be required to submit additional documents in support of the proposed sports betting operation, fulfil inspection requirements and pay statutory fee(s) in part or full.
(v) Final License: Whenever the sports betting company has fulfilled the conditions for the AIP, a letter should be addressed to the NLRC advising the Commission of the compliance and seeking the grant of the final license. Final License is issued by the NLRC upon confirmation that the conditions of the AIP have been fulfilled as well as the applicants’ proof of following:
- Evidence of the sports betting company’s connection to the NLRC transaction reporting and monitoring platform within 14 days of commencing business;
- Payment of 5% of monthly gross proceeds on or before the 5th day of the succeeding month as follows: (i) 2% of gross proceeds as administration & monitoring fee payable to the NLRC, (ii) 3% of gross proceeds payable to the National Lottery Trust Fund;
- Submission of monthly reconciliation log or report on transactions in the approved format; and
- Satisfactory system audit by the NLRC, usually on a quarterly basis.
The NLRC will upload the names and contact details of the successful applicants on the NLRC’s website. Sports Betting companies are not allowed to modify or alter or amend the particulars or modalities of an approved sports betting scheme without prior approval of the NLRC.
Also, you can read about the Lagos Sports Betting Licence here.
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The above article is for information only and NOT as legal advice. Interested applicants who require clarification or seek guidance on the process of incorporating and processing sports betting license in Nigeria may contact Koriat & Co. at 3rd 191, Igbosere Road, Lagos Island, Lagos or via Email admin@koriatlaw.com or Telephone: 09067842241.
