Lagos State Issues 30-Day Compliance Directive to Telecoms and VAS Operators on Gaming Services
The Lagos State Lotteries and Gaming Authority (LSLGA) has issued a public notice requiring all telecommunications operators and licensed Value-Added Service (VAS) aggregators operating in Lagos State to comply with its requirements within 30 days.
Following the landmark Supreme Court ruling delivered on 22 November 2024 in Attorney-General of Lagos State & Ors. v. Attorney-General of the Federation & Ors. (Suit No. SC/1/2008), which affirmed that lotteries and games of chance fall within the residual legislative competence of individual states, the Lagos State Lotteries and Gaming Authority (LSLGA) issued a public notice under the Lagos State Lotteries and Gaming Authority Law 2021.
The directive mandates that all Telecommunication Operators, Mobile Network Operators (MNOs), licensed Value-Added Service (VAS) aggregators, and VAS providers facilitating lottery, betting, or gaming activities within Lagos State must immediately align with state licensing and tax regulations.
The LSLGA highlighted that federal permits issued by the Nigerian Communications Commission (NCC) for telecommunications or VAS activities do not constitute a licence or authorization to offer, conduct, or facilitate gaming and betting activities in Lagos State. Furthermore, employing an intermediary, such as an MNO, VAS provider, payment channel, or carrier-billing engine, does not exempt the underlying gaming operator from being fully licensed and regulated by the Authority.
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All mobile network operators (MNOs), value-added service (VAS) aggregators and service providers have thirty days from the date the notice is issued to complete the required compliance measures. They must verify directly with the Lagos State Lotteries and Gaming Authority (LSLGA) the licensing and tax-compliance status of every gaming operator using their platforms in Lagos State and submit comprehensive transaction, carrier-billing, and revenue-sharing records for all hosted operators covering the “Arrears Period”, from 22 November 2024 to the date of the notice, to support accurate tax assessments.
They must also stop onboarding any gaming operator unable to provide evidence of a valid licence or authorization issued or recognized by the Authority, and immediately suspend the facilitation of services for any existing operator conducting gaming activities without an LSLGA licence.
All gaming operators and facilitating tech platforms must account for and remit all statutory financial obligations under the Law, including statutory licence fees, gaming taxes, statutory levies, and the Good Causes Levy. Every gaming operator that offered services in Lagos State via telecom or VAS channels must settle all uncollected taxes and levies due for the Arrears Period. Outstanding liabilities will be formally assessed by the Authority based on verified transaction and revenue data, subject to applicable statutory penalties and interest.
Non-compliance carries severe legal consequences under the Lagos State Lotteries and Gaming Authority Law 2021:
- Section 33(3): Operating or facilitating unauthorized gaming, including operating gaming equipment, accepting wagers, renting premises, employing staff, or advertising such services, constitutes a statutory offence.
- Section 101(5): Where a corporate offence is committed with the consent, connivance, or neglect of a director, manager, secretary, or other principal officer, that individual may be held personally liable alongside the company and face criminal prosecution.
Directors and principal officers are explicitly advised to exercise strict corporate due diligence to ensure their network infrastructure is not knowingly or negligently utilized for unlawful gaming. Upon the expiration of the 30-day compliance window, the LSLGA will issue statutory enforcement notices and pursue full legal and regulatory remedies against non-compliant operators and facilitating intermediaries.
