FSGRN member states sign Subnational Reciprocity Licensing Framework
On 7 May 2025, delegates from the Federation of State Gaming Regulators of Nigeria (FSGRN) attended the meeting intending to sign the Subnational Reciprocity Licensing Framework at the Radisson Hotel in Lagos. The agreement eliminates licensing fragmentation for online sports betting, online casinos, public online lotteries, and promotional competitions. Not only does the framework simplify procedures, but it also enhances regulation and consumer protection and fosters investment within the region.
As the narrative document states:
“Each participant state is offered a unified system of licensing, which provides both flexibility and stability for investors. Steps towards protecting the consumers and regulating the market effectively are taken as well.”
Signing in Lagos
The signing session was indeed a historic moment for Nigeria’s gaming regulation. Until now, operators seeking to conduct business within several states simultaneously were burdened with multiple applications, examinations, licences, fees, and compliance regimes for each state. Now, under the new framework, they will receive a Universal Reciprocity Certificate (URC), which covers all member states. “One Licence covers all member states,” is what the declared at the event. This slogan highlights the primary purpose of the framework, which is to reduce the duplicate licensing burden while enhancing regulatory coordination.
Unified licensing system
The URC applies to four categories of gaming activity:
1. Online Sports Betting
2. Online Casino
3. Public Online Lottery
4. Promotional Competitions
Operators will submit one application to the Secretariat of the FSGRN, providing standardised documentation, compliance declarations, and proof of financial standing. Once granted, the URC allows seamless market access across all member states without additional state-level permits. By harmonising reporting protocols and compliance audits, the framework reduces administrative costs and promotes transparency.
Transitional measures and fee waiver
To allow transition from the current licences, the FSGRN instructed that all operators already licensed by the former National Lottery Regulatory Commission (NLRC) or by states in their own right must apply for the URC. In recognition of past regulatory disruption, the FSGRN declared a complete waiver of 2025 licence fees for NLRC-licenced operators, subject to the fulfilment of the new requirements. These operators will instead be required to renew and pay necessary licence fees beginning 1 January 2026. This relief provision promotes business continuity and compliance with the new standards.
Regulators’ reactions
At the ceremony, the Chairman of the FSGRN and CEO of the emphasised the framework’s broader significance:
“This initiative underscores our collective commitment to true federalism, regulatory integrity, and economic pragmatism. With this reciprocity framework, we are creating a level playing field, upholding constitutional order, and enabling a more predictable operating environment for responsible gaming operators with the utmost respect for the autonomy of respective states enshrined in the constitution.”
Other state regulators applauded the unified front:
• Michael Eja, Director General of the Cross-Rivers Lotteries and Gaming Agency, said, “This framework reflects the spirit of inter-state collaboration that has long been missing in our regulatory space. It is a bold statement that Nigeria’s federating units can work together to simplify processes without compromising oversight or accountability.”
• Olajide Boladuro of the Oyo State Gaming Board noted, “The Universal Reciprocity Certificate will remove unnecessary barriers to entry for licenced operators and help foster a more vibrant and competitive gaming sector across states. It’s a win for innovation, investment, and the rule of law.”
• Lami Bello, Director of the Emerging Tax Department at the Taraba State Internal Revenue Service, added, “For years, operators have been caught in a web of overlapping requirements. This framework replaces that confusion with clarity and consistency while ensuring that each state retains its constitutional authority to regulate gaming within its borders.”
Alignment with global best practices
Nigeria’s subnational reciprocity model mirrors successful approaches in other federal systems. In the United States, interstate compacts enable cross-border wagering; Canada relies on provincial agreements; Germany regulates through the Interstate Treaty on Gambling; Switzerland administers gaming via the International Gambling Concordat; and India permits cooperative arrangements among states. These international examples demonstrate that multi-jurisdictional licensing can uphold state autonomy while providing a unified market for operators.
Benefits and future outlook
By simplifying the licensing process, the Subnational Reciprocity Licensing Framework will:
i) Attract new investment via a stable regulatory framework
ii) Encourage responsible gaming through balanced regulation
iii) Increase state revenue in a predictable fee structure
iv) Stimulate product and service innovation
As applications are now available through the FSGRN Secretariat and a 2025 fee waiver is being offered, operators have a vested interest in making the switch. As Nigeria’s federating units set out on this collaborative journey, the gaming sector can look forward to a safer, more transparent, and growth-driven future.
