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Uganda’s milestones and pathways to sustainable growth

Mercy Mutiria
Written by Mercy Mutiria

In Uganda, just like in most parts of Africa, the sector is expanding rapidly. Within four years, revenue generated by the government from betting firms increased sixfold – from Shs50b ($) in June 2020 to Shs323b in June 2025, says the National Lotteries and Gaming Regulatory Board (NLGRB).

The total funds staked have increased from Shs500 billion ($139.5 million) in the 2021/22 financial year to nearly Shs8 trillion ($2.23 billion), while an average of 52 companies are active in Uganda’s gambling and betting industry.

The market is dynamic, with approximately 10 new companies joining each year, drawn in by increasing demand, digital innovation, and an investor-friendly regulatory environment. However, competition, regulatory evolution, and changing business models also drive many out. 51 operators have left in the past five years, while 2023 was a year of tax changes and increasing compliance expenses.

The trillion-shilling sector

New players continue to enter the market, indicating lasting confidence in Uganda’s market amid pressures. Yet, information from NLGRB indicates that operator exits come at a high price, aside from the impact on business turnover. Most leave behind unsettled player deposits, unpaid tax, and job losses.

A regulatory loophole compounds this risk: security bonds, intended to address operator liabilities, expire every year and once expired, cannot be recalled, thereby compromising consumer protection. NLGRB has, nevertheless, suggested a critical reform that aims to establish a formal exit process, resolving all tax obligations and safeguarding player funds before exit.

During the 2023/24 financial year, NLGRB resolved 46 complaints related to unpaid winnings, bet cancellations, system failures, operator closures, and disputes between employees. The amount under dispute from public complaints amounted to approximately Shs1.66 billion ($463,033.76); however, two outstanding suits seek Shs24.1 billion ($6.7 million), which is nearly 15 times the value of all public complaints.

Ensuring revenue integrity

But that is not all. The government is not garnering nearly sufficient tax revenue from this growth. The Uganda Revenue Authority (URA) projected collecting Shs439 billion ($122.5 million) for the 2023/24 financial year, but collected Shs194 billion ($54.1 million), which was 59% below the projection, but up from last year’s Shs152 billion ($42.4 million).

Betting firms tax only the cash won by players after deducting their incurred costs. For example, if gamblers stake Shs100 million ($27,893.60) and win back Shs90 million ($25,104.24), the firm taxes only the Shs10 million ($2,789.36) profit.

To plug the leakage, the Finance Ministry is establishing a National Central Electronic Monitoring System to monitor bets and winnings in real-time.

The compliance issue

The most significant threat to the flourishing gaming industry, however, is noncompliance. A comprehensive audit conducted nationwide by the NLGRB last year revealed that only 32% of the 2,295 betting premises met the licensing and operational standards.

The failure is both structural and quantitative in nature. Financially, some operators defaulted on fundamental requirements, such as demonstrating capital adequacy and submitting returns on time. Others inflated their balance sheets with illiquid reserves or reported income from unlicensed services such as software and odds provision.

Some operators, like Fortuna, even blocked inspections entirely, openly contesting the regulator’s authority.

Expanding loopholes

In the meantime, digital loopholes are becoming more prevalent. Players now play bingo games through USSD on radio and television using Random Number Generators (RNGs) without third-party testing, and they face no age verification. Additionally, there is Aviator, a fast-paced casino game now offered by operators without casino licenses.

It appears that the existing laws were not designed for today’s rapidly evolving and sophisticated gambling sector. All is quicker – with internet games, mobile gambling, and online adverts, there to back them up. NLGRB, however, is developing a new system to get up to speed, but delays are costing tax revenue.

For instance, advertisers still do their work manually. Last year, the regulator received only 14 gambling adverts, turned down four of them, and most adverts were not forwarded at all. To track advertisements, NLGRB officials must watch TV or listen to the radio themselves.

Even legal promotions show a financial loss. Why? Because the law doesn’t allow NLGRB to charge a fee to process promotions. This means money is slipping through legal cracks. To enhance financial oversight, the NLGRB plans to collaborate more closely with the Bank of Uganda to increase transparency over transactions involving gaming funds.

If the government doesn’t act fast, the industry’s speed and scale will outpace the law, costing the country billions of shillings in lost revenue.

A new and improved regulator

However, despite these challenges, the sector has made some significant reforms.

While inaugurating the new NLGRB board, Finance Minister Matia Kasaija stated that the outgoing board, chaired by Aloysius Mugasa Adyeri, had transformed the NLGRB from a once disorganised regulator into a modern, transparent, and credible institution.

“Alongside CEO Denis Mudene Ngabirano and the Secretariat, you have instigated a transformation that has redefined the gaming sector. The board not only maintained the status quo but also enhanced, expanded, and developed the institution,” he stated.

The new board, to be led by Kenneth Kitariko, an expert with over 25 years of experience in financial markets, boasts a rich pool of regulatory, legal, enforcement, governance, and sports leadership experience.

The other members include Mark Paul Odong, an experienced law enforcement officer; Faridah Bahemuka Murungi, an expert in legal and tax policy; Esther Akullo, an expert in planning and accountability; and William Blick, an expert in sports governance and stakeholder engagement.

Kitariko said the new board had stepped into a new chapter – “one that requires courage, focus, and unrelenting commitment to drive strategic execution”.

The new board will also be tasked with aligning NLGRB with Uganda’s development agenda, which aims to enhance local revenue through technology and data optimisation, and to achieve a tenfold expansion from $61.3 billion to $500 billion by 2040. Additionally, it will support strategic targets under the National Development Plan IV.

Ngabirano indicated that the new board is timely as the gaming industry is dynamic and evolving, an aspect that has new expectations, adding that NLGRB would ensure that it maintains the values of integrity, efficiency, and fairness in the regulation of the gaming industry.

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