The participants are Arinze Arum<\/strong>, executive secretary\/CEO of the Enugu State Gaming and Lotto Commission; Wendy Rosenberg<\/strong>, director at Werksmans Attorneys; Olabimpe Akingba<\/strong>, head of responsible gaming at pawaTech; Moruntshi Kemorwale<\/strong>, chief executive officer of the Gambling Authority of Botswana; and Moss Gondwe<\/strong>, board member of the African Lotteries and Gaming Association (ALGA).<\/p>\n\n\n\n For Arinze Arum<\/strong>, the main obstacle to harmonisation is “the significant differences in the legal, political, and regulatory structures across African jurisdictions.”<\/p>\n\n\n\n He notes that each country has its own peculiarities, market realities and governance models, making it difficult to develop a one-size-fits-all regulatory framework. “For instance, while some countries operate centralised gaming regulation, others, such as Nigeria and South Africa, have decentralised systems with multiple regulatory authorities,” he says.<\/p>\n\n\n\n Arum argues that moving from dialogue to a practical harmonised framework will require regulators and policymakers to establish a common regulatory agenda, ideally through a multilateral treaty or formal cooperation framework endorsed by their respective governments.<\/p>\n\n\n\n Such a framework, he says, should focus on shared principles, minimum regulatory standards, information sharing, responsible gaming, consumer protection, anti-money laundering measures and cross-border collaboration, while allowing individual jurisdictions the flexibility to address their unique domestic realities.<\/p>\n\n\n\n Wendy Rosenberg<\/strong> is more sceptical about whether a unified framework is achievable.<\/p>\n\n\n\n She argues that, unlike the EU, “Africa has no supranational legal architecture capable of binding member states to a common regulatory framework.” In her experience, national governments and regulators are receptive to harmonisation in principle and participate in regional workshops and collaborative fora, such as those hosted by the Gaming Regulators Africa Forum (GRAF).<\/p>\n\n\n\n “But, ultimately, each country develops and implements its own laws and, in practice, they tend towards their own domestic jurisdiction \u2014 understandably so, given their mandates to protect consumers and advance their own economic, political, and socio-economic priorities,” she adds.<\/p>\n\n\n\n Rosenberg points to the fragmentation within South Africa itself as an illustration. Gambling is an area of concurrent national and provincial competence, with a national gambling board plus nine provincial regulators, each administering their own legislation, many of which date back to the late 1990s.<\/p>\n\n\n\n “While there are some similarities, there are also differences. The result is genuine internal tension. For example, provincial regulators permit fixed-odds online betting under bookmakers’ licences, while the National Gambling Board regards certain online betting offerings as unlawful. If a single country cannot achieve internal alignment, continental harmonisation remains, realistically, an aspiration rather than an imminent prospect \u2014 worth pursuing, but not to be expected soon,” she adds.<\/p>\n\n\n\n For Olabimpe Akingba<\/strong>, Pan-African regulatory harmonisation is often misunderstood as requiring one law for all African countries, which she argues is neither realistic nor necessary.<\/p>\n\n\n\n She says Africa is incredibly diverse, with different systems of government, legal systems, languages, cultural nuances, levels of market maturity and regulatory priorities. Those differences should be respected.<\/p>\n\n\n\n What is realistic, she argues, is harmonisation around common principles and minimum standards. She says regulators do not need identical legislation to agree on core issues such as player protection, responsible advertising, measures to combat illegal and black market operators, anti-money laundering standards and information sharing between regulators.<\/p>\n\n\n\n Akingba believes moving from conversation to action requires three things: stronger collaboration between regulators through regular dialogue, agreement on practical evidence-based minimum standards that reflect African market realities, and a collective commitment to tackling illegal gambling as a continental challenge rather than an individual country problem.<\/p>\n\n\n\n “Harmonisation is not about removing the independence of each African country; rather, it is about creating an environment where compliant operators can compete fairly, players are better protected and regulators can work together to build a sustainable gaming industry across Africa,” she says.<\/p>\n\n\n\n Moruntshi Kemorwale<\/strong> argues that Pan-African regulatory harmonisation will only become a reality when the focus shifts from pursuing identical laws to pursuing common regulatory outcomes.<\/p>\n\n\n\n She says Africa’s jurisdictions differ in legal systems, market maturity and national priorities, but regulators can still agree on minimum standards for licensing, responsible gambling, anti-money laundering, consumer protection, cybersecurity, data governance and environmental, social, and governance (ESG) reporting. Harmonisation, in her view, should be principles-based rather than prescriptive.<\/p>\n\n\n\n From an ESG perspective, Kemorwale argues that regulation must balance economic growth with social responsibility and sound governance. A continental framework should encourage cross-border information sharing, mutual recognition of certain regulatory processes, joint enforcement against illegal online operators, common integrity standards for sports betting and coordinated research on gambling-related harm.<\/p>\n\n\n\n She suggests that regional bodies can pilot these initiatives before broader continental adoption.<\/p>\n\n\n\n Ultimately, she says, harmonisation is not about surrendering sovereignty, but about strengthening Africa’s collective regulatory capacity, protecting consumers, attracting responsible investment and ensuring that the growth of gaming delivers sustainable public value across the continent.<\/p>\n\n\n\n For Moss Gondwe<\/strong>, the urgency of harmonisation is driven by the scourge of illegal operators, borderless online gambling and the lack of strategies to combat underage gambling.<\/p>\n\n\n\n He argues that it is even more critical for regulators, operators and ALGA to cooperate and formulate strategies jointly to address these challenges before they get out of control. By doing so, he says, regulators and operators can protect revenue losses, exercise better control and ensure investors get value for their investments.<\/p>\n\r\n\t\tShared principles, not uniform laws<\/h2>\n\n\n\n
A sceptical view<\/h2>\n\n\n\n
Minimum standards over identical laws<\/h2>\n\n\n\n
Common outcomes, not identical laws<\/h2>\n\n\n\n
Urgent cooperation<\/h2>\n\n\n\n
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