If you manage property in Lagos, you must be registered

Most of this year's property news in Lagos has been about one number: the tenancy bill before the State House of Assembly would cut the agency fee on a letting to five per cent. Less discussed is that a ten per cent ceiling on that same fee has been law since 2015, and that the law carrying it also requires firms like yours to register with the state before they manage anything.

The registration duty is the one to check first, because it applies to the firm managing the building. You do not escape it by pointing at the agent who found the tenant. If your firm both manages buildings and lets them, two separate duties land on you: registration as a manager, and the fee ceiling as a letting agent.

Registration, and the permit that follows it

The Lagos State Real Estate Regulatory Authority Law 2021 was signed on 7 February 2022. It repealed the older Lagos State Estate Agency Regulatory Authority Law, which was Chapter L28 of the Laws of Lagos State 2015. It created the Lagos State Real Estate Regulatory Authority, LASRERA for short, which is the body you deal with.

Two separate things matter here, and the Law treats them as steps in an order. Registration is the firm being entered on the Authority's books. A permit is the annual document that lets a registered firm actually transact, and section 27 says you cannot be issued one until you have registered. A firm that never registered was therefore never eligible for a permit, so if it has been letting or managing in the meantime, it has been doing so without either.

Section 27 covers property developers, facility managers and property management companies, whether the business trades as one person or as a limited company. When you register you also have to tell the Authority which projects you are working on at the time.

Under section 29(3) a permit runs for one year. Section 29(4) lets the Authority review how long each category of permit lasts, so treat one year as the standing rule rather than a guarantee, and read what your own permit says. Section 31 requires you to apply for renewal no later than two weeks before the current one expires.

Section 31 does not set a penalty for missing that deadline. Section 48(b) is the provision that would apply, because it covers contravening any other part of the Law. I have found no case of LASRERA enforcing it against a late renewal specifically, so treat this as exposure rather than settled practice, and file early enough that it never comes up.

What registering actually involves

Section 26(2) sets the conditions an individual applicant has to meet before LASRERA will register them. You need to be Nigerian or hold a valid work permit, be at least eighteen, hold a LASRRA number, which is the Lagos State residents registration number, and have business premises in the state. You also need a minimum educational qualification of WASC, GCE or NECO, proper records of your transactions, a separate client account for money you hold on other people's behalf, three years of tax clearance certificates, and a business name registered with the Corporate Affairs Commission.

A company registers on slightly different terms. It must be incorporated at the Corporate Affairs Commission, keep proper transaction records and a separate client account, have three years of tax clearance, ensure any non-Nigerian directors hold valid work permits, and have at least one director who personally meets the conditions set for individual applicants.

Most of that list is documents you either already hold or have to go and obtain, so treat it as a gathering exercise before you approach LASRERA at all. The two items that take longest are the three years of tax clearance and the separate client account, so start with those.

What not registering costs

Section 48(a) makes failure to register an offence. On conviction the fine is not less than ₦250,000 for an individual and not less than ₦1,000,000 for a company.

The words "not less than" set a minimum rather than a fixed amount, so a court can go higher. This is a criminal fine that follows a conviction in court, not a bill the Authority posts to you.

The fee ceiling is older than the argument about it

Section 32(2) says that the fees a person or organisation dealing in real estate can charge clients shall be:

(a) in a Letting/Lease transaction, not more than ten (10%) per cent of the total rent collected on any transaction; and

(b) in sale or purchase of interests in buildings; where two or more holders of permits are retained by the owner/vendor for the sale/ lease, fees shall not be more than fifteen per cent (15%) of the total proceeds of sale or tenancy.

Paragraph (a) is the one that governs a letting, so it is the one most firms come up against every month. It sets the ceiling at ten per cent of the rent collected on that transaction.

Paragraph (b) is a mess. It opens by talking about a sale or purchase, then refers to a sale or lease, then measures the cap against proceeds of sale or tenancy, and those three do not line up. If a deal of yours falls in that area, that is a question for your solicitor and not for a blog post.

What paragraph (a) does not do is settle every argument about the base it is measured on. "Total rent collected" is the statutory phrase, and the Law does not go on to say whether that means the full annual rent written into the agreement or the money actually received. The base is not the only open question, because the section does not reach every charge either. Section 32(2)(a) is not drafted as one ceiling over every naira that changes hands around a tenancy. Section 32(1) deals with charges for legal documentation separately, by referring them to the scale of fees that governs what lawyers may charge, and that scale sits outside this cap. So a fee under a different name may fall inside the ten per cent or outside it, and what decides it is what the charge is genuinely for rather than what it is called. Renaming an agency fee does not move it out of the cap. Put any real case to your solicitor before you restructure anything.

The ceiling itself is not new. The repealed 2015 Law carried the same ten per cent limit on letting and lease fees at its section 26(11)(a), and the 2021 Law kept it.

So the Assembly is deciding whether to halve a ceiling that already exists in law, not whether to have one at all. Punch and Radio Nigeria both reported it that way, as a cut from ten per cent to five.

Where the bill has got to

A bill becomes law in stages. It is read a second time and debated, then sent to a committee that can rewrite it, then read a third time and passed, and finally assented to by the Governor. Only that last step makes it binding on anyone.

Rebuilding your fee structure around five per cent today means rebuilding it around a number that binds nobody yet, and the committee can still change that number before it ever binds anyone.

What to do this week

Find out whether your firm is registered, and if it is, when the permit expires. If nobody in the office can answer that, ring LASRERA and ask rather than assuming either way. I would not rely on the online register for this. Section 25 requires the Authority to keep a register open to public inspection, and the state told residents in June 2025 to verify registrations through the LASRERA website, but I could not reach that site while writing this. Until it is back, the document in your own file is what you are relying on.

For agents you engage, ask to see two things rather than an assurance: proof that the firm is registered, and the current permit with its expiry date on it. An expired permit is a different problem from never having registered, and you want to know which one you are looking at.

Then take one recent letting and put your total fee against ten per cent of the rent collected on it. If you are over, you were over before the bill was drafted, and the fix is to bring the current schedule within the ceiling now and take advice on anything already invoiced. Do not wait for the five per cent debate to resolve, because it has no bearing on the rule you are breaching.

None of this makes a firm fully compliant. The same Law also requires client accounts for money you hold on behalf of others, rules on remitting and receipting what you collect, and disclosure of the projects you are working on. Those take longer than a week. Registration and the fee check are the two you can settle now, against a rule that has been in force for four years while the argument ran about the next one.