If you manage property in Lagos, you must be registered

If your firm manages property in Lagos, it has to be registered with the state's real estate regulator, LASRERA, under the Lagos State Real Estate Regulatory Authority Law 2021, which was signed on 7 February 2022. Failing to register is a criminal offence, and on conviction a company faces a fine of at least ₦1,000,000.

The duty falls on the firm that manages the building, so you cannot shift it onto the agent who found the tenant. And if your firm also lets property, the same Law limits the fee you can charge on a letting to ten per cent of the rent collected. That ceiling was already in the 2015 law this one replaced. It is worth knowing about, because most of this year's property news has been about a tenancy bill that would cut the fee to five per cent, and the ten per cent limit that already binds you gets less attention.

Two checks to make this week

First, find out whether your firm is registered, and if it is, when its permit expires. A permit is the annual document that lets a registered firm do business, and I explain below how it differs from registration. Start with the registration and permit documents in your own files, because for now they are all you have to go on. I would not rely on the online register for this yet: section 25 requires the Authority to keep a register open to public inspection, and in June 2025 the state told residents to check registrations on the LASRERA website, but I could not reach that site while writing this. If the files do not answer the question and nobody in the office can, ring LASRERA and ask instead of assuming either way.

For agents you work with, ask to see two documents instead of accepting their word: proof that the firm is registered, and its current permit with the expiry date on it. An expired permit is a different problem from never having registered, and you want to know which one you are dealing with.

Second, check one recent letting against the ten per cent ceiling. Compare your total fee on it with ten per cent of the rent collected. What counts towards the fee, and what the ten per cent is measured against, are both less settled than they look, and I explain both below. If you are over, you were already over before the bill was drafted, so bring your fee schedule within the ceiling now and take advice on anything you have already invoiced. The five per cent debate has no bearing on the rule you would be breaching.

Who has to register

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.

Registration and a permit are two different things, and the Law puts them in order. Registration means the Authority enters your firm on its books. A permit is the annual document that lets a registered firm do business, and section 27 says you cannot be issued one until you have registered. So a firm that never registered was never eligible for a permit either, and if it has been managing or letting property in the meantime, it has been doing so without either.

The 2021 Law repealed the Lagos State Estate Agency Regulatory Authority Law, Chapter L28 of the Laws of Lagos State 2015, and set up the Lagos State Real Estate Regulatory Authority, the body you deal with.

What failing to register costs

Section 48(a) makes failing 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.

"Not less than" sets a minimum, so a court can impose more. And because it is a criminal fine, it follows a conviction in court. It is not a bill the Authority sends you.

What you need to register

Section 26(2) sets the conditions an individual must meet before LASRERA will register them:

• Nigerian citizenship, or a valid work permit
• age eighteen or over
• a LASRRA number, issued by the Lagos State Residents Registration Agency (a different body from LASRERA, despite the similar name)
• business premises in Lagos State
• 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
• 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
• make sure any non-Nigerian directors hold valid work permits
• have at least one director who personally meets the conditions for individual applicants

Gather these before you approach LASRERA, starting with the three years of tax clearance and the separate client account, which take longest.

The permit, and renewing it on time

Under section 29(3) a permit lasts 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 permit expires.

Section 31 sets no penalty of its own for a late renewal application. The provision that would apply is section 48(b), which 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 arises.

The ten per cent fee ceiling

Section 32(2) sets the most that a person or organisation dealing in real estate can charge a client. Paragraph (a) is the one that governs a letting, so it is the one most firms apply every month:

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

Paragraph (b) deals with the sale or purchase of interests in buildings, and sets a fifteen per cent ceiling where two or more permit holders are retained by the owner or vendor. Its wording is confused, though: after opening with a sale or purchase, it refers to a sale or lease, then measures the cap against the proceeds of sale or tenancy, and those do not line up. If a deal of yours might fall under paragraph (b), ask your solicitor.

Paragraph (a) leaves two questions open. The first is what the ten per cent is measured against. The Law says "total rent collected" and does not say whether that means the full annual rent in the agreement or the money actually received.

The second is which charges count, because section 32(2)(a) is not one ceiling over every naira that changes hands around a tenancy. Section 32(1) deals with charges for legal documentation separately, under the scale of fees that governs what lawyers may charge, so those sit outside the ten per cent. Whether a charge counts depends on what it is genuinely for, whatever it is called, so renaming an agency fee does not take it out of the cap. Put any real case to your solicitor before you restructure your fees.

The repealed 2015 Law had the same ten per cent limit on letting and lease fees in its section 26(11)(a), and the 2021 Law kept it.

So the Assembly is deciding whether to halve an existing ceiling. Punch and Radio Nigeria both reported the bill that way, as a cut from ten per cent to five.

Where the bill has got to

A bill goes through several stages before it binds anyone. It is read a second time and debated, sent to a committee that can rewrite it, read a third time and passed, and finally signed by the Governor. Only that last step makes it binding.

If you rebuild your fee structure around five per cent now, you are building it around a number that binds nobody yet, and one the committee can still change.

What registration does not cover

None of this makes a firm fully compliant with the Law, which also requires client accounts for money you hold for others, rules on paying over and receipting what you collect, and disclosure of the projects you are working on. Those take longer than a week to put in place.