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Olatokunbo Bamgose

The Lagos Land Use Charge, Amendment Law 2025: Enforcement, New Rates, and the Legal Obligations of Property Owners and Corporate Occupiers

Lagos State has commenced enforcement against Land Use Charge defaulters while simultaneously operating under a materially amended LUC framework for 2026. For every director, practitioner, and business leader with property interests in Lagos, the compliance obligations are live and the enforcement posture of the state government is unambiguous.

The Legal Framework

The Land Use Charge is an annual property tax levied on property owners in Lagos State under the Land Use Charge Law. It is calculated by reference to the assessed market value of the land and buildings, the location and classification of the property, and the use to which it is put. It constitutes one of Lagos State’s primary sources of internally generated revenue and is administered by the Lagos Inland Revenue Service (LIRS) through the Land Use Charge Office (LUCO).

The Land Use Charge (Amendment) Law 2025, effective January 1, 2026, introduced material changes to the rates structure, the penalty framework, and the exemptions available under the LUC regime. The amendments pursue three stated policy objectives: increasing compliance across the property-owning population,discouraging land speculation and idle land banking, and incentivising sustainable development practices.

The LUC is calculated using the formula: LUC =

Market Value × Relief Rate x Charge Rate, where market value is determined by the Lagos State Valuation Office, the relief rate reflects any applicable exemptions, and the charge rate is the annual percentage applicable to the property category. The 2025 Amendment materially affects all three inputs for certain categories of property.

The Material Changes Under the 2025

Amendment

Penalty Surcharge on Undeveloped Land

The most significant rate change for business owners and investors is the doubling of the

penalty surcharge on undeveloped plots. Under the amended law, land with no substantial building or active use now attracts a 100% penalty surcharge on the base LUC rate. The previous surcharge was 50%. The stated rationale is to discourage land banking and accelerate development in high-demand areas of Lagos.

This change has a direct and material impact on any individual or entity holding undeveloped land in Lagos – whether for future development, as a speculative investment, or as uncommenced business premises. For Nigerian companies and directors holding undeveloped Lagos land on their balance sheets, the 2026 LUC assessment for those properties will be materially higher than the 2025 assessment. Financial planning and tax provisioning should reflect the amended rate.

Maximum Penalty for Contravention

The maximum penalty for contravention of the

LUC Law has been restored to N250,000. Some context is important here: the N250,000 maximum was originally introduced under the Land Use Charge Law 2018, replacing the N100,000 figure in the prior law. The 2020 LUC Law subsequently reduced specific penalties back to N100,000 in response to stakeholder pressure. 

The 2025 Amendment reinstates the N250,000 ceiling, alongside an express statement that enforcement against persistent defaulters may include legal action.

In addition, the Attorney-General of Lagos State retains express statutory powers — confirmed and reinforced under the amended framework – to institute action to enforce payment of Land Use Charge and to distrain property of defaulting payers pursuant to a court order. This is not a theoretical remedy. The enforcement infrastructure supporting its exercise has materially improved.

Green Building Exemptions

Properties meeting verified green building standards qualify for significant LUC exemptions.

Specifically, properties holding Nigerian Green Building Council (NGBC) Level 2+ certification

– which requires at least 50% renewable energy capacity and at least 40% water efficiency — qualify for a 50% to 100% LUC exemption for the first five years post-certification, with the precise exemption level dependent on the certification tier achieved.

For developers and businesses with the capacity to pursue NGBC certification, the LUC saving over five years represents a material financial benefit.

The upfront premium for green construction — typically estimated at 8-14% of build cost — is recoverable through the LUC exemption and associated rental premium within two to four years in most Lagos submarkets. This should be factored into development planning from the earliest stage.

Early Payment Discount

The 15% early payment discount for 2026 bills settled within the approved timeframe remains available. Given the active enforcement environment, utilising this discount is a financially rational and straightforward course of action for every compliant property owner.

The Current Enforcement Position

The Lagos State Government’s March 2026 statement announced the commencement of enforcement proceedings against 2025 LUC defaulters and gave notice that the 2026 bills are in the system and compliance is expected. The enforcement drive is supported by inter-agency data coordination – including the use of Geographic Information System (GIS) technology for property mapping and identification – that enables the state to identify non-compliant property owners with greater precision than was previously possible.

The practical significance of this is that the informal enforcement environment in which some Lagos property owners previously operated – where non-payment was a cost-benefit calculation weighted against the likelihood of detection — has changed. The state’s enforcement infrastructure has improved materially. The GIS mapping programme,electronic billing systems, and cross-agency data sharing create a significantly higher probability of identification for non-compliant owners than existed under the pre-digital enforcement model.

Practitioners advising property-owning clients should treat the state’s stated commitment to act against defaulters as operationally credible, not aspirational.m

Implications for Legal Practitioners

The LUC compliance position of client companies and individuals is a matter that legal advisers should be addressing proactively, particularly in the context of property transactions, corporate due diligence, and estate planning.

In transaction contexts, the LUC history of a property – whether bills have been paid, whether there are outstanding liabilities, whether any undeveloped land surcharge applies, and what the 2026 assessment reflects – is a standard due diligence item whose significance has increased under the amended law.

Outstanding LUC liabilities constitute encumbrances on property and affect the clean title representation that vendors are required to give. Solicitors acting on acquisitions should obtain and verify the full LUC payment history, including the 2025 arrears position, before completion.

In corporate governance contexts, directors of companies with significant property holdings in Lagos carry an obligation to ensure those Properties are  LUC-compliant. Under Sections 311 and 312 of CAMA 2020, directors must act with care, skill, and diligence of a reasonably prudent  person and must not allow the company ur liabilities without reasonable prospect of meeting them. Negligence in managing statutory

property tax obligations — a quantifiable, foreseeable liability – is precisely the kind of governance failure that personal liability under CAMA 2020 is designed to address.

In estate planning contexts, accumulated LUC liabilities pass with the property and must be addressed in any disposal, transfer, or estate administration involving Lagos real estate.

What Property Owners and Corporate Clients Must Do

Verify the 2026 LUC assessment for all Lagos properties. Bills are accessible through the LIRS/ LUCO online portal using the Property Identification Number (PIN). Where bills have not been received, seek them actively rather than assuming no liability exists.

Regularise all outstanding 2025 LUC liabilities immediately. The grace period for 2025 defaulters is closing and enforcement is active.

Regularising prior to formal enforcement action avoids the risk of distrained property and removes the encumbrance ahead of any planned transaction.

Assess whether any properties are classified as undeveloped. Where they are, the 100% penalty surcharge applies and should be reflected in financial planning and balance sheet provisioning for 2026.

Take advantage of the early payment discount for 2026 bills where the payment window remains open. The 15% saving is straightforward and the alternative – late payment plus active enforcement — carries costs that substantially exceed the discount foregone.

Review commercial leases to determine whether any LUC obligations are allocated to occupying tenants under the lease terms. Where they are, confirm that tenants are meeting those obligations, since ultimate liability for unpaid LUC rests with the registered property owner.

Assess green building certification as a development planning tool. For new developments and major refurbishments, the path to NGBC Level 2+ certification and the associated five-year LUC exemption should be modelled against build cost at the planning stage.

Where LUC assessments are believed to be incorrect, file a written objection within 30 days of receiving the demand notice and engage the Land Use Charge Assessment Appeal Tribunal.

The Tribunal now offers a virtual dispute resolution option, which reduces the procedural friction of challenging assessments that are factually wrong.

Conclusion

The Land Use Charge (Amendment) Law 2025 and the enforcement drive underway in 2026 represent a compliance environment that is more demanding, and more actively enforced, than at any previous point in the LUC’s history. For Nigerian businesses, directors, and practitioners with Lagos property interests, the obligation is current, the penalties are material, and the relevant LUC history – going back to 2025 arrears

is now recoverable by the state with greater ease than before. Orderly compliance now is significantly less costly than reactive compliance later.

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