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Nigeria’s Court of Appeal Just Confirmed COSON Has No Licence to Collect Royalties

Nigeria’s Court of Appeal Just Confirmed COSON Has No Licence to Collect Royalties

Nigeria’s Court of Appeal has dismissed COSON’s bid to stop the Copyright Commission from treating its licence as lapsed, leaving MCSN as the only body currently approved to collect royalties on behalf of Nigerian songwriters.
Nigeria’s Court of Appeal Just Confirmed COSON Has No Licence to Collect Royalties Nigeria’s Court of Appeal Just Confirmed COSON Has No Licence to Collect Royalties

On July 9, 2026, a three-judge panel at Nigeria’s Court of Appeal in Lagos dismissed an appeal by the Copyright Society of Nigeria (COSON), affirming that the organisation has had no valid licence to operate as a royalty-collecting body since May 2019. The Nigerian Copyright Commission (NCC) made the judgment public on July 25, and it has been working its way through Nigerian legal and entertainment press since. For a country whose recorded music sells the world on Afrobeats, the question of who is legally allowed to collect the royalties generated inside Nigeria itself has now gone unresolved for the better part of eight years, and this ruling does not end that.

What the Court Actually Decided

The panel, led by Justice Polycarp Terna Kwahar and joined by Justices Folasade Ayodeji Ojo and Muslim Sule Hassan, was not asked to settle the underlying fight over who should be Nigeria’s official royalty collector. The narrower question was whether COSON was entitled to an interlocutory injunction stopping the NCC from treating its operating approval as gone while a separate, substantive suit plays out. The court said no, affirming a December 1, 2021 Federal High Court ruling in Suit No. FHC/L/CS/425/2020.

An interlocutory injunction is meant to preserve the status quo, not to reverse actions that have already been completed, the court held, finding that COSON’s operating approval had already been suspended in April 2018 and had expired by May 2019, well before COSON filed its case.

The court also awarded costs of ₦200,000 against COSON. Counsel for the NCC, Lynda Alphaeus, additionally accused COSON of misrepresenting language from the trial court’s earlier ruling, calling the insertion of words that did not appear in the original judgment “mischievous.” COSON’s counsel, James Ononiwu, maintained the organisation’s position that the NCC had no authority to revoke a CMO licence without a prior court order, and that what happened in 2018 was an unlawful suspension, not a lawful revocation.

How Nigeria Got Two Rival Collection Societies

Nigeria’s Copyright Act requires collective management organisations (CMOs), the bodies that license public performance, broadcast, and mechanical use of songs on behalf of songwriters and publishers, to hold NCC approval under the Copyright (Collective Management Organisations) Regulations of 2007. COSON, founded and long chaired by veteran music executive Tony Okoroji, was Nigeria’s original CMO. The NCC suspended its approval in April 2018 amid a leadership dispute and allegations of financial mismanagement, and that approval lapsed entirely in May 2019 after COSON did not meet the regulator’s renewal conditions.

Into that vacuum stepped the Musical Copyright Society of Nigeria (MCSN), which says it was actually Nigeria’s first CMO, established in 1984, before repeated changes to the regulatory framework saw its own applications denied for years. The NCC renewed MCSN’s approval in December 2020 and has reaffirmed it since, including in statements from the Commission’s leadership in 2025. As of this ruling, MCSN is the only body the NCC recognises as licensed to collect royalties on behalf of Nigerian rights holders.

Why This Actually Matters for Working Songwriters

This is not a fight that stays inside courtrooms and press statements. Every radio station, event venue, streaming platform, and broadcaster operating in Nigeria is supposed to pay licence fees to a CMO for the right to publicly perform or broadcast copyrighted music, and that CMO is supposed to distribute those fees back to the songwriters and publishers whose songs got played. When it is genuinely unclear which organisation holds that mandate, and has been unclear for close to eight years, licensees have an excuse to delay paying anyone, and songwriters have no reliable single address to register with or chase for money owed.

That confusion sits alongside a system that, for most Nigerian artists’ actual global income, is beside the point. The royalties that flow from Spotify, Apple Music, Boomplay, or Audiomack streams are handled directly through distribution deals and the platforms’ own reporting, not through COSON or MCSN. But domestic public performance and broadcast royalties, the money owed every time a song plays on Nigerian radio, in a club, or at a live event, run through exactly this contested lane. For songwriters who don’t have a major publishing deal doing this chasing for them, knowing which CMO to register catalogue and works with is not a technicality. It is the difference between getting paid and not.

This Is Not Over

COSON has not conceded. According to commentary from entertainment industry writer Efe Omorogbe, the organisation is preparing to take the fight to the Supreme Court, continuing a pattern where it has challenged every adverse ruling since the original 2021 Federal High Court decision. The NCC, for its part, used its own statement on the ruling, issued through Director of Press and Public Relations Ijeoma Egbunike, to reiterate plainly that COSON is “not currently approved to operate as a Collective Management Organisation in Nigeria.” The substantive suit challenging aspects of the 2007 CMO Regulations themselves, as opposed to this interlocutory injunction fight, remains separately pending.

The Real Story Is the Design, Not the Verdict

Nigeria runs, at least on paper, a one-CMO-per-class system: one body for musical works, one for each other copyright category. COSON and MCSN briefly operated in parallel for about fourteen months before this fight escalated, and nothing in Nigerian law actually forbids more than one CMO existing at once. The unresolved question worth more attention than this week’s appellate score card is whether that one-CMO model is even the right design for a market this size, versus a system where songwriters can choose between competing collection bodies the way they can choose between distributors. Until Nigerian policymakers settle that structural question, rulings like this one will keep arriving every year or two, resolving a procedural point while leaving the people who actually wrote the songs no closer to a collection system they can trust.

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Zimbabwe Paid Some Musicians Three Dollars in Royalties. Its Most-Streamed Artist Built His Own Label Offshore.

Zimbabwe Paid Some Musicians Three Dollars in Royalties. Its Most-Streamed Artist Built His Own Label Offshore.