Gaming Law 2025 Comparisons

Macau’s gaming industry entered 2025 with renewed momentum and a clearer regulatory horizon. In his Policy Address of 14 April 2025, Chief Executive Sam Hou Fai reaffirmed the government’s commitment to the dual objectives of “innovation and diversification” while consolidating regulatory oversight of the gaming sector. The emphasis is now on the effective execution of non-gaming projects, reinforcement of compliance standards, and the continued alignment of the gaming industry with the broader economic diversification strategy of Macau SAR.

The market has responded positively to this environment. According to the Gaming Inspection and Co-Ordination Bureau (DICJ), Macau recorded its highest post-pandemic gross gaming revenue (GGR) in August 2025, reaching MOP22.16 billion (approximately USD2.77 billion), following equally strong results in June and July 2025. Government macro-forecasts set full-year GGR at approximately MOP240 billion (around USD30 billion), while independent analysts project 5–6% growth in 2025 – a sign of sustained recovery and operational stability moving into 2026.

Legislation

On the legislative front, Law 7/2024 (Credit for Gaming) and Law 20/2024 (Illegal Gambling) have now moved from enactment to implementation. Law 7/2024, effective 1 August 2024, restricts the extension of gaming credit to concessionaires themselves, centralising credit risk and improving traceability. Law 20/2024, meanwhile, has broadened investigative powers, strengthened sanctions, and underpinned a series of publicly announced enforcement actions, a trend expected to continue in the years ahead.

At the administrative level, the DICJ underwent significant restructuring in 2025, marked by the appointment of a new director, signalling the government’s intention to strengthen institutional governance and modernise supervision. The Bureau also expanded its inspectorate incorporating new officers, reinforcing its capacity for on-site supervision and real-time monitoring. Technological adoption has accelerated, particularly with radio-frequency identification (RFID)-enabled chip tracking now used to attribute play to foreign patrons – a data-driven measure introduced after the limited results of the foreign-player zones and now integral to administering tax incentives for international-market development.

The transition of satellite casinos, mandated under the Gaming Law (Law 16/2001, with amendments introduced by Law 7/2022) remains one of the most consequential structural adjustments of the current concession cycle. The law requires that all gaming venues operate from properties owned by their respective concessionaires by 31 December 2025, effectively ending the traditional model in which third-party investors partnered with operators under revenue-sharing or service agreements.

A further regulatory development with direct implications for the gaming industry is the government’s consultation on the revision of Macau’s Advertising Law (Law No 7/89/M), launched on 4 July 2025. The consultation paper proposes a new framework that would explicitly prohibit the advertising of games of fortune or chance across all media, including digital and cross-border online platforms. It clarifies that references to casinos, gaming equipment, or gambling behaviour that could be construed as encouraging participation in gaming activities would be deemed unlawful, even if indirectly presented.

The draft further contemplates increased fines, immediate removal or blocking of infringing online content, and potential suspension of business operations in cases of repeated breaches. If implemented, these amendments will represent the first substantive reform of gambling-related advertising in over three decades, imposing stricter compliance and monitoring duties on casino concessionaires, gaming promoters, and marketing affiliates operating in or targeting the Macau market.

Over the course of 2025, some long-standing satellite casinos – particularly those in standalone hotels – have already ceased (or announced they will cease) operations or re-purposed their premises ahead of the deadline. This consolidation may affect employment levels, supply-chain contracts, and small-scale hospitality operators, but is viewed by policymakers as a necessary rationalisation to ensure that the market operates within a transparent, concessionaire-controlled framework. Notably, some operators have publicly indicated that they may acquire some of the hotel properties hosting satellite casinos currently operating under their brands, signalling a strategic move toward direct ownership and long-term integration of those venues within their concession portfolios. Discussions continue between the authorities, concessionaires, and investors on how best to redeploy affected workers and facilities, and further adjustments are anticipated as the deadline approaches.

The only licensed online activity continues to be the sports lottery, operated by Macau Slot Co. Ltd., which holds the exclusive concession for football and basketball betting. In 2025, the Macau SAR government extended this concession by one year, to 5 June 2026, allowing additional time to assess the future regulatory model for sports betting as part of the government’s broader review of the lottery and non-gaming entertainment sectors.

No new forms of online or interactive gaming have been legalised, and enforcement against unauthorised offshore platforms remains active under Law 20/2024 (Illegal Gambling).

In parallel, Macau’s courts have begun to apply the interpretative provision set out in Article 63 of Law 16/2022 to disputes concerning long-standing patron deposits held before 2022. Notably, the Court of Final Appeal held for the first time that Article 63 of Law 16/2022 is an interpretative provision that clarifies Article 29 of Administrative Regulation No 6/2002: a concessionaire’s joint liability for activities of gaming promoters only arises when the acceptance, in the casino, of deposits of funds or chips by promoters (or their agents) relates to funds or chips that were actually used in casino gaming or were winnings from such gaming, assessed notably by reference to the concessionaire’s records of exchange or play; mere deposits – especially interest bearing “investment” deposits – without credible evidence of use in gaming, fall outside “activity developed in casinos” and do not trigger joint liability. The court acknowledged a divergence between Chinese and Portuguese versions but adopted the legislative intent reflected in Law 16/2022 and its legislative report, applying the interpretative rule retroactively to pending cases, and therefore rejected joint liability on appeal before it.

At the same time, casino-related suspicious transaction reports (STRs) declined by approximately 9.5% year-on-year in the first nine months of 2025, reflecting both the maturation of AML controls and a structural shift toward the mass-market segment rather than diminished vigilance.

Diversification

Beyond gaming, diversification efforts have taken tangible form. Macau Slot’s sports-lottery concession was extended by one year to 5 June 2026, ensuring continuity during the ongoing policy review, while major entertainment partnerships – including NBA pre-season games hosted in Macau from October 2025 – highlight the government’s determination to expand non-gaming tourism and international visibility.

Together, these developments depict a market entering 2026 with renewed stability, greater regulatory sophistication, and a more sustainable balance between gaming and non-gaming growth.

Into 2026

Looking forward, 2026 marks the third year of the current gaming concessions. Pursuant to Article 22 of the Macau Gaming Law, the Macau SAR government must conduct a comprehensive review of the performance of each gaming concessionaire every three years. The first review cycle is expected to be initiated in late 2025/early 2026, marking the midpoint of the current ten-year concessions. This process will assess compliance with contractual obligations, non-gaming investment targets, corporate social responsibility (CSR) undertakings, and contribution to economic diversification, a long-standing goal of local and national governments.

It is expected that the review will also inform the government’s policy adjustments on foreign-market development incentives, responsible-gaming initiatives, and the treatment of satellite casinos after their 31 December 2025 transition deadline. The review will therefore constitute the first comprehensive policy checkpoint of the new concession era.

Interactive Gaming

In Macau, the term “interactive gaming” (online gaming) is defined within the regulatory framework to limit the scope of online and telecommunications-based gambling activities.

In general terms, and with the sole exception of sports lotteries (football and basketball), interactive (online) gaming is not permitted. Macau enforces a strict prohibition on online gaming, covering online casinos, poker, and all forms of interactive gaming. During discussions surrounding Law No 20/2024, dated 28 October 2024 (Law to Combat Illegal Gambling Crimes), the government reaffirmed its opposition on legalising online gaming, citing significant social and regulatory concerns. Officials stated that regulating online gaming is not part of Macau’s legislative agenda. Consequently, operators are not allowed to offer online games, and individuals found facilitating such activities face severe penalties.

Furthermore, Law No 20/2024 criminalises the unauthorised operation of online gaming, covering games of chance and pari-mutuel betting. Under this law, individuals who operate, promote, or organise online gaming without appropriate legal authorisation – regardless of if the systems, devices, or servers are located in Macau – face prison sentences ranging from one to eight years, with negligent involvement in such activities also subject to legal penalties.

In summary, online gaming and interactive betting remain prohibited in Macau, except where expressly authorised by law, aside from the following.

Sports Betting

Status: permitted, with restrictions

Sports betting in Macau is limited primarily to sports lotteries, specifically for football and basketball, under exclusive concessions. While popular in many international jurisdictions, general sports betting – such as those covering a broader range of sports or events – is tightly regulated and not readily permitted without explicit government concessions. These operators are subject to regulatory oversight by the Gaming Inspection and Coordination Bureau to maintain compliance with local laws and regulations.

For operators located outside Macau – and without prejudice to what is now criminalised under Law No 20/2024 and that has been mentioned – there have been reports of international co-operation in offering online gaming services to the Macau market. However, it remains unclear if Macau residents betting on foreign offshore platforms on a passive basis is considered illegal, as Macau’s laws lack a defined basis for action against foreign operators in cross-border betting scenarios.

Macau maintains a six-concession framework for land-based casino gaming, each concession granted in December 2022 for a ten-year term ending 31 December 2032.

The Macau Gaming Law requires that all gaming operations be conducted in venues owned by the concessionaires, thereby initiating a three-year transition period ending on 31 December 2025 for properties historically operated as satellite casinos.

Under Macau’s legal framework, three types of land-based gaming are permitted.

Games of Chance

This kind of game is defined under the Macau Gaming Law (specifically Article 2.1.1) as “those in which the result is contingent because it depends exclusively or mainly on the luck of the player”. Casino games of chance and their rules are authorised by the Secretary for Economy and Finance, published in the Macau SAR official gazette, based on recommendations from the DICJ, either on its own initiative or at the request of concessionaires. Macau’s authorised casino games include a variety of traditional and regional options, such as baccarat, blackjack, craps, fan tan, poker variations (eg, Texas hold ’em), and mahjong, among others. Games can only be conducted within the casinos or gaming areas of the concessionaires.

Pari-Mutuel

Pari-mutuel (animal racing – horse and greyhound only) is defined as a “system of betting on animal racing or a sporting event in which the winners split the total amount bet, after deduction of commissions, fees and taxes in proportion to the amount individually bet” (currently there are no concessions for the operation of pari-mutuel pursuant to the termination of horse-racing concessions on 31 March 2024).

Operations Offered to the Public

Under the Macau Gaming Law, operations offered to the public are “those in which the hope of winning [depends] solely on luck, such as lotteries, raffles, tombola and sweepstakes”. Sports betting on football and basketball is allowed under an instant lotteries’ concession contract established before the 2001 Gaming Law.

Social games are also permitted.

The primary legislation is set out below in chronological order. The list does not include secondary legislation.

Games of Chance

• Decree-Law No 47/98/M, dated 26 October 1998 (Administrative Licensing Legal Framework).
• Decree-Law No 39/99/M, dated 3 August 1999 (Article 1171 of the Macau Civil Code).
• Decree-Law No 40/99, dated 3 August 1999 (Commercial Code: gaming companies and commercial contracts).
• Law No 16/2001, dated 19 September 2001, with the amendments introduced by Law No 7/2022 (the “Macau Gaming Law”: setting the general framework for the operation of games of fortune in casinos).
• Administrative Regulation No 26/2001, dated 29 October 2001, with the amendments introduced by Administrative Regulations Nos 34/2001, 4/2002 and 28/2022 (sets the general terms of the public tender required to select the concessions to operate games of fortune in casinos, as well as the suitability and financial capacity requirements of bidders and concessionaires).
• Law No 10/2012, dated 27 August 2012, with the amendments introduced by Law No 17/2018 (frequency of casinos).
• Administrative Regulation No 26/2012, dated 26 November 2012 (sets the rules applicable to the supply of gaming machines and related gaming equipment).
• Administrative Regulation No 19/2021, dated 21 June 2021 (DICJ framework).
• Administrative Regulation No 32/2022, dated 28 July 2022 (creates the Macau Gaming Commission).
• Administrative Regulation No 54/2022, dated 7 December 2022 (sets the rules for reduction or exemption of additional contributions).
• Law No 16/2022 of 16 December 2022 (regime of operation of casino games of chance).
• Administrative Regulation No 55/2022, dated 21 December 2022 (regulation of the regime of operation of casino games).
• Law No 7/2024 of 22 April 2024 (regime of credit for casino games of chance).

Lotteries and Sports Lotteries

• Ordinance No 27/86/M, dated 1 February 1986 and Law No 12/87/M, dated 17 August 1987 (Instant Lottery).
• Concession Contract awarded to SLOT – Sociedade de Lotarias e Apostas Mútuas Limitada, dated 21 February 1989, valid until 2026.
• Ordinance No 138/98/M dated 5 June 1998 (Sports Lottery – Football).
• Chief Executive Order No 62/2000, dated 27 April 2000 (Sports Lottery – Basketball).
• Executive Order No 8/2004 of 3 March 2004 (Lottery “Pacapio”).
• Executive Order No 20/2005 of 27 May 2005 (basketball betting).
• Executive Order No 67/2018 of 20 April 2018 (football betting).

Pari-Mutuels

• Decree-Law No 7611 of 26 August 1964 (regulation for greyhound racing), with amendments.
• Ordinance No 163/90/M, dated 27 August 1990 (horse racing and pari-mutuels).

Note: the legislation on greyhound racing has not been revoked, despite there being no concession in place for that activity.

Criminal Penalty Regime

• Law No 6/97/M, dated 30 July 1997 (Organized Crime Act), partially revoked.
• Law No 16/2001, with the amendments introduced by Law No 7/2002 (48-B establishes the crime of disobedience for entities that do not allow the authorities to enter the gaming premises subject to supervision, as well as administrative sanctions).
• Law No 2/2006, dated 3 April 2006 (Anti-money Laundering Act).
• Law No 3/2006, dated 3 April 2006 (Anti-terrorism Financing Act).
• Administrative Regulation No 7/2006, dated 7 April 2006 (preventive measures for the crimes of money laundering and financing of terrorism).
• Instruction No 1/2016, dated 21 April 2016, with amendments introduced by Instruction No 1/2019 (DICJ’s Instruction on Anti-money Laundering and Combatting the Financing of Terrorism for the Gaming Sector).
• Law No 20/2024, dated 28 October 2024 (Law on Combating Illegal Gambling Crimes).

Gambling is defined under the Macau Gaming Law as “[games] in which the result is contingent because it depends exclusively or mainly on the luck of the player”.

See 3.2 Definition of Gambling.

According to Article 2.1.2 of the Macau Gaming Law, interactive gaming encompasses games of fortune or chance under specific conditions that both define and restrict this category.

• Interactive gaming must involve the opportunity to win a prize, which can either be in cash or another item of value. This prize offer is essential to the game’s structure and must be in accordance with the game’s official rules.
• Players participate through telecommunications technologies, including phones, fax, internet, data networks, video signals, or digital data transmission, and players must either make, or agree to make, payments to engage in the game, whether in cash or other valuables.
• Games must be offered or formally approved as casino games of chance, or as electronic or mechanical gaming machines within Macau casinos.

There are different offences stated in the Macau gaming legal and regulatory framework with different penalties depending on the nature.

Criminal Nature

Under the Gaming Law, simple disobedience (Article 48-B) is a crime applying to individuals who obstruct inspection authorities, such as the DICJ or the Financial Services Bureau, by refusing them entry, failing to allow them to complete inspections, or withholding requested documents and data.

Law No 16/2022 introduced the crime of illicit deposit (Article 40), which targets casino concessionaires, gaming promoters, and related personnel who accept funds not intended for gaming purposes. This offence is punishable by two to five years of imprisonment for individuals, with fines up to MOP10.5 million or judicial dissolution for entities.

Disobedience (Article 41) under Law No 16/2022 reaffirms penalties for refusal to comply with inspection authority requirements, supporting enforcement within Macau’s gaming regulatory environment.

Regarding unlawful gambling, see 3.6 Penalties for Unlawful Gambling.

Administrative Nature

Under the Macau Gaming Law (Article 45), the Chief Executive may terminate a casino concession for threats to Macau’s or national security (that of China), significant obligation breaches, public interest, or unsuitability of the concessionaire. Concessions also end by mutual agreement, reversion, or expiration.

In addition (Article 47), the Chief Executive may unilaterally terminate a concession for abandonment, non-payment, unauthorised transfer of rights, or unfulfilled investment obligations. All associated assets revert to Macau SAR without compensation.

Finally, it should be noted that, according to Article 48, the Chief Executive may terminate a concession if the casino concessionaire endangers national or Macau’s security or is deemed unsuitable.

Contractual Nature

Casino concession contracts in Macau outline significant penalties for unauthorised actions, such as the transfer, disposal, or encumbrance of casino operations.

Under Law No 20/2024, there are distinct penalties for unlawful gambling activities in Macau, with various offences covered.

• Unlicensed games of chance – operating unauthorised games of chance is punishable by imprisonment of one to eight years. Anyone collaborating in such activities can face up to three years in prison or a fine of up to 360 days.
• Participation in unlawful games – engaging in illegal gambling is penalised with imprisonment of up to six months or a fine of up to 180 days. Being present in unauthorised gambling establishments may incur a fine of up to 90 days.
• Unlicensed pari-mutuel betting – unauthorised pari-mutuel betting operators face one to eight years of imprisonment, while collaborators may receive up to three years in prison or a fine of up to 360 days.
• Unlicensed online gambling – organising or promoting online games of chance or pari-mutuel betting without authorisation results in one to eight years of imprisonment. Negligence in such cases is also punishable.
• Illegal lottery operations – running or selling unauthorised lottery tickets may lead to prison sentences of up to three years or fines of up to 360 days for operators, and up to two years or 240 days for unauthorised ticket sellers.
• Unlawful loans and currency exchange – providing loans for gambling purposes can result in prison terms of one to five years, or up to eight years if identification documents are used as guarantees. Unauthorised currency exchange related to gambling carries a maximum sentence of five years.
• Coercion and fraud in gambling – coercing someone to gamble through violence or threats is punishable by two to eight years in prison. Fraudulent gambling practices or using counterfeit gaming tokens may lead to prison sentences of one to five years.

The DICJ, organically under the Secretary for Economy and Finance, is the public authority of Macau SAR responsible for collaborating in the formulation of gaming industry policies, implementing these policies, and overseeing the regulation, supervision, and co-ordination of gaming operations and activities. Its organisation and functions are governed by Law No 19/2001, which defines its duties as follows:

• assisting in defining, co-ordinating, and implementing gaming industry policies;
• ensuring that casino gaming concessionaires, management companies, gaming promoters, and related entities abide by Macau SAR laws and uphold public interests;
• supporting the drafting and refinement of gaming regulations and issuing necessary guidelines to relevant entities;
• monitoring activities of casino gaming concessionaires, gaming promoters, and others to ensure compliance with legal and contractual requirements;
• evaluating the financial capacity and suitability of concessionaires and other gaming-related entities;
• overseeing all gaming activities to ensure they operate lawfully;
• enforcing compliance with gaming laws;
• tracking gross gambling revenue and other specified earnings;
• conducting studies and research on gaming-related issues;
• granting licences for casino game promotion activities;
• regulating, inspecting, and approving gaming machines, equipment, and systems;
• approving equipment and systems for use by casino gaming concessionaires;
• encouraging casino gaming concessionaires and gaming promoters to comply with government policies and fulfil social responsibilities;
• promoting responsible gambling practices; and
• performing other legally mandated responsibilities.

Other Agencies

In addition to the DICJ, other regulatory entities are empowered to oversee the gaming industry.

• Financial Services Bureau (DSF) – responsible for managing and collecting all revenues owed to Macau SAR. In co-ordination with the DICJ, it also has the authority to conduct audits of casino gaming concessionaires and promoters to ensure adherence to financial obligations and regulatory standards.
• Judiciary police (PJ) – operate a dedicated unit with exclusive authority to investigate crimes within casinos, other gaming venues, and their surrounding areas.
• Financial Intelligence Office (GIF) – gathers and analyses the information related to potential money laundering and terrorist financing.
• Social Welfare Bureau (IAS) – addresses issues related to problem gambling, providing resources and support to mitigate the social impact of gambling.
• Health Bureau (SS) – responsible for enforcing the casino smoking ban, ensuring compliance with public health regulations in gaming establishments.

Macau’s gaming regulatory framework is a hybrid system, combining prescriptive requirements with risk-based elements.

Embedded within prima facie casino gaming concession contracts, the framework outlines strict guidelines and operational standards for concessionaires, promoters, and other industry stakeholders. It mandates comprehensive regulations for licensing, financial reporting, and operational practices – eg, internal control guidelines of the DICJ – while setting clear expectations for compliance with laws and regulations.

In parallel, Macau’s model incorporates risk-based regulation, especially in anti-money laundering (AML) and counter-terrorism financing (CTF/CFT). Agencies such as the Financial Intelligence Office apply risk indicators to assess transactions and monitor activities, enabling resource prioritisation toward higher-risk areas and tailored regulatory actions to safeguard the region’s financial stability.

Macau’s gaming industry operates under an administrative concession model, where the government grants concessions to legally incorporated entities through administrative concession contracts. This approach applies to the operation of casino games, lotteries and Chinese and sports lotteries. For casino gaming, concessions are awarded via an international bidding process organised by the Macau SAR government, and only a maximum of six concessions are permitted under current statutes.

To qualify, applicants must be Macau-incorporated limited liability companies with a registered share capital of at least MOP5 billion (USD625 million). The company’s business scope must include casino gaming, and a Macau permanent resident must hold at least 15% of the share capital and act as managing director. Applicants, qualified shareholders, directors, and key employees undergo a suitability assessment by the DICJ to ensure they meet stringent legal and financial standards. Financial capacity must be demonstrated through guarantees from financial institutions or primary shareholders.

In the most recent 2022 international tender, seven entities competed for six available concessions, which were awarded to existing operators Wynn Resorts (Macau) SA, MGM Grand Paradise, SA, Galaxy Casino, SA, SJM Resorts, SA, Venetian Macau, SA, and Melco Resorts (Macau), SA. These ten-year contracts took effect on 1 January 2023, and will run through 31 December 2033.

Law No 16/2022, governing casino operations, also introduces a licensing requirement for gaming promoters, and all casino management companies and gaming promoter collaborators must obtain authorisations.

Casino Gaming Concessions

In Macau, the operation of casino games is strictly regulated, requiring the award of a concession. Applications for these concessions are permitted only when the Macau government initiates a formal tender process, which is both limited and competitive. While this process provides entry points for eligible operators, it is unlikely that new tenders will be offered in the foreseeable future.

Gaming Promotion

Alongside the concession for the operation of casino games, the government also issues specific licences exclusively for gaming promoters who engage with the casino gaming concessionaires to support and promote gaming activities within their casinos. These licences are available for gaming promoters.

Gaming Equipment

The authorisation regime in Macau for gaming machines, equipment, and systems is governed by stringent regulatory requirements. Only manufacturers with authorisation from the DICJ are permitted to supply gaming machines in the region. This authorisation mandates that suppliers meet high standards in terms of technical specifications, quality control, and operational security. Additionally, gaming machines must comply with technical standards approved by Macau, undergo rigorous inspections, and be compatible with the electronic monitoring systems required by the DICJ.

Casino Gaming

Under the Macau Gaming Law, the maximum term for a gaming concession is set at ten years. However, extensions can be granted in exceptional cases, allowing renewals of up to three additional years if justified and approved by the Chief Executive.

Gaming concessionaires undergo a performance review every three years, ensuring ongoing compliance with contractual obligations. According to Article 45, the Chief Executive, with input from the Specialised Commission for Casino Games, holds authority to terminate a concession based on several grounds, including risks to national or Macau security, mutual agreement with the concessionaire, non-compliance, and reasons of public interest.

Unilateral termination can also occur if a concessionaire fails to meet critical obligations, such as abandoning or suspending operations without cause, unauthorised transfers of operations, failure to pay required taxes or premiums, or neglecting investment commitments stipulated in the concession contract.

Additionally, the Macau government retains the right to redeem or order administrative intervention (sequestration) of a concession in specific circumstances. Should termination or redemption occur, Macau can assume control of the casinos and gaming assets, reinforcing the government’s commitment to regulatory integrity in the gaming sector.

A key transitional issue remains the status of satellite casinos, which must, under the law, operate from premises owned by the casino concessionaires by 31 December 2025.

This ongoing adjustment continues to influence supply contracts, property leases, and employment structures across the sector.

Some third-party-operated venues have already closed or been absorbed into concessionaire portfolios.

The outcome of this transition will shape the geographic and operational configuration of Macau’s gaming market for the remainder of the concession period.

Gaming Promotion

The validity of a gaming promoter licence in Macau, as specified in Law No 16/2022, is initially from the date of issuance until 31 December of the following year. After the initial period, the licence can be renewed annually. Each renewal extends the licence for an additional year, contingent upon continued compliance with licensing requirements and suitability assessments.

Gaming Equipment

The authorisation is granted if the conditions are met, and the authorised entities shall submit an application to renew the authorisation every year to continue supplying gaming equipment.

Additionally, a mandatory suitability review is required every six years.

Casino Gaming Concessions

The process of applying for a concession is regulated by Administrative Regulation No 26/2001. As mentioned, Macau operates under a concession system. This system grants a concession to operate to successful applicants following a public tender. The process begins with the establishment of a tender committee by the Executive. Interested companies/bidders, along with their directors, key employees and shareholders holding more than 5% of the share capital, undergo a suitability and financial capacity assessment supervised by the DICJ before receiving authorisation. Once the public tender is concluded and all requirements and criteria are met, a concession contract is signed between the concessionaire and the Macau government, providing further legitimacy to the casino gaming concessionaire’s operations.

Gaming Promotion Licence

As for the gaming promotion activity, Law No 16/2022 lays out rigorous conditions to ensure that only qualified entities meet the standards to be licensed as gaming promoters, with requirements on corporate structure and purpose, financial capacity, residency and ownership, suitability, existence of an operational agreement, as well as a guarantee to ensure compliance. The following provides a summary.

• The entity must be a legally established company in Macau, specifically structured as a limited liability company by shares. Importantly, its exclusive business scope must be limited to gaming promotion.
• Applicants are required to maintain a minimum capital of MOP10 million (approximately USD1.25 million), fully paid in cash upon incorporation. This capital threshold must be maintained throughout the licence period to ensure financial resilience and responsibility in operations.
• At least 50% of the company’s share capital must be owned by Macau permanent residents who are at least 21 years old. Additionally, all shareholders must be individuals legally capable of exercising their rights, ensuring local representation and accountability.
• The company, along with its major shareholders, directors, and key employees, must undergo a suitability review conducted by the DICJ. This assessment checks for financial stability, outstanding debts, unresolved legal fines related to gaming, and the absence of any bankruptcy or insolvency history among stakeholders.
• Applicants must secure an agreement with a licensed casino concessionaire to provide gaming promotion services. This partnership must be formalised and is a crucial prerequisite for obtaining the promoter licence.
• To ensure compliance with Macau’s stringent gaming regulations, promoters must provide a financial guarantee as stipulated by law.

Gaming Equipment Authorisation

To secure authorisation from the DICJ, gaming machine manufacturers must provide comprehensive documentation, including proof of authorisation from relevant jurisdictions, records of compliance, and details of authorised machine models. Additionally, applicants must submit a notarised legal declaration affirming the standing of existing licences and a full disclosure of ownership structure, focusing on stakeholders with 5% or greater capital involvement.

Casino Gaming Concessionaires

For casino gaming concessions, the timeline follows the schedule set out in the public bidding rules, which defines the phases and deadlines for application, evaluation, and awarding.

Gaming Promoters

There is no set timeline for gaming promoter licences. The time required for approval depends on how quickly applicants meet all specified requirements, as each application undergoes a detailed review to ensure compliance with regulatory standards.

Gaming Equipment Manufacturers and Distributors

There is no set timeline for the authorisation to be granted. As with gaming promoters, the time required for approval depends on how quickly applicants meet all specified requirements, as each application undergoes a detailed review to ensure compliance with regulatory standards.

Macau’s casino concession tender process establishes clear guidelines to ensure that applicants meet the highest standards for operating gaming activities. The tender programme specifies minimum requirements for applicant eligibility, including financial capacity, suitability, and the ability to contribute positively to Macau SAR. Applicants must also offer terms that align with the proper and advantageous operation of casino games in Macau.

To participate, applicants must provide a guarantee deposit, the amount of which is set by an order from the Chief Executive.

Casino concessionaires in Macau are obligated to pay an annual premium, consisting of a fixed and a variable portion, for the right to operate games of chance. The fixed portion is currently set at MOP30 million, as determined by the Chief Executive’s Dispatch No 215/2001. The variable portion is based on the specific gaming activities conducted, with costs assigned per type of gaming table and machine: VIP tables incur MOP300,000 each, non-VIP tables MOP150,000 each, and gaming machines MOP1,000 each. Contracts also establish a minimum guaranteed amount for this variable premium portion, regardless of the number of tables operated.

A special premium applies when gaming tables or machines fail to meet an annual minimum gross revenue, as set in Dispatch No 162/2022. This special premium is MOP7 million per gaming table and MOP300,000 per gaming machine and compensates for the difference between actual and minimum revenue.

Additionally, concessionaires must make special contributions during the concession term. These include a 2% contribution of the GGR to a public fund for cultural, social, and educational initiatives, and a 3% contribution to support urban development, tourism promotion, and social security. The Chief Executive may reduce or waive these contributions under specific conditions, such as efforts to expand customer markets or the occurrence of extraordinary, unforeseen events that negatively impact Macau’s economy and casino operations.

Regarding gaming promoters, under Dispatch No 232/2022, there are specific fees for gaming promoters and collaborators, as follows.

• Gaming Promoter Licence – issuance and renewal fees are set at MOP3,000, with a MOP500 fee for a replacement copy.
• Collaborator Authorisation – issuance and renewal fees are MOP1,500, and a replacement copy incurs a fee of MOP200.

Macau’s gaming legislation does not create individual “personal licences” but requires that certain persons involved in the supervision, management, and operation of casino gaming be suitable to perform their functions.

Persons subject to suitability verification include:

• the directors of concessionaires, gaming promoters, management companies, and gaming-machine manufacturers;
• key employees occupying senior positions in operations, finance, administration, compliance, human resources, legal affairs, and IT; and
• collaborators engaged by gaming promoters to assist in gaming-promotion activities.

Suitability assessments are conducted by the DICJ through standardised disclosure forms modelled on international practice. The review covers integrity, financial capacity, and professional qualifications, and authorisations remain subject to continuing compliance throughout the concession or authorisation term.

The concessionaires or promoters bear the costs of verification for directors and key employees in accordance with their concession contracts or DICJ schedules, while collaborators pay an issuance or renewal fee of MOP1,500.

Although no personal sanctions are provided in law, an adverse suitability finding may result in the suspension or revocation of the related concessionaire’s or promoter’s approval, ensuring accountability through indirect regulatory consequence.

The 2022 reform in Macau introduced updates to the definition and regulation of casino gaming premises, summarised as follows.

Authorised Locations Only

Gaming is now exclusively permitted in venues authorised by the Chief Executive. Approval takes into account Macau’s urban planning standards and social impact, with insights from the Specialised Gaming Commission to ensure community alignment.

Property Ownership Requirements

Casinos, together with the associated gaming equipment and assets, reverted to Macau SAR on 31 December 2022 – at the end of the previous concessions – and were placed at the disposal of the concessionaires as of 1 January 2023 under their new concession contracts, in return for the payment of rent.

Pursuant to Law 16/2022 (Gaming Law), all casino gaming must be conducted in properties (hotels and resorts) owned by the concessionaires, with limited exceptions allowing temporary gaming on Macau-registered vessels or aircraft operating on designated routes outside the region.

A grace period ending on 31 December 2025 was granted for the adjustment of satellite casinos operating in premises not owned by concessionaires, to ensure compliance with the new ownership and use requirements applicable to gaming areas. See 1.1 Current Outlook and Recent Changes.

Regulated Casino Zones

Every gaming establishment must include specific functional zones, which include designated areas for gaming, cashier and treasury operations, surveillance, storage for chips and cash, and restricted logistical spaces for employees.

Modification and Closure Approvals

All structural changes or closures of casino premises require prior approval from the Chief Executive. Upon concession expiry or termination, casino facilities and equipment – that are not already property of Macau SAR – may revert to government control, reinforcing regulatory oversight.

Enhanced Security and Compliance Measures

Casinos are required to implement rigorous surveillance and monitoring systems as mandated by Macau’s regulatory bodies.

B2C licences are not applicable in Macau.

B2B licences are not applicable in Macau.

The use of affiliates does not apply in Macau.

In Macau, white labels do not apply.

Technical measures are not applicable in this jurisdiction.

The RG requirements are stated in the Macau Gaming Law (Articles 42-A and 42-B) which mandates casino concessionaires to actively promote responsible gambling. This includes offering clear information on safe gambling practices and the risks of addiction, as well as enforcing access restrictions for individuals who are barred from entering casinos.

The concession contracts expand on these responsibilities, mandating that each casino gaming concessionaire establish a specialised team dedicated to responsible gambling support. This team is tasked with assisting individuals impacted by gambling-related issues and training staff to identify and respond to signs of problem gambling. Additionally, concessionaires must submit annual reports to the DICJ, outlining their responsible gambling activities and plans for the upcoming year.

See 7.1 RG Requirements.

Macau has implemented measures to encourage responsible gambling practices, including allowing individuals and their family members to voluntarily ban themselves from entering casinos for a period of up to two years. This confidential process is managed through the DICJ.

Following the 2022 amendment to Macau’s Gaming Law, new regulations have been put in place. These require casinos to develop and implement comprehensive responsible gambling strategies, including:

• restrictions on gambling-related advertisements;
• limitations on the placement of ATMs within casino premises; and
• mandatory provision of support resources for those affected by gambling issues.

As part of these support resources, casinos must offer access to helplines and information about treatment centres for individuals seeking assistance with gambling-related problems.

Macau’s casino industry adheres to strict AML standards, overseen by the DICJ and aligned with APG (Asia/Pacific Group on Money Laundering) guidelines.

Casino concessionaires must conduct customer due diligence, report suspicious transactions, and undergo independent annual audits. Meticulous accounting and accessible record-keeping are mandated, with auditors required to immediately report any suspected money laundering. The DICJ and the DSF may perform unannounced audits, and the Chief Executive may order further financial audits for public interest.

Key legislation includes the following.

• Law No 2/2006 and No 3/2006 (amended by Law No 3/2017) for AML/CFT measures.
• Administrative Regulation No 7/2006 (amended by Administrative Regulation 7/2017) on AML/CFT preventive protocols.
• DICJ Instruction 1/2016 (amended by Instruction 1/2019) outlining preventative measures required of gaming operators.

Macau’s AML framework for casinos requires rigorous transaction reporting and internal compliance.

High-Value Reporting (ROVE)

For high-value transactions of MOP500,000 (USD62,500) or more within 24 hours, a report – known as “ROVE” – must be completed within two business days. The ROVE must include details such as the individuals involved, transaction amount, origin of funds, and compliance officer approval. It is submitted to the DICJ electronically on the 1st and 15th of each month.

Suspicious Transaction Reports

Suspicious activities, regardless of amount, are reported to the Financial Intelligence Unit through an STR within two working days of detection. Casinos must report any gaming, betting, or credit activities that seem unusual in nature, complexity, or amount and could indicate money laundering or terrorist financing. If customer due diligence alerts a patron to the investigation, it is permissible to delay actions as long as the transaction is still reported as suspicious.

Internal AML Programme Requirements

Casinos must also maintain an internal AML programme that includes continuous staff training and assessments of their control systems to ensure AML/CFT measures are effective. The Chief Executive sets specific AML programme standards, considering Financial Action Task Force (FATF) recommendations and evaluation reports, to enhance the effectiveness of these preventative measures.

The primary regulatory bodies overseeing advertising in Macau include the Economic and Technological Development Bureau (DSEDT), which monitors compliance with advertising standards, and the Gaming Inspection and Coordination Bureau, which specifically regulates advertising within the gaming industry.

There is no specific definition of advertisement of gaming in Macau. Nonetheless, under Law No 7/89 (Macau’s Advertising Law, which is currently under review – see 1.1 Current Outlook and Recent Changes) an advertisement is broadly defined as any public communication intended to promote products, services, or activities, regardless of the medium used. This definition includes all promotional materials aimed at influencing consumer behaviour or raising awareness of a specific activity or service.

Promotional activities within casinos require the DICJ’s approval.

Law No 7/89/M regulates advertising content and methods, with specific restrictions on games of chance. Advertising that directly promotes games of chance is prohibited, although information related to gaming can be shared in limited contexts like classified listings or yearbooks. The law aims to control public exposure to gaming advertisements, restricting promotional activities outside approved venues and minimising the impact on the general public.

This restrictive stance was formalised in June 2015 with guidelines clarifying what qualifies as illegal advertising of games of chance, limiting these rules strictly to gaming-related promotions.

In July 2019, the DICJ extended these rules to non-gaming commercial activities within casinos. Concessionaires and promoters must now obtain prior approval for any promotional activities within casino premises, covering verbal announcements, media displays, and physical promotional materials, further underscoring Macau’s commitment to regulating gaming advertisement.

Despite the aforesaid restrictions, under Macau’s gaming law and concession contracts, casino gaming concessionaires are required to promote their developments both locally and internationally, positioning Macau as a top destination for tourism and entertainment. These advertising efforts align with the government’s goal of economic diversification, extending Macau’s appeal beyond gaming.

Concessionaires must also work closely with the Macau government on global promotional initiatives, supporting campaigns that showcase Macau’s unique offerings.

Violations of gaming advertising regulations incur administrative fines of MOP2,000 to MOP12,000 for individuals and MOP5,000 to MOP28,000 for companies.

Disclosure Requirements

The disclosure requirements for Macau casino concessionaires and shareholders, particularly those holding 5% or more of the share capital, are outlined under the Macau Gaming Law and concession contracts.

Key obligations include the following.

• Any transfer or encumbrance of shares, or other rights related to these shares, by the concessionaire or shareholders holding 5% or more of the company’s capital, requires prior authorisation from the Secretary for Economy and Finance. This includes actions such as assigning voting rights to non-shareholders, transferring real or credit rights exceeding limits set in the concession contract, and entering into loan agreements above specified thresholds. Failure to obtain this authorisation renders the actions null and void.
• Furthermore, if a shareholder’s interest is transferred by inheritance, the concessionaire must inform the DICJ within 15 days of the inheritance, along with relevant documents.

Once authorisation is granted, concessionaires are required to submit supporting documents to the DICJ within 30 days of the transaction.

Cross-Shareholding

There are legal restrictions on cross-shareholding among casino gaming concessionaires, prohibiting a concessionaire or a qualified shareholder from directly owning shares in another casino concessionaire or indirectly holding 5% or more of the share capital in another concessionaire.

Foreign Gaming and Public Listing

The concessionaire must inform the DICJ within 15 days of becoming aware that any of its directors or any shareholder holding, directly or indirectly, 5% or more of its capital are involved in licensing or concession processes for operating casino games of chance in other countries or regions, commencement or cessation of such gaming operations abroad.

The same applies if any shareholders holding 5% or more of the concessionaire’s capital, directly or indirectly, are listed on a stock exchange.

If a concessionaire wishes to operate games of chance in casinos in other countries or regions, it must obtain prior authorisation from the Chief Executive, following consultation with the Specialised Committee on Games of Chance. To meet this requirement, the concessionaire is obligated to submit to the Macau SAR government, or make efforts to obtain and submit, any documents, information, or data requested for this purpose, except for those deemed confidential by law.

See 10.1 Disclosure Requirements.

See 10.1 Disclosure Requirements.

Under Macau’s gaming laws, regulations, and casino gaming concession contracts, the DICJ is granted a comprehensive set of enforcement powers.

These allow the DICJ to, among other things:

• perform regular and unannounced inspections of gaming premises to ensure compliance with legal and contractual obligations – inspectors may access all areas of a casino, review operational practices, and examine pertinent documents to verify adherence to regulations;
• impose fines and other penalties in cases of regulatory violations;
• actively monitor revenue flows and conduct periodic financial audits to promote financial transparency and mitigate risks of money laundering and other illicit activities; and
• license gaming promoters and approve gaming equipment and systems used within casinos.

See 3.5 Key Offences and 3.6 Penalties for Unlawful Gambling.

Criminal Sanctions

The Gaming Law establishes the offence of simple disobedience (Article 48-B), applicable to anyone who refuses to permit inspection staff from the DICJ or the Financial Services Bureau to enter and remain in inspection areas until the inspection is complete, or who fails to present and provide requested documents and data as required by law.

As mentioned, the recently enacted Law No 20/2024 also criminalises certain conducts with imprisonment of up to eight years.

The Criminal Procedure Code in Macau governs the entire criminal process, starting with investigation and evidence collection, where the judiciary police conduct inquiries, gather evidence, and collaborate with specialised agencies on financial crimes. Following this, the Public Prosecutions Office (MP) evaluates the evidence and decides on filing charges, ensuring due process in accordance with the Code. Judicial process and sentencing take place in court, where structured trials assess evidence and legal arguments. Sentences, including imprisonment and/or fines, are then imposed if defendants are found guilty by a decision that cannot be appealed.

Administrative Sanctions

With the 2022 reform, the Macau Gaming Law now clearly defines administrative penalties for non-compliance, with fines scaled by the severity of the offence. Previously, administrative offences were managed under various laws, including those addressing illegal gambling, AML, and advertising.

Sanctions include the following:

• minor offences – fines from MOP100,000 to MOP500,000 for violations like breaches in accounting or internal controls;
• serious offences – fines between MOP600,000 and MOP1.5 million for failures to meet capital requirements or similar infractions; and
• grave offences – fines from MOP2 million to MOP5 million for severe violations such as unauthorised gaming or use of non-owned properties for gaming activities.

Law No 16/2022 (Law on Operation of Casino Games) further specifies fines for specific infractions, such as up to MOP500,000 for failure to submit management contracts and up to MOP5 million for exceeding commission limits. Additional penalties can include partial or full casino closures for up to one year or public disclosure of the sanctions imposed.

In addition to fines, the law authorises further sanctions, including temporary bans on credit extension or representation contracts for up to one year and mandatory public disclosure of violations.

Law No 7/2024 (Credit for Casino Gaming Law) introduced administrative sanctions for non-compliance, with concessionaires and gaming promoters now face stricter financial penalties based on offence severity, as follows.

• Severe violations – fines of MOP2 million to MOP5 million apply for unauthorised credit activities and critical regulatory breaches.
• Moderate violations – fines from MOP600,000 to MOP1.5 million target failures in contract compliance and oversight.
• Minor violations – fines of MOP100,000 to MOP500,000 are imposed for less serious infractions.

The severity of fines and additional sanctions under Law No 7/2024 is determined by key factors, including:

• the gravity of the offence;
• the harm caused;
• the offender’s level of fault and financial capacity;
• any benefits gained from the violation; and
• the offender’s prior conduct.

Administrative sanctions in all legal instances are imposed under the Administrative Procedure Code, which establishes the legal standards for handling these offences. Regulatory authorities such as the DICJ follow this Code’s structured procedures for investigating infractions, issuing fines, suspending licences, and applying other penalties, with adherence to due process and appeal rights. The DICJ serves as the primary enforcement body in the gaming industry, imposing sanctions for violations such as breaches of concession contracts or regulatory non-compliance.

Contractual Sanctions

Casino gaming concession contracts include penalty clauses that impose sanctions in cases of assignment, transfer, disposal, or encumbrance of the operation of a casino or gaming area.

These penalties range from MOP600 million to MOP2 billion.

Further sanctions may include sequestration, redemption, or termination of the concession.

• Sequestration – this allows the government to temporarily assume control of a concession if there are serious operational issues, such as unjustified interruptions or severe organisational deficiencies.
• Redemption – Macau reserves the unilateral right to reclaim a concession through redemption, with compensation to the concessionaire, as determined by the government.
• Termination (stated in the concession contracts) – the government can also terminate a concession based on public interest or non-compliance. In cases of termination for public interest, the concessionaire is entitled to fair compensation, reflecting investments made and the remaining duration of the concession.

See 11.2 Sanctions.

Games of Chance

Under Article 27 of the Macau Gaming Law, casino gaming concessionaires must pay a special gaming tax of 35% on gross gaming revenue, payable by the 10th day of each month. In addition, gaming operators are required to contribute 2% of their GGR to public funds for cultural, scientific, social, economic, and educational development, as well as an additional 3% for urban development, tourism promotion, and social security initiatives. A 5% tax is also applied to commissions paid to gaming promoters.

See also 4.9 Ongoing Annual Fees regarding annual premium and special premium.

Despite this taxation structure, the Macau Gaming Law grants the Chief Executive the authority to partially or fully exempt operators from the Income Complementary Tax if deemed in the public interest.

Operations Offered to the Public (Lotteries, Including Sports Lotteries)

The operator for instant lotteries, including the sports lottery, must pay a minimum annual rent of MOP1 million. The rent is determined based on sales revenue thresholds as follows:

• for sales revenue from MOP0 to MOP10 million, a rent of MOP1 million is due;
• for revenue between MOP10,000,001 and MOP30 million, 12% of the excess is due as rent;
• for revenue between MOP30,000,001 and MOP45 million, 13% of the excess is due;
• for revenue between MOP45,000,001 and MOP60 million, 14% of the excess is due; and
• for revenue between MOP60,000,001 and MOP80 million, 16% of the excess is due.

Pari-Mutuel

This is not in operation and it is not foreseeable that it will be in the future.