Costa Rica

This points toward near-term market-structure contraction and consolidation among private land-based operators rather than expansion. The state lottery operator Hrvatska Lutrija retains a favourable low-risk exemption from several of the new restrictions, structurally advantaging the state entity relative to private operators. The progressive winnings tax, projected to raise 50 to 70 million euros annually, signals a market of meaningful fiscal scale, but the reform's overall trajectory — tightening across fees, tax, marketing, and distribution simultaneously — suggests that near-term commercial opportunity for new private entrants is constrained rather than expanding. Absent T1 market-size data, the opportunity assessment is held at the Uncertain tier.

Separate licence categories exist for land-based casinos, betting shops, and arcades. Lotteries are operated by the state entity Hrvatska Lutrija under a low-risk gaming exemption that places them outside several of the new restrictions. The issuing authority is the Ministry of Finance, which retains licensing administration and the self-exclusion system pending the constitution of a new dedicated regulatory agency provided for under the Act but not yet confirmed as operational. No per-pathway capital requirements or fit-and-proper test detail were available in the structured evidence this cycle; those conditions remain a gap. The land-based coupling combined with approximately 50 percent higher annual licence fees materially raises the structural barrier to entry for any cross-border online operator.

No marketing restrictions apply to Costa Rica-registered gambling operators with respect to their offshore-facing activity. Operators market globally from CR with no responsible-gambling advertising requirement and no CR authority regulating offshore-facing gambling advertising. This is the most permissive marketing environment in the dataset; host-country advertising rules remain the operative constraint.

The new Gambling Act, grounded in DURABLE primary legislation, materially expanded the enforcement toolkit available to the Croatian regulator. Licence revocation and multi-million-euro fines are now available for non-compliance, and the regulator is empowered to impose direct penalties or suspend advertising for breaches — all statutory powers carrying DURABLE durability. The enforcement record to date centres on the IP-blockade regime: over 900 unlicensed gambling websites were blocked by government order ahead of the reform's full implementation, a probable enforcement action demonstrating the government's willingness to use administrative blocking at scale. Enforcement is now extending toward payment-level controls, with PSPs and financial entities compelled to halt suspicious transactions to unlicensed operators and banks required to block payments to blacklisted operators — a FRAGILE-durability obligation pending instrument citation. No individual enforcement actions against named licensed operators were confirmed this cycle. The unregulated-sector enforcement theory follows the civil-law statutory-licensing-stack model: unlicensed gambling offered to Croatian residents constitutes a primary offence under the Gambling Act itself, with secondary vectors of IP-blocking, payment blocking, and advertising prohibition. The EUROMAT and HUPIS TRIS non-notification complaint introduces legal-validity uncertainty over the reform's enforceability, but this does not constitute a safe harbour for unlicensed operators.

Gambling operators licensed in Croatia are designated reporting entities subject to customer due diligence, enhanced due diligence for politically exposed persons, and suspicious transaction reporting obligations under the EU AML framework. No jurisdiction-specific AML/CFT change was evidenced in the structured claims this cycle, and no MONEYVAL mutual evaluation result or national AML action plan was located. The practical burden of AML/CFT compliance for a Croatian-licensed operator is therefore assessed against the EU harmonised framework baseline, but the absence of fresh T1 AML evidence means the specific domestic implementation depth — STR thresholds, CTR requirements, beneficial-ownership register obligations — cannot be confirmed from this cycle's evidence. This gap is flagged for resolution in the next cycle.

Self-exclusion is requestable by the player, family members, doctors, or social-care workers, including on an indefinite basis. Operators must adopt a socially responsible gambling charter tied to the National Strategy for the Prevention of Gambling Addiction to 2030, developed with the Ministry of Health, the Croatian Institute of Public Health, and academic experts — an obligation grounded in an enabling Act with delegated detail carrying MIXED durability. These obligations collectively require investment in identity-verification systems, register-integration infrastructure, and ongoing compliance monitoring that did not exist under the prior 2009 and 2015 regime.

Costa Rica applies a territorial tax system: income from non-CR-resident players is not subject to CR corporate income tax. There is no gambling-specific GGR tax. CR-sourced income attracts standard corporate tax, and 13% IVA applies to CR-sourced services. This territorial exemption is the central tax advantage of the hub model.

Costs are registration-driven, not licence-driven. Company formation runs ~USD 1,000–2,000 plus notary; reported data-processing/licence fees include ~USD 5,000 permanent, ~USD 5,000 renewal, and ~USD 500 legal. Total first-year cost is typically USD 30,000–50,000 with agent and legal services. No bond or guarantee requirement applies, making CR among the lowest-cost entries globally.

Costa Rica has a well-developed banking sector with CRC and USD widely used and SINPE Móvil (national instant payment) ubiquitous. The structural weakness for gambling operators is that SUGEF does not classify them as AML-obligated entities, leaving CR-registered operators with minimal AML credibility before correspondent banks. International PSPs increasingly restrict CR-registered gambling entities, and US correspondent banks scrutinise CR gambling flows heavily under FinCEN advisories. Payment access is the critical and declining bottleneck.

The kladomati ban and venue-siting limits have generated an industry projection — rated Uncertain, from a single-source HUPIS estimate — that 50 to 70 percent of betting shops may need to relocate or close, threatening up to approximately 15,000 jobs. This points toward near-term consolidation among private land-based operators rather than competitive expansion. The land-based coupling for online licensing means that the competitive landscape for online gambling is effectively limited to operators with an existing Croatian land-based presence, further concentrating the market.