Costa Rica

Costa Rica's market opportunity signal this cycle is anchored to a single cited estimate that approximately 53 percent of the domestic gambling market is illegal, a figure the Interpreter rates only Uncertain given its single-source, trade-press origin. That estimate has been explicitly adopted as the rationale for Bill 25.600, the successor JPS-modernization bill introduced after the January 2026 rejection of Bill 25.057.

Costa Rica has no dedicated online-gambling licence category and no JPS-issued betting authorisation; the standing structural position is that operators rely on municipal data-processing certificates issued under a 1922-era gambling law that predates any concept of digital wagering. This is a mixed-durability arrangement: the underlying statute is old but stable primary legislation, while the certificate-based practice built on top of it is an improvised operational workaround rather than a purpose-built licensing regime, and could be displaced entirely by future legislation. The most advanced attempt to close this gap, Bill 25.057, which would have created the first dedicated JPS online-gambling licensing framework, was rejected by the Legislative Assembly's Security and Narcotrafficking Commission in January 2026. No conditions for licence applications, renewals, suspensions, or revocations exist because no licence exists to apply for, renew, suspend, or revoke; the framework remains entirely aspirational pending a successor bill's passage.

The municipal Law 9050 data-processing permit remains the sole practical entry pathway for offshore-facing gambling operators in Costa Rica; no B2B gambling licence and no dedicated online-gambling authorisation exist in the jurisdiction. Domestic-facing entry into lottery or sports betting is foreclosed entirely by the Junta de Proteccion Social's statutory monopoly under the 1952 Ley de Loterias, and land-based casino entry is limited to hotel-confined premises under the 1991 Decree No. 20224-G.

No player-protection development occurred this cycle; Costa Rica's framework for self-exclusion, deposit limits, age verification, and marketing restrictions specific to gambling shows no change from the prior baseline. This reflects the jurisdiction's broader structural position: because no dedicated online-gambling statute exists, there is correspondingly no dedicated player-protection regime built around such a statute. Coverage gaps persist here — no structured evidence located this cycle addresses self-exclusion registers, deposit-limit mandates, or age-verification standards for either the JPS monopoly channel or the offshore-facing Law 9050 permit channel.

No distribution or platform-rule development was identified this cycle. Costa Rica has no dedicated app-store, ISP-blocking, search-de-listing, or affiliate-marketing-platform restriction regime specific to gambling, consistent with the jurisdiction's absence of a purpose-built online-gambling statute.

Enforcement in Costa Rica's gambling sector operates without a dedicated gambling regulator or enforcement authority; the state's practical tools are limited to municipal permitting under the 1922-era gambling law rather than any purpose-built gambling enforcement power. Against this backdrop, an estimated 53 percent of the domestic market is characterised as illegal, a figure rated only Uncertain given its single-source, trade-press origin, yet it has been adopted as the explicit rationale for the successor reform bill, Bill 25.600.

No change to Costa Rica's extraterritorial or offshore-facing carve-out occurred this cycle. The jurisdiction's structural basis — the composite 1922/1952/1991 statutory framework plus the Law 9050 data-processing permit — permits offshore-facing online gambling operators to operate on a non-resident-only basis without a dedicated gambling licence, provided their activity is not directed at Costa Rican residents.

Costa Rica's anti-money-laundering framework was materially expanded this cycle by Legislative Decree No. 10961, which amends Law 7786 through a new Article 15 quater and was published on 19 June 2026. The decree brings virtual-asset service providers within the AML/CFT perimeter for the first time, requiring mandatory registration with SUGEF, the country's financial-supervision authority.

No new gambling-specific operational obligation surfaced this cycle. The one adjacent development, Legislative Decree No. 10961, brings virtual-asset service providers into Costa Rica's AML/CFT perimeter through mandatory SUGEF registration, but this is explicitly framed as an AML obligation rather than a gambling-licence condition, and it applies to VASPs generally rather than to gambling operators as a defined class.

No change to fee schedules, tax rates, or compliance-lift factors occurred this cycle, and Costa Rica has no dedicated gambling tax regime outside the Junta de Proteccion Social's monopoly framework; there is accordingly no cost-to-operate baseline to revise for the offshore-facing online segment. The one adjacent development is the enactment of Legislative Decree No. 10961, published 19 June 2026, which amends Law 7786 to add Article 15 quater and brings virtual-asset service providers into the AML/CFT perimeter through mandatory registration with SUGEF.

This registration is explicitly not an operating licence, but it is a durable legal obligation that lands directly on the crypto-settlement rails many offshore-facing operators domiciled in Costa Rica use to move player funds, creating a new compliance dependency for any Costa-Rica-domiciled VASP counterparty in an operator's payment chain.

Costa Rica has no gambling-specific payment regulation, but Legislative Decree No. 10961's extension of the AML/CFT perimeter to virtual-asset service providers creates an indirect, and potentially significant, constraint on crypto-settled gambling payment flows. Any Costa Rica-domiciled virtual-asset counterparty must now register with SUGEF, and failure to do so risks exclusion from correspondent banking relationships, a de facto banking-access gate rather than a formal payments licence. This is durable primary legislation, not guidance, so the constraint is not readily reversible by administrative discretion.

For an offshore-facing operator relying on a Costa Rica-domiciled virtual-asset counterparty to settle player funds, the practical effect is a new precondition on continued access to banking rails, even though no gambling-specific payment instrument or capital control has been introduced this cycle.

Legislative sponsors of Expediente 25.600 introduced the first quantified estimate of Costa Rica's unlicensed gambling market this cycle, placing unlicensed platforms' share of the domestic lottery and sports-betting market at fifty-three percent, alongside an approximately three-hundred-million-dollar-per-year diverted-proceeds figure cited in supporting commentary.

Costa Rica's reform horizon is defined by a rejection-and-succession pattern. Bill 25.057, the most advanced attempt to create a JPS-issued online-gambling licensing framework, was rejected by the Legislative Assembly's Security and Narcotrafficking Commission in January 2026. Its successor, Bill 25.600, described as a Strengthening and Modernization of the Social Protection Board measure, was introduced proposing real-time monitoring and financial-intelligence-unit linkage for gambling oversight, but has not advanced to a floor vote this cycle.

As introduced, Bill 25.600 carries FRAGILE durability: it is a proposal, not an enacted instrument, and the Probable confidence rating attaching to its introduction does not extend to its eventual passage. Coverage of both bills rests exclusively on Tier 3 trade-press and aggregator reporting rather than a primary legislative record, a thin-record status that should temper confidence in the reform trajectory pending direct legislative confirmation.