United Arab Emirates

Federal Decree-Law No. 25 of 2025 deleted Articles 1012-1019 of the UAE Civil Transactions Law, the chapter establishing gambling and betting contracts as void, effective 1 June 2026. This removes the civil-law basis for treating gaming contracts as automatically void and consolidates commercial gaming exclusively into the General Commercial Gaming Regulatory Authority's licensing regime. GCGRA, established by federal decree, holds exclusive federal jurisdiction to license commercial gaming across all seven Emirates. Criminal prohibitions under the Penal Code against unlicensed gambling remain fully in force alongside this civil clarification. The market itself remains nascent: only two B2C operator licences are live, one still pre-launch, and Dubai has no licensed operator. The jurisdiction sits within a civil-law family, where the licensing stack (enabling decree plus implementing regulator rules) forms the operative legal basis for lawful gaming activity.

## Licence Triggers No Person may operate or manage any activity in UAE related to Commercial Gaming, or establish or participate in the establishment of any Gaming Facility without first obtaining the required Licenses, approvals, and permits from the GCGRA and Local Entities. ## Type of licence needed See GCGRA guidance for more information: guide-to-licenses-in-the-uae_brochure_111223-w-cover.pdf GCGRA grants five categories of licenses: Entity Licenses: Gaming Operators: Entities operating online and land-based platforms, sports wagering, and the lottery (incl. retailers). Gaming-Related Vendors: Suppliers of gaming equipment or services (including technology, payments, and geolocation). Key Persons – Corporates: Corporate bodies with significant roles in licensee operations, such as a Controller (15% + ultimate controlling rights / equity in licensee), an Affiliate, Management Services Provider (i.e. service provider accounting, general admin, maintenance, recruitment, and other operational services) Individual Licenses: Key Persons – Individuals: Directors, executives, controllers in licensees. Gaming Employee: Employees directly involved in licensed gaming activity. Licenses span lottery, casino, sports betting (when regulated), as well as technology and services. Licensing is open to major international operators/providers, subject to due diligence and regulatory approval. ## Period of licence & renewal process The term of the license is dependent on the type of license. Licenses are renewable upon expiry unless there is substantial evidence of gross non-compliance by the Licensee. ## Application timeframe and phrases Phase 1: Initial Screening: Applicant provides high level information such as the company name, key people, organisation structure, licenses required, where they want to operate, etc. ; see: chrome-extension://efaidnbmnnnibpcajpcglclefindmkaj/https://www.gcgra.gov.ae/media/m4hl4tzv/gcgra-intake-form-0225.pdf GCGRA conducts initial screening and if successful provides Applicant with an Invitation to Licensing Portal ## Phase 2: In Principal Approval Application Fee paid by Applicant and then GCGRA provides Applicant access to the Licensing Portal and uploads detailed documentation as set out above GCGRA conducts initial investigation and confirms to Applicant they are eligible for In-Principal Approval In-Principle Approval Fee paid by Applicant In-Principle Approval granted by GCGRA ## Phase 3: Full Approval Once Phases 1 and 2 are complete Applicant cam incorporate corporate an entity, obtain relevant permits/visas/licenses, open bank accounts, etc. GCGRA conducts full review of the applicant if required, can establish a presence in the UAE GCGRA confirms Applicant suitability and Intent to Issue license License Fee paid by Applicant License granted to Applicant (with or without conditions) License term commences, when Licensee is ready for operations to commence, Licensee must demonstrate that all conditions have been satisfied List of documents & type of information needed to support application Applicants must provide full corporate and ownership due diligence, technical and operational documentation, and demonstrate fit-and-proper status. Some items are specific to the license but typically the Applicant will need to provide the GCGRA with the following: Business Information: Corporate documentation Organisation chart showing all related business entities Description of business activities Directors and Officers information Financial information, including financial accounts Qualifying Domestic Entity (QDE) details ## Details of Key Persons Third-party details, including legal advisors, auditors and accountants Information on the Applicant’s legal history (statutory, regulatory, financial, criminal, political) Overview of the responsible gaming plan to be put in place Security and data protocols are particularly emphasized, given the high priority on excluding unlicensed play and sensitive locations. The licencees are listed on the GCGRA website ## Geographical cover Licences are limited to operation and supply in the UAE. ## Bad Actor / Cooling off periods Unknown at this stage. ## Applicant considerations The Applicant must have an identifiable ownership and control structure There should be feasible financing plan which must include an evaluation of the financial conditions and the source of financing Applicant’s honesty and trustworthiness should be beyond reproach including that of key persons The Applicant / key persons should have gaming industry experience and necessary qualifications to operate the business The Applicant / key persons should have no criminal record or be involved in activity that poses a threat to the security, trade relations, or diplomatic reputation of the UAE. Any involvement in litigation or other legal disputes or involvement in proceedings in any jurisdiction in which regulation of gaming or gaming activities was an issue will be taken into consideration. This includes failure to satisfy any judgments, orders or decrees of any court in any jurisdiction Quality of the operation(s) that is the subject of the license will be considered, including technology solutions and infrastructure improvements, redevelopment of blighted areas, or clean-up of environmentally damaged areas. Number and quality of jobs being proposed and any guarantees for minimum levels of employment

## Partially Regulated The United Arab Emirates (UAE) has recently emerged as a region of significant opportunity for the gaming sector, with robust commercial interest both regionally and internationally. The sector is governed by a newly established regulatory authority - General Commercial Gaming Regulatory Authority (GCGRA), and a suite of first-in-region products, transitioning the country towards a regulated model for gaming and lottery. While the first major integrated casino resort will not open until 2027, B2B and B2C interest continues to accelerate, especially following the launch of the UAE Lottery in late 2024. However aside from the specific gambling sectors now being regulated by the GCGRA, the underlying law is a prohibitive one as set out under Articles 460-463 of Federal Decree Law No. 31/2021 on the Issuance of the Crimes and Penalties Law (Penal Code). This creates an offence for both gambling customers and those providing facilities for gambling. With regards to online gambling, Article 38 of Federal Decree Law No. 34/2021 Concerning the Fight Against Rumors and Cybercrime (Cybercrime Law) imposes penalties on: "Everyone who creates, manages or supervises a website or transmits, sends, publishes, re-publishes or propagates through the information network the practice of gambling activities, in other than the permitted cases. Where “permitted cases” presumably means those authorised by GCGRA. ## Market size The UAE is in early growth phase—the population is about 9 million. The market focus is currently on lottery (three products: Lucky Day, Pick 3, scratch cards) and hospitality gaming (resorts). Online and land-based casino/sportsbetting expected to expand following regulatory development and first resort opening. ## Localisation Gaming and lottery offerings are available online and in retail via The Game LLC, the current sole licensee for UAE lottery services, see: https://www.thegamellc.ae/#about UAE law requires advanced geolocation, including restrictions on play from prohibited locations (such as religious sites) and the ability for Emirates to “opt out” of lottery or future gaming activities. Payments: Licensed providers for payments and technical services must be approved. Digital/telephony restrictions mean VPN use is frequent, but prohibited for online lottery. Player communications must adhere to local language and cultural norms. ## Top Key Attractions and Challenges ## Attractions Large, affluent population and high levels of tourist arrivals. Excellent service and technology infrastructure. Attractive tax regime for gaming businesses. World-class regulatory framework and government backing. Growing number of international suppliers and opportunity for regional B2B operations. Attractive place for hiring employees due to low tax rates, and excellent travel connections. ## Challenges Complex and evolving regulatory requirements, particularly for compliance technology. Cultural and religious sensitivities around gaming require advanced controls and careful product positioning. VPN use is common in UAE, but strictly forbidden for lottery/gaming play—technically challenging to enforce. Only initial product categories (lottery, land-based casino) allowed; future growth of verticals depends on further regulation.

Marketing of licensed gaming activities is permitted under guidance from the federal and Emirate-level regulators. In essence marketing should not be in Arabic language or in any way targeted to consumers based in UAE. Advertising must be socially responsible, not target minors, and strictly comply with all Sharia and cultural norms. Lottery marketing is visible but controlled: focus is on responsible play, with full exclusion of vulnerable player groups. Retail and online channels are both used for lottery distribution and engagement. For more detail see GCGRA marketing requirements: gcgra-advertising-standards_26062024-aa-amendments-003.pdf UAE-based entities may face direct consequences (primarily fines, an order to remove the infringing advertisement, suspension/closure of the business) as a result of advertising gambling activities. Non-UAE entities publishing online gambling adverts will most likely face being blocked by the TDRA .

In alignment with the UAE Federal Law by Decree Regarding Regulating Commercial Gaming, the GCGRA has established a robust framework of technical standards produced by Gaming Laboratories International, LLC (GLI) in collaboration with legal experts for the testing and certification of gaming technology. These are specific to the type of game / operation and can be found here: https://www.gcgra.gov.ae/en/legislation-compliance/legislation/technical-standards/

General Commercial Gaming Regulatory Authority (GCGRA): Federal regulator for commercial gaming, including casinos and lottery. Ras Al Khaimah Tourism Development Authority (RAKTDA): Local licensing and tourism partner for gaming in Ras Al Khaimah. Gambling Directorate: Additional regional regulatory influence within Ras Al Khaimah. The GCGRA is the principal gambling regulator responsible to licensing and supervision of gambling licensees not only in relation to gambling operations but also money laundering supervision. The GCGRA also strongly relies on the role of ‘key persons’ in determining whether an operator’s culture, behaviour, and sound governance complies with GCGRA requirements. Lack of compliance with GCGRA guidance, licence conditions and UAE’s AML laws may lead to administrative actions or penalties that include: The denial, revocation, suspension, conditioning or restriction of a licence A monetary fine Any other administrative measures taken against or agreed to by a licensee or applicant Typical triggers for enforcement against unlicensed operators. Directly targeting of UAE will likely come to the attention of the authorities, particularly where there’s localised and offline advertising. Targeting can take the form of use of .ae domain name, having text in Arabic and listing any prices in AED. The GCGRA provides information on the dangers and consequences of illegal gambling, as shown here: https://www.gcgra.gov.ae/en/legislation-compliance/compliance/risks-of-engaging-in-illegal-gaming-activities/