By January 1, 2026, concessionaires must either acquire the premises or transfer their satellite casinos to a casino management company.
The gambling landscape in Macau is set to undergo potential regulatory changes as the region's new administration assesses existing laws governing the gaming industry. Lawyers from JNV – Lawyers and Notaries have outlined areas for potential reforms, emphasizing compliance with updated regulations and the supply of gaming machines.
A recent analysis by JNV lawyers Jorge Neto Valente, André Santos Raquel, and Jessica Hon for Legal 500 suggests that the Macau gambling market is bracing for further amendments under the administration of the new Macau Chief Executive Sam Hou Fai.
Valente, founder of JNV and a seasoned figure in Macau's legal and gaming sectors, highlighted the likelihood of new laws shaping the industry’s future.
New Offenses Under Law No. 20/2024
The most recent substantial legal change, enacted under Law No. 20/2024, became effective on October 29, 2024. This law introduces harsher penalties targeting gambling-related crimes, including “illegal lending for gambling” and the operation of unauthorized currency exchange services. These measures aim to crack down on illegal activities that have plagued Macau’s gaming sector for years.
According to the JNV legal review which was cited by AGBrief, these penalties are only the beginning. Additional regulations may emerge, as authorities aim to tighten oversight in the gaming industry further.
Focus on Gaming Machines and Lotteries
One significant area flagged for potential reform is Administrative Regulation No. 26/2012, which governs the supply of gaming machines, equipment, and systems in Macau. JNV’s analysis predicts that this regulation could see an overhaul as part of broader efforts to modernize the industry.
Further developments in lotteries and sports betting may also be on the horizon. The Gaming Inspection and Coordination Bureau (DICJ) is preparing to implement its updated Electronic Gaming Machines Standards 2.0, set to take effect on December 31, 2026. This new standard will impose stricter compliance requirements on gaming operators, urging them to adapt to these changes to maintain operational continuity.
“Industry players are advised to prepare for compliance, as this will impact their operations significantly,” the legal experts cautioned.
Scheduled Compliance Reviews
In addition to changes in gaming machine regulations, the DICJ is scheduled to conduct a comprehensive compliance review of the casino gaming concession contracts. These reviews occur every three years and aim to ensure concessionaires adhere to regulatory obligations.
The upcoming review, set to begin on January 1, 2025, has raised concerns about its potential impact on Macau’s gambling market. With the region closely tied to China’s economy, broader geopolitical and economic factors may also influence the industry’s stability.
Despite these uncertainties, the contracts signed in 2022 between the government and concessionaires outline significant plans for both gaming and non-gaming investments. These developments provide opportunities for companies supplying goods and services to casino operators, creating potential growth avenues for businesses entering the market.
Challenges for Start-Ups
Macau’s status as the largest land-based gambling market in the world remains a key attraction for businesses. However, JNV’s analysis highlights the challenges facing start-ups seeking to establish operations in the region.
The high barriers to entry, including the need for concession contracts, make Macau a complex jurisdiction for new businesses. Still, the region’s dominance in global gambling ensures it remains a lucrative market for those who successfully navigate its regulations.
Satellite Casinos and the Transition Period
Law No. 7/2022, enacted prior to the public tender for new casino concessions, introduced significant changes for satellite casinos. It allows new concessionaires to operate existing casinos on third-party premises for a transitional period of three years, provided they obtain approval from Macau’s Chief Executive.
This transitional period, which began in 2023, will conclude on January 1, 2026. By then, concessionaires must either acquire the premises of these satellite casinos or transfer their management to a casino management company. This requirement adds another layer of complexity for operators, compelling them to reevaluate their long-term strategies.
As Macau’s gambling industry faces a wave of potential regulatory changes, legal experts emphasize the importance of balancing growth with oversight. Stricter compliance measures aim to address longstanding issues, from illegal activities to operational inefficiencies. At the same time, the region’s focus on non-gaming investments reflects efforts to diversify its economy and reduce reliance on gambling revenue.
For businesses and investors, Macau’s evolving regulatory environment presents both challenges and opportunities. While tighter rules may initially disrupt operations, they also promise a more stable and transparent gaming market in the long run.
Read related article: Macau Satellite Casinos Face Uncertainty Amid Pending Talks
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