Commercial Gaming & Gambling in the UAE Regulatory Framework

Over the past year, the United Arab Emirates has taken unprecedented steps to regulate commercial gaming (casinos, lotteries, sports betting, etc.), aiming to unlock tourism and economic growth. In 2023, the federal government created the General Commercial Gaming Regulatory Authority (GCGRA) to oversee all licensed gambling under strict, globally-aligned standards. Any company or individual looking to offer casino-style gaming, online betting, lottery or related activities must now obtain a GCGRA license. At HLS-Global UAE, we have been closely monitoring these developments and stand ready to guide clients through the licensing and compliance requirements in this evolving sector.

1. Regulatory Framework & Market Outlook

For decades, most forms of gambling were prohibited in the UAE aside from limited charitable raffles and small promotional lottery draws. In late 2023, the UAE announced a shift: it established the GCGRA and introduced a comprehensive licensing regime. Under the new rules, all commercial gaming requires licensing by the federal authority. Operating without a license is illegal and carries severe penalties (heavy fines, imprisonment, and business closure). The GCGRA’s mandate now covers lotteries, internet gaming, sports wagering and land-based facilities (casinos, slot halls, etc.).

The UAE’s new gaming regime is already in motion. In July 2024, the GCGRA awarded the first national lottery license to The Game LLC (an Abu Dhabi-based company). Existing raffle operators (Emirates Draw and Mahzooz) paused their draws at the GCGRA’s request during the licensing process. In October 2024, Wynn Resorts announced it had received the UAE’s first casino license for its planned $3.9 billion resort on Ras Al Khaimah’s Al Marjan Island. These landmark developments have set the stage for further expansion of licensed gaming in the UAE.

The Wynn Al Marjan resort (RAK) is slated to open mid-decade as the UAE’s first luxury casino destination. Abu Dhabi and Dubai have not publicly announced specific casino projects yet, but both emirates are actively designing entertainment zones and regulations. Online gaming and sports betting platforms (including international operators) are also expected to seek UAE licenses as the framework matures. Overall, the outlook for commercial gaming in the UAE is cautiously optimistic. The regulatory framework provides clarity for investors while balancing cultural and social concerns. As additional licenses are issued and projects are built, the UAE could emerge as a major regional gaming hub.

2. Who Needs a License (Eligible Parties)

The UAE’s GCGRA regulates all commercial gaming activities (lotteries, casinos, online betting, sports wagering, etc.) at the federal level. Any company or individual engaging in such activities must obtain the appropriate GCGRA license before operating. The licenses are broadly divided into entity licenses and individual licenses, each with detailed documentary and suitability requirements as below:

• Gaming Operators: Any company that runs gambling activities must be licensed. This includes casino operators, lottery organizers and retailers, online gaming platforms, sports and event betting operators, etc.
  
  
• Gaming Vendors: Suppliers of gaming equipment or services (e.g. makers of slot machines, IT platforms) must obtain a vendor license.
  
  
• Key Corporate Persons: Entities or individuals controlling a gaming business (typically ≥15% ownership or voting control) must be licensed as Key Persons (Corporate).
  
  
• Key Individuals & Employees: Senior personnel – such as CEOs, CFOs, board members or other “key persons” – and any gaming employees (dealers, attendants) require individual licenses or occupational permits.
  
  

Each license type has specific criteria, but broadly any person or company whose activities fall under the definition of commercial gaming must obtain the appropriate GCGRA license before operating. Under GCGRA regulations, “commercial gaming” refers to any activity in which money (or its equivalent) is wagered on games of chance or skill—covering lotteries, casinos, online betting, sports/event wagering, and related gaming platforms.

3. Licensing Process (Key Steps)

The GCGRA’s licensing process is structured and thorough. The key steps are as below:

1. Intake & Screening: Submit an Intake Form to notify the GCGRA of your intent and provide basic company and project details. The GCGRA performs an initial eligibility review.
   
   
2. Portal Access & Application Fee: If pre-screening is passed, the applicant pays a non-refundable application fee to gain access to the GCGRA’s online licensing portal. All detailed application materials are then submitted through this portal.
   
   
3. Document Submission: Provide comprehensive documentation via the portal – including corporate records, financial statements, organization charts, business plan, information on key persons and third parties, and a responsible gaming plan.
   
   
4. In-Principle Approval: The GCGRA reviews the submission and, if all requirements are met, grants an in-principle approval. At this stage, the applicant pays an ‘In-Principle Fee’ equal to 10% of the total license fees. This approval allows the applicant to incorporate entities, obtain permits, and open bank accounts in preparation for operations.
   
   
5. Final Review & License Issuance: After fulfilling any remaining conditions (such as finalizing corporate structure or technology readiness), the applicant pays the remainder of the license fee (the other 90%). Upon receipt of all fees and documentation, the GCGRA issues the final commercial gaming license and a ‘Certificate of Operation’.
   
   

Throughout this process, the GCGRA conducts thorough suitability checks (integrity, financial soundness, criminal background, etc.) on all owners, investors, and key personnel. While the GCGRA aims for an expeditious review, it has not published a fixed timeline. In practice, applicants should allow several months from initial intake to final approval, depending on application completeness and regulatory workload.

4. Fees & Timeline

• Application Fee: Paid upfront to access the licensing portal. It covers preliminary review and is non-refundable. (The exact AED amount has not been publicly disclosed.)
• In-Principle Approval Fee: Equal to 10% of the full license fee, due when in-principle approval is granted.
• License Fee: The remaining 90% of the license fee is payable before final license issuance. This fee is calculated based on the license category and scope of operations (examples might run into the high six or seven figures for major resorts, though official rates are pending release).
• Renewal/Maintenance Fee: A yearly fee (often a “maintenance” or “renewal” fee) is due each year to keep the license active. This is generally comparable to the initial license fee and is non-refundable.
• Timeline: The GCGRA has not set formal deadlines, but publicly states it will process applications smoothly and promptly. Applicants should anticipate multiple months for the full cycle (initial intake, reviews, approvals, and company set-up). Prompt submission of complete documentation and fees can help avoid delays.

5. Ongoing Compliance Requirements

Licensed gaming entities face continuous obligations to maintain their license as enumerated below:

• AML/CFT Compliance: Operators must strictly comply with UAE Anti-Money Laundering and Counter-Terrorism Financing laws. Robust customer due diligence, reporting of suspicious transactions, and related controls are mandatory.
• Responsible Gaming: Licensees must implement a comprehensive Responsible Gaming Program (“RG Program”). This includes player education on risks, age-verification, advertising only to adult audiences with no misleading promotions, and providing customer support or self-exclusion tools. Biennial audits of the RG program by a GCGRA-approved auditor are required.
• Reporting and Updates: Companies must keep the GCGRA informed of any material changes (e.g., changes in ownership/control, financial status, jurisdiction, or any legal investigations). Failure to disclose such changes or to report major compliance issues can lead to penalties or license suspension.
• Audit and Inspection: The GCGRA will conduct ongoing compliance audits and inspections as part of its oversight. Operators must make records and systems available for review upon request.
• Annual Renewal: Licenses must be renewed each year. Renewal applications (and payment of the annual fee) are due before the expiry of the current licenses. The GCGRA will verify continued compliance as a condition of renewal.

How HLS-Global UAE Can Help

Navigating the new UAE gaming licensing regime requires careful planning and expert advice. Our firm has experience in UAE regulatory processes and global gaming standards. We assist clients by: identifying the correct license categories; preparing and reviewing all application materials (intake forms, business plans, financial models, RG policies, etc.); managing the GCGRA portal submissions; and coordinating required audits and government interactions. We also ensure ongoing compliance post-licensing (AML programs, RG implementation, reporting). In this still-nascent sector, professional guidance is strongly advised. By leveraging our multidisciplinary expertise, we help you streamline the licensing process and confidently operate within the UAE’s gaming framework.

💼 Partnering with HLS-Global UAE means tapping into a boutique team that knows both the local landscape and international gaming norms. We handle the heavy lifting so you can focus on building your gaming business with confidence.

Disclaimer: All views expressed in this article are solely for informational purposes and should not be construed as legal advice. This information is for reference only and is bound to change in case of any amendments or changes to applicable laws. We do not assume any responsibility or liability for any errors or omissions in the content of this article, and do not make any warranties about the completeness, reliability, and accuracy of the information expressed in this article.