MACAU SAR, CHINA Law and Practice Contributed by: Pedro Cortés, Lektou
a necessary rationalisation to ensure that the market operates within a transparent, concessionaire-con- trolled framework. Notably, some operators have pub- licly indicated that they may acquire some of the hotel properties hosting satellite casinos currently operating under their brands, signalling a strategic move toward direct ownership and long-term integration of those venues within their concession portfolios. Discussions continue between the authorities, concessionaires, and investors on how best to redeploy affected work- ers and facilities, and further adjustments are antici- pated as the deadline approaches. The only licensed online activity continues to be the sports lottery, operated by Macau Slot Co. Ltd., which holds the exclusive concession for football and bas- ketball betting. In 2025, the Macau SAR government extended this concession by one year, to 5 June 2026, allowing additional time to assess the future regulatory model for sports betting as part of the government’s broader review of the lottery and non-gaming enter- tainment sectors. No new forms of online or interactive gaming have been legalised, and enforcement against unauthorised offshore platforms remains active under Law 20/2024 (Illegal Gambling). In parallel, Macau’s courts have begun to apply the interpretative provision set out in Article 63 of Law 16/2022 to disputes concerning long-standing patron deposits held before 2022. Notably, the Court of Final Appeal held for the first time that Article 63 of Law 16/2022 is an interpretative provision that clarifies Article 29 of Administrative Regulation No 6/2002: a concessionaire’s joint liability for activities of gaming promoters only arises when the acceptance, in the casino, of deposits of funds or chips by promoters (or their agents) relates to funds or chips that were actually used in casino gaming or were winnings from such gaming, assessed notably by reference to the concessionaire’s records of exchange or play; mere deposits – especially interest bearing “investment” deposits – without credible evidence of use in gam- ing, fall outside “activity developed in casinos” and do not trigger joint liability. The court acknowledged a divergence between Chinese and Portuguese ver- sions but adopted the legislative intent reflected in
Law 16/2022 and its legislative report, applying the interpretative rule retroactively to pending cases, and therefore rejected joint liability on appeal before it. At the same time, casino-related suspicious transac- tion reports (STRs) declined by approximately 9.5% year-on-year in the first nine months of 2025, reflect- ing both the maturation of AML controls and a struc- tural shift toward the mass-market segment rather than diminished vigilance. Diversification Beyond gaming, diversification efforts have taken tangible form. Macau Slot’s sports-lottery concession was extended by one year to 5 June 2026, ensur- ing continuity during the ongoing policy review, while major entertainment partnerships – including NBA pre- season games hosted in Macau from October 2025 – highlight the government’s determination to expand non-gaming tourism and international visibility. Together, these developments depict a market entering 2026 with renewed stability, greater regula- tory sophistication, and a more sustainable balance between gaming and non-gaming growth. Into 2026 Looking forward, 2026 marks the third year of the current gaming concessions. Pursuant to Article 22 of the Macau Gaming Law, the Macau SAR govern- ment must conduct a comprehensive review of the performance of each gaming concessionaire every three years. The first review cycle is expected to be initiated in late 2025/early 2026, marking the midpoint of the current ten-year concessions. This process will assess compliance with contractual obligations, non- gaming investment targets, corporate social respon- sibility (CSR) undertakings, and contribution to eco- nomic diversification, a long-standing goal of local and national governments. It is expected that the review will also inform the government’s policy adjustments on foreign-market development incentives, responsible-gaming initia- tives, and the treatment of satellite casinos after their 31 December 2025 transition deadline. The review will therefore constitute the first comprehensive policy checkpoint of the new concession era.
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