Gaming Law 2025

MACAU SAR, CHINA Trends and Developments Contributed by: Pedro Cortés, Lektou

The Macau Gaming Industry in 2025: From Recovery to Recalibration The Macau gaming industry ends 2025 with solid operating momentum, firmer supervision, and clearer policy signals. The market posted a new post-pan- demic high in August 2025 with gross gaming revenue (GGR) of MOP22.16 billion (approximately USD2.77 billion). For the nine months until September 2025, cumulative GGR reached MOP181.3 billion (approxi- mately USD22.6 billion), up roughly 7.1% year-on- year (YoY). The government’s initial 2025 GGR target of MOP240 billion (approximately USD30 billion) has since been revised to MOP226 billion, implying a Q4 run-rate of MOP15–20 billion per month. On the fiscal side, gaming tax receipts for January– September 2025 totalled MOP70.4 billion (approxi- mately USD8.78 billion), representing an increase of 6% YoY, tracking the GGR path and confirming con- tinued budgetary reliance on casino levies. The 2025 Policy Address reinforced the dual mandate: rigorous oversight with measurable diversification. Execution is visible in on-property supervision, tech- nology uptake, and non-gaming programming, while operators calibrate mix and capex (capital expendi- ture investment) to premium-mass fundamentals. Legislative implementation and enforcement Law 7/2024 (Credit) is fully in force: only concession- aires may extend gaming credit, centralising risk and traceability. Law 20/2024 (Illegal Gambling) underpins stepped-up actions against unlicensed/online activity and associated financial misconduct with publicised enforcement expected to continue. Supervisory capacity and data-driven monitoring The DICJ (Gaming Inspection and Coordination Bureau) entered 2025 with new leadership and an expanded inspectorate, shifting towards analytics- supported oversight. RFID/chip-tracking helps attrib- ute foreign play for incentive purposes, replacing the earlier reliance on segregated “foreigner” zones. Satellite casinos: final transition and structural rebalancing The three-year transition for satellite casinos ends on 31 December 2025. The 2022 reforms require casino

areas to be owned by Macau SAR and placed at con- cessionaires’ disposal (with rent) or otherwise to be under concessionaire ownership/control, eliminating the legacy model of third-party property owners oper- ating gaming under service/revenue-share. During 2025, a number of satellites, especially in stand-alone hotels, ceased gaming or repurposed ahead of the deadline. Policymakers view this as necessary rationalisation to improve transparency, unify compliance, and concen- trate accountability in concessionaires. Notably, SJM Resorts has publicly indicated it may acquire proper- ties hosting satellite casinos under its brand – sug- gesting consolidation rather than extinction of some sites post-deadline. The transition may signify knock- on effects for employment, supplier contracts, certain areas of the city, and lease economics, with the gov- ernment encouraging redeployment and retraining to mitigate disruption. On 1 January 2026, Macau’s gaming map should consist entirely of gaming venues fully controlled by concessionaires. Judicial clarification of deposit liability Courts have begun applying Article 63 of Law 16/2022 (interpretative) to legacy “patron deposit” disputes against promoters: concessionaire joint liability for promoter-accepted deposits turns on whether funds were actually used in gaming or were gaming win- nings per concessionaire records; mere “investment” deposits fall outside “activity developed in casinos”. This alignment with the 2022 legislative intent narrows exposure in pending cases. Advertising law reform: gaming-specific impact On 4 July 2025, the government opened consulta- tion to overhaul Law 7/89/M (Advertising Law). The proposal would explicitly prohibit direct/indirect advertising of games of fortune or chance across all media including digital and cross-border, enumerate prohibited depictions/inducements, raise fines, and empower online takedowns and business-suspension for repeat offenders. If enacted, this will be the first comprehensive update in three decades and would materially tighten marketing compliance for con-

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