SWITZERLAND Trends and Developments Contributed by: Simon Planzer and Florian Furger, PLANZER LAW
In most zones (19) – Baden-Aarau, Bern, Bernese Oberland East, Geneva, Fribourg, Jura, Lucerne, Lugano, Locarno, Mendrisio, Montreux, Neuchâtel, Nordbünden, Südbünden, Sarganserland, Schaff- hausen, Schwyz, Winterthur and Zurich – only one applicant applied for a licence. However, in four zones, there was competition for the licences. In the zones of Basel and Saint Gallen, two applicants competed. In the Valais zone, there were three competitors, the incumbent casino in Crans-Montana and two new casino projects in Martigny and Sion. Similarly, there were initially three applicants for the Lausanne zone, with one project in the city of Laus- anne and two in the immediate surroundings of Laus- anne. However, the applicant with a project in the city of Lausanne had to withdraw due to the lack of political support from the city of Lausanne, which is a legal requirement. Even though legislation on casinos is federal in nature, both the canton and the city are able to prevent casinos setting up on their territories simply by denying political support. All casino applications had to be submitted for a spe- cific casino project in one of the 23 casino zones that had been pre-defined by the federal government. The new 23 zones include those 21 areas where casinos had already been located, supplemented by two new casino zones. The requested licensing materials were substantial, containing thousands of pages with far-reaching solid-reputation requirements and detailed business, operational and economic analyses. Moreover, follow- ing the submission of the applications, the regulator continued the process further, seeking further clarifi- cation and information from applicants. New opportunities for international investors from 2026 International investors have different investment and business opportunities in the Swiss casino market. They can consider a change of ownership by purchas- ing a majority or minority share in casinos; cooper- ate with licensees by providing their online platform solutions and additional services; or serve as game provides to casinos. In the case of (co-)ownership and online platform provisioning, robust good-repu-
tation/background checks apply to the company and its beneficial owners. For many international B2Cs, these investment options were formerly not available, as Swiss gaming law imposed the five-year cool- down period to those with Switzerland-facing online gaming offerings. As mentioned above, most inter- national first-tier gaming brands withdrew from the Swiss market in January 2019 when the revised Gam- ing Act entered into effect, supported by enforcement measures in July the same year. From 2025, or later, depending on the exact date of withdrawal from the market, these B2Cs will normally no longer be barred from purchasing a casino share or cooperating with casinos as serious business partners. (B2Cs that have been active on the Swiss online gaming market for less than five years would not meet the solid-reputa- tion criterion and would need to go through the cool- down phase before instituting Swiss facing business after shutting down their online game portfolio.) The Swiss online casino gaming segment The first four online offerings by Swiss casinos (Jack- pots, MyCasino, Swiss Casinos, Casino777) went live in the second half of 2019. The number of domestic online casino offerings increased by the end of 2021 to 11. No additional online offerings went live in 2022, mainly for two reasons. First, the business focus was placed on successfully securing the casino licence, and the effort put into the licence application, covering thousands of pages, was huge. Second, the regulator signalled that it would not license an online offering for the remaining short licensing period (to the end of 2024). This is because the online licence is an exten- sion of the terrestrial casino licence. If the applicant had not been granted a renewed licence for its ter- restrial casino operations, it would have needed to cease its online business after only a couple of years. One of the 11 online casinos (Casino Neuchâtel) in fact ceased activities at the end of 2022, as the owners expressed their desire to focus on their online busi- ness of its sister casino in Bern. In the course of the licence application process, ten incumbent online casinos reapplied, and two new applications for online offerings were submitted simultaneously, raising the number of domestic online casino offerings to 12 as of 2025. It is worth noting that there is no fixed licensing window for the online
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