New regulations and regulator signal new era for legal gaming in UAE

In a landmark move back in September 2023, the General Commercial Gaming Regulatory Authority (GCGRA) was established to regulate “commercial gaming” in the UAE.

‘Commercial gaming’ in this context refers to the regulation of the UAE lottery; internet gaming including both computer and mobile; sports wagering, such as betting on the outcome of a football match; and casinos, such as the licence granted to a resort development in Ras Al Khaimah (RAK) late last year.

The GCGRA's establishment appears to be one of the UAE’s strategies to broaden its economy and diversify its revenue streams and has created an opportunity for global players in this space to enter the UAE market.

This newly regulated gaming market will likely spur innovation, particularly in areas like online gaming. At present, under the new framework, the scope of “commercial gaming” has been left relatively wide, perhaps to allow the inclusion of other activities such as eSports at a later stage.

The launch of the GCGRA came alongside the announcement of its first licensee in 2024 being awarded to ‘The Game LLC’, which operates the UAE lottery. Officially operational in November 2024, the UAE lottery allows UAE residents to participate in several different games, including the opportunity to win an AED 100 million (approx. US$27m) jackpot as part of the 'Lucky Day' game.

Interestingly, and in line with other jurisdictions around the world, the GCGRA has indicated its intention to maintain only one official lottery in the UAE. The regulator has indicated that although existing lottery-style games like Big Ticket and Dubai Duty Free will be allowed to continue under GCGRA supervision, no new lotteries will be permitted.

This raises questions in relation to the gaming companies which previously operated in the UAE prior to the GCGRA’s establishment, including popular raffle operators Mahzooz and Emirates Draw.

It appears that most of these companies suspended operations at the beginning of 2024 after the introduction of the GCGRA and competed to obtain the UAE lottery licence. It is unclear whether the GCGRA will authorize these entities to resume operations under another branch of commercial gaming permitted as part of the new framework.

These developments provide fascinating insights about the UAE's burgeoning gaming sector, with the GCGRA at the heart.

Who is the UAE gaming regulator, GCGRA? 

The GCGRA is the federal executive agency responsible for regulating and overseeing all commercial gaming activities in the UAE. Its mission is to ensure that the UAE gaming industry operates within a framework that prioritises player safety and socially responsible gaming practices.

The establishment of the GCGRA came 18 months after it was first announced that Las Vegas luxury resort, the Wynn, would debut a resort in RAK which would feature a ‘licensed gaming’ component considerably larger than its Las Vegas counterpart.

The resort is scheduled to open in early 2027 on Al Marjan Island and will feature a 225,000 square feet gaming area. In October 2024, the resort became the first physical casino operator licensed by the GCGRA, making it the second entity to obtain a license in the UAE, after the UAE Lottery.

The Wynn has attracted other real estate and hospitality giants to RAK looking to cater to the anticipated influx of tourists and high-net-worth individuals. Properties near the Wynn have become highly sought after, commanding a premium and driving up property values in the emirate, particularly on and around Al Marjan Island.

Specifically, there has been an increased demand for luxury, branded residences in the vicinity of the Wynn. These market observations replicate similar trends identified in other jurisdictions around the world such as Macau, where the direct impact of integrated gaming resorts increased property values.

In addition to tourists and investors, RAK is likely to see a boost in long-term residents looking to live and work in the emirate, especially employees in the hospitality, entertainment, and food and beverage sectors. This in turn will likely drive the need for additional service infrastructure, food and beverage establishments, and retail outlets and malls to cater to the day-to-day needs of an increased population.

What’s next for UAE commercial gaming 

Whilst the GCGRA is still in the nascent stages of building out its regulatory framework, the regulator is clear that it is dedicated to promoting responsible gaming in the UAE. The licensing process will involve a thorough evaluation of the applicant to ensure that it meets the highest ethical and professional standards, and the evaluation process includes an assessment of the entity and its proposed activities, its directors, senior management, as well as the responsible gaming plan to be put in place.

At present, the GCGRA’s regime only applies to operators, vendors and employees of commercial gaming entities and the GCGRA has indicated that this does not extend to service providers.

Given that gaming operators are increasingly integrating technology and fintech solutions to enhance their operations, particularly in relation to internet gaming and eSports, we expect that the GCGRA will need to work closely with financial regulators and other authorities to ensure that service providers maintain high cybersecurity and fraud standards to ensure a secure and effective gaming environment thrives across the country.

Interestingly, the GCGRA also mandates that commercial gaming operators offer tools for safer gaming experiences in compliance with the GCGRA’s ‘Responsible Gaming Framework’, which include things such as deposit limits, cooling-off periods, self-monitoring capabilities, and options for self-exclusion.

This approach prioritises player protection, ethical practices, and harm prevention in the gaming space and aligns with international best practices, such as in the United Kingdom, Singapore, Canada and Australia.

Co-written by Philip Corfield-Smith and Nayab Aziz of Pinsent Masons.