All Bets Are On: 2025 UAE Commercial Gaming Review

Recently celebrating its second birthday, the United Arab Emirates' (UAE) commercial gaming (aka gambling) ecosystem, led by Federal regulator the General Commercial Gaming Regulatory Authority (GCGRA), continues to evolve at pace.  2025 proved to be a landmark year for regulatory and commercial developments, highlighted by the groundbreaking licensing of the UAE’s first online gaming platform last month. 

Below is our top five round-up for 2025:

1. First i-gaming operator licensed: for those watching the market, a clear indication that a UAE-based online gaming platform was on the horizon was the licensing of the Emirates’ first online casino vendor in November 2025 (see below).  Coin Technology Projects LLC, the UAE’s first (and currently only) licensed internet gaming operator launched two new gaming platforms in December 2025, play971 and Truewin (NB: the name “play971” is particularly notable, incorporating the UAE’s dial code of +971 and labelling it as an Emirates-based i-gaming site). 

   Neither platform disappoints, each offering a comprehensive selection of games (including blackjack, slots and roulette) and sports betting, with play971 also having a dedicated racing subsite with “watch live” functionality, odds and race information (Coin Technology Projects LLC holds both an internet gaming and sports wagering license).  Geo-blocking is up and running on the play971 site with (at the time of writing) registration only possible from certain locations in the UAE, indicating a controlled and gradual launch.  The terms and conditions allow both UAE residents and visitors to register, with (potentially) some additional registration requirements for UAE nationals.    

2. First vendors offering live casino and horse racing content: this presents a classic chicken-and-egg conundrum; does the vendor or the operator come first?  Live Online Gaming Services LLC (part of the Yolo Group and operating the brand Live88) became the first GCGRA licensed online live casino content provider in October 2025, clearly signalling that an online gaming operator license was imminent.  The vendor's location in the Emirate of Abu Dhabi further indicated that the first online gaming operator would also be Abu Dhabi based, a prediction that proved correct (see above).  Arena Leisure Ltd, the first UAE gaming-related vendor to offer live horse racing content and data, was licensed by GCGRA shortly after the first internet gaming/sports wagering licensee (as above). The pattern is clear; with each new operator license issued, a number of related vendor licenses are granted.

   The UAE’s vendor licensing framework also presents a strategic opportunity for suppliers that are providing business-to-business (B2B) commercial gaming products and services internationally (not necessarily to a UAE-licensed operator) to establish a local UAE presence/apply for a vendor license.  Notably, in support of this newly established sector, the Emirate of Ras Al Khaimah has recently relaunched the rebranded “Innovation City”, a free zone focusing on core pillars including “Gaming and iGaming”.

3. New rules on protection of children online: reflecting international best practice, the UAE issued Federal Decree Law No. 26 of 2025 on Child Digital Safety in December 2025, regulating the online environment for minors.  It includes a specific prohibition on digital platforms allowing children to “participate in, create accounts for, or access online commercial games”.  Online commercial games are defined as any online games with a primary purpose of generating direct or indirect financial gain for its operator, including gambling games and digital activities involving wagering or betting for monetary or valuable consideration.  This is a broad definition and “valuable consideration” could include any coins or tokens with real-world value. 

   The law requires that any platforms offering commercial games take the “necessary technical and administrative measures to prevent children from accessing [commercial] games” which includes age verification mechanisms, parental control tools and blocking harmful content.  This likely means that it will not be sufficient for an online gaming platform to simply include a tick box requiring users to confirm they are an adult; they may be required to implement evidence-based checks that confirm age such as provision of ID or age verification through a telecommunications operator.

4. One operator per Emirate model: various gambling publications have reported that each of the seven Emirates will be able to support one land-based and one online operator.  To date, there has been no official GCGRA communication on this point, but it is apparent that operators are being licensed in a controlled and gradual manner, with only one land-based operator (Wynn Al Marjan, located in the Emirate of Ras Al Khaimah) and one online operator (Coin Technology Projects LLC, as above) licensed.  If this is accurate, it means there will be a limited number of both types of operator licenses available (a maximum of seven of each, one for each Emirate) and likely that more conservative Emirates abstain entirely from the new licensing regime.  Interestingly, to date, the Emirate of Dubai has neither a licensed land-based nor online operator.

5. First published definition of Commercial Gaming (and enhanced Anti-Money Laundering (AML) requirements): the UAE reissued and updated its AML framework in September/October 2025, now including the concept of “commercial gaming” and “gaming operators”. Interestingly, this is the first time we have seen a published definition of “commercial gaming” (in a law), defined as “any game of chance, or any form of opportunity-based or practice-based activity that relies on chance and skill, in which a specific monetary amount is placed as a stake with the objective of winning a monetary amount or any other item of value.”  Two observations on the definition: (i) it clearly establishes that games involving skill are considered commercial games if there is any chance element (regardless of the balance between skill and chance), and (ii) a monetary stake, i.e. “pay to play", is required.  Lotteries, online gaming platforms, sports betting platforms and any games of chance or opportunity are considered to be commercial gaming, regulated and licensed by the GCGRA.  In practice, it seems that any game that involves chance and paid entry would be considered a commercial game and regulated by GCGRA.

   The new AML framework states that gaming operators (i.e. anyone operating a land-based casino, online gaming platform, sports betting or a lottery) are Designated Non-Financial Businesses and Professions (DNFBP) if a single transaction is (or linked transactions are) valued at equal to or over AED 11,000 (approximately USD 3,000).  Transactions involving only gaming tokens or chips would not qualify as they do not involve actual money (although converting chips to cash equal to or above the AED 11,000 threshold would qualify).  DNFBPs have more onerous compliance requirements under the AML framework including additional customer due diligence, reporting and record-keeping.     

In conclusion, the UAE's commercial gaming sector has made remarkable strides in 2025, transitioning from regulatory framework to operational reality. As the sector continues to mature, stakeholders should anticipate further regulatory developments and licensing activity in 2026. 

For further information or advice on the UAE's commercial gaming regulatory framework, licensing requirements or compliance obligations, please do not hesitate to contact us.