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how to obtain a gaming licence in Macau

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How to Obtain a Gaming Licence in Macau (concessions, Operating Licences & Permits), Step-by-step (2026)

By Global Law Experts
– posted 6 hours ago

Understanding how to obtain a gaming licence in Macau is essential for any casino operator, equipment supplier or investor planning to enter the world’s largest gaming market. The Macau Special Administrative Region (SAR) operates under an administrative concession model governed by Law No. 16/2001 (the Gaming Law), as substantially amended by Law 7/2022, with additional enforcement provisions introduced by Law No. 20/2024 (the Law on Illegal Gambling Activities). This guide consolidates the eligibility requirements, procedural steps, documents, timelines and costs that apply to concession bids, operating licences, machine approvals and related permits as of mid-2026. Practitioners advising on commercial transactions in Macau’s gaming sector will find an actionable, deadline-driven playbook below.

Overview of the Macau Gaming Licence Process and Who It Applies To

Macau’s gaming industry operates under an administrative concession model in which the government grants concessions to legally incorporated entities through administrative concession contracts. This approach applies to the operation of casino games, lotteries and Chinese and sports lotteries. The distinction between the different types of authorisations is critical for any applicant assessing how to obtain a gaming licence in Macau.

Types of gaming authorisation

  • Gaming concession. An administrative contract between the Macau SAR government and a concessionaire, authorising the operation of games of fortune or chance in casinos. Concessions are awarded via an international public tender process organised by the government. Under the amended Gaming Law, a maximum of six concessions may be in force at any time, each granted for a maximum term of 10 years (with a possible exceptional extension of up to 3 years).
  • Operating permits and sub-authorisations. The pre-2022 sub-concession model has been abolished. All operators now hold concessions directly with the government.
  • Gaming machine and equipment approvals. Suppliers of electronic gaming machines (EGMs), equipment or gaming systems must obtain approval from the Gaming Inspection and Coordination Bureau (DICJ) in accordance with the Macau EGM Technical Standards before their products may be deployed on casino floors.
  • Junket promoter licence. Entities that promote gaming and bring VIP players to casinos must obtain a separate junket promoter licence from the DICJ, subject to enhanced fit-and-proper and financial-guarantee requirements introduced by Law 7/2022.

The primary regulatory bodies are the DICJ (which supervises day-to-day gaming operations, processes licence and machine applications, and conducts inspections), the Secretary for Economy and Finance (who approves game rules and issues certain orders) and the Government Tender Committee (which manages the public tender process for concessions).

Eligibility and Prerequisites, Gaming Licence Requirements Macau

Before any formal application is submitted, applicants must confirm they satisfy the baseline gaming licence requirements Macau imposes under the amended Gaming Law. Failure to meet even one structural prerequisite will result in automatic disqualification.

Corporate structure and local incorporation

Applicants for a gaming concession must be incorporated in Macau as a limited liability company by shares (sociedade anónima). This entity must have its registered office in Macau and must be established for the specific purpose of operating games of fortune or chance. The managing directors must be Macau residents, and all share capital must be registered in the applicant’s name. The incorporation must be completed via the Macau Commercial Registry before any application is lodged.

For suppliers seeking gaming machine approvals and junket promoters applying for a junket promoter licence, separate entity requirements apply, but a local legal presence (whether a branch or a locally incorporated subsidiary) is required for regulatory communication and service of notices.

Capital and financial prerequisites

The eligibility capital requirement for concession applicants is substantial. Under the ICLG Gambling Laws and Regulations Report, concession applicants must demonstrate a minimum share capital of MOP 5 billion (approximately USD 625 million). Applicants must also provide:

  • Audited financial statements for the preceding three financial years, prepared by an internationally recognised audit firm
  • Proof of capital and bank letters confirming available funds, issued within the preceding 90 days
  • Source-of-funds documentation tracing the origin of capital contributions, compliant with Macau’s AML/CFT framework

Junket promoters and equipment suppliers face lower capitalisation thresholds, but must still demonstrate financial capacity and post guarantees as required by DICJ guidance.

Fit and proper / background checks

All key persons, directors, significant shareholders (typically holding 5% or more) and ultimate beneficial owners (UBOs), must pass fit-and-proper assessments conducted by the DICJ with assistance from third-party vetting agencies. Required disclosures include:

  • Criminal record certificates from each country of residence (typically valid for 3–6 months from issue)
  • Declarations of business interests, liabilities and any prior regulatory sanctions
  • AML/CFT compliance history and details of the nominated AML compliance officer

The 2022 amendments tightened these standards. Industry observers expect the DICJ to apply a broader definition of “associated persons” in practice, capturing individuals with indirect influence over corporate decision-making.

Step-by-Step Procedure: How to Obtain a Gaming Licence in Macau

The gaming concession process Macau follows is structured around a government-initiated public tender, while supplier and junket licences are processed through DICJ administrative applications. The four core procedural steps below apply to concession bids; parallel steps for supplier and junket permits are noted where relevant.

Step 1, Pre-entry and strategic planning

Who: Applicant, local counsel, financial advisers.
Typical duration: 2–8 weeks.

Before a formal tender opens, prospective concessionaires should complete the following preparatory actions:

  1. Incorporate the Macau vehicle. Establish a sociedade anónima at the Macau Commercial Registry with the requisite share capital structure. Ensure articles of association reflect a sole corporate purpose of operating games of fortune or chance.
  2. Appoint resident directors. Identify and appoint managing directors who are Macau permanent residents, as required by the Gaming Law.
  3. Prepare the business plan. Draft a comprehensive gaming operations plan covering projected gross gaming revenue (GGR), internal controls, staffing, responsible gaming measures and community contribution commitments, all of which are evaluated during the tender.
  4. Engage compliance advisers. Commission AML/CFT manuals, responsible gaming policies and internal audit frameworks ahead of the formal submission deadline.

For suppliers seeking gaming machine approvals, this stage involves engaging an accredited testing laboratory to certify equipment against the Macau EGM Technical Standards, and preparing the machine technical file for DICJ review.

Step 2, Formal application or tender submission

Who: Applicant; Government Tender Committee (for concessions); DICJ (for supplier/junket applications).
Typical duration: Bid window set by government notice (historically 60–90 days for the public tender); DICJ administrative applications can be submitted at any time.

For casino concessions, the Macau SAR government publishes a tender notice in the Boletim Oficial (Official Gazette) specifying submission requirements, evaluation criteria and the closing deadline. The 2022 tender process, the most recent, was overseen by a dedicated committee established under Executive Order 135/2022. Applicants must submit a sealed bid containing:

  • Completed corporate and shareholder documentation (see H2 4 below for the full checklist)
  • Business plan, GGR projections, and investment commitments (including non-gaming development pledges)
  • AML/CFT compliance manuals and responsible gaming policies
  • Audited financials and source-of-funds evidence
  • Site plans, property documents and fire/safety approvals for proposed casino premises

For gaming machine and equipment suppliers, the application is submitted directly to the DICJ with the relevant machine technical files, testing laboratory certificates and corporate documentation. The DICJ’s machine approval service is listed on the Macao SAR Government services portal under service reference PS-1409.

For junket promoters, the application is submitted to the DICJ with the required promoter agreements, financial guarantees and key-person documentation. Applications for a junket promoter licence are listed on the Macao SAR Government permits and licences portal.

Step 3, Regulatory review, fit-and-proper checks and DICJ technical review

Who: DICJ, Secretary for Economy and Finance, third-party vetting agencies.
Typical duration: 8–20 weeks (concession dossier review); 4–12 weeks (machine approvals per batch).

Once the application or bid is received, the DICJ initiates a multi-track review:

  1. Corporate and UBO verification. The DICJ cross-checks all shareholder disclosures, traces UBO chains and verifies incorporation documents against Commercial Registry records.
  2. Fit-and-proper assessment. Criminal record certificates, financial standing and regulatory history of all key persons are reviewed. The DICJ may commission third-party vetting agencies to conduct background investigations in the applicant’s home jurisdictions.
  3. AML/CFT compliance review. The DICJ assesses the adequacy of the applicant’s anti-money-laundering policies, internal controls, customer due diligence procedures and suspicious transaction reporting mechanisms. Following the 2022 amendments, casinos must develop and implement comprehensive AML programmes, and the DICJ’s review of these during the application phase has become substantially more rigorous.
  4. Technical review (for machine/equipment approvals). The gaming machine approval procedure requires the DICJ to verify acceptance or approval in accordance with the Macau EGM Technical Standards and compliance with the minimum technical requirements. Equipment must pass testing at a DICJ-recognised laboratory before approval is granted.

The DICJ application timeline for this phase varies significantly depending on the complexity of the corporate structure, the number of jurisdictions involved in background checks and any queries raised during the review. Applicants should budget for at least 8 weeks at a minimum and anticipate that complex multi-jurisdictional structures may extend the timeline to 20 weeks or longer.

Step 4, Contract negotiation, licence grant and post-grant compliance

Who: Macau SAR Government, DICJ, concessionaire/applicant.
Typical duration: 4–12 weeks (contract negotiation); 2–6 weeks (licence grant and operational commencement).

For concessions, the casino gaming concession contract is an administrative contract negotiated and signed between the Macau SAR and each individual concessionaire. The contract specifies investment commitments, non-gaming development obligations, employment targets, GGR-sharing arrangements and operational conditions. Once finalised, the concession contract is published in the Official Gazette and registered with the DICJ.

For supplier licences and junket promoter authorisations, the DICJ issues a formal approval notice following the satisfactory completion of all review steps. Post-grant, all licence holders must comply with ongoing reporting, inspection and compliance obligations.

Consolidated gaming concession process Macau, timeline table

Step Who does it Typical duration
Pre-application corporate setup and business plan Applicant, counsel, financial advisers 2–8 weeks
Public tender submission (concession) or DICJ application (supplier/junket) Applicant → Government Tender Committee / DICJ 60–90 days (tender window); ongoing (DICJ applications)
DICJ dossier review and fit-and-proper checks DICJ, third-party vetting agencies 8–20 weeks
Machine/equipment technical review and testing DICJ technical teams, accredited testing labs 4–12 weeks per batch
Concession contract negotiation and signature Macau SAR Government, applicant 4–12 weeks
Licence grant and operational commencement DICJ 2–6 weeks after contract signature / approval

Documents Needed for a Gaming Licence in Macau

The documents needed for a gaming licence application are extensive. The following table consolidates the mandatory submissions for concession applicants, with notes indicating parallel requirements for supplier and junket applications. All foreign-language documents must be accompanied by certified Chinese and/or Portuguese translations, and notarisation or apostille authentication is required for documents issued outside Macau.

Document Notes (issuer, format, validity)
Company incorporation certificate Issued by Macau Commercial Registry; certified copy; must be current at date of submission
Articles of association / Memorandum Certified copy reflecting sole corporate purpose (games of fortune or chance)
Shareholder and UBO list Notarised; must include passport/ID copies for each UBO; chain-of-ownership chart required
Audited financial statements (last 3 years) Audited by internationally recognised firm; in MOP or equivalent with certified translation
Business plan and gaming operations plan Must include GGR projections, internal controls, staffing, responsible gaming and community contributions
AML/CFT policies and compliance manuals Must identify the named AML compliance officer; aligned with DICJ guidance and 2022 amendments
Criminal record certificates (key persons) Issued by country of residence; valid for 3–6 months from issue; apostilled if foreign-issued
Proof of capital / bank letters Issued within preceding 90 days; must include source-of-funds documentation
Property/site documents and floor plans Technical drawings, fire/safety approvals; applicable to concession applicants with physical casino premises
Machine/equipment technical files (suppliers) Per Macau EGM Technical Standards; testing laboratory acceptance certificate required
Junket promoter documents (where applicable) Promoter agreements, financial guarantees, key-person disclosures per DICJ requirements

Gaming machine approval procedure, sub-process

The gaming machine approval procedure is administered by the DICJ under Macao SAR Government service PS-1409. Suppliers must demonstrate acceptance or approval in accordance with the Macau EGM Technical Standards and compliance with prescribed minimum technical requirements. The process involves submission of the machine technical file, testing at a DICJ-recognised laboratory and formal DICJ review. The likely practical effect of the 2022 amendments is that the DICJ now conducts more granular technical inspections, particularly for software-based gaming systems and server-supported platforms.

DICJ Application Timeline and Key Deadlines

The consolidated DICJ application timeline below distinguishes between concession tenders (which occur on a government-set schedule) and administrative licence applications (which are processed on a rolling basis).

Phase Concession (public tender) Supplier / junket licence (DICJ application)
Pre-application preparation 2–8 weeks before tender opens 2–6 weeks before submission
Application / tender window 60–90 days (set by Official Gazette notice) Rolling, submit at any time
DICJ dossier review and fit-and-proper 8–20 weeks 6–16 weeks
Technical review (machines/equipment) N/A (handled post-concession grant) 4–12 weeks per batch
Contract negotiation / licence grant 4–12 weeks 2–6 weeks after review completion
Post-grant commencement 2–6 weeks Immediate upon approval notification

Concession tender windows are rare events. The most recent public tender concluded in late 2022, and the six current concessions run for 10 years. Early indications suggest the next tender round would not occur before 2032 unless exceptional circumstances trigger early reversion. Supplier and junket applications, by contrast, are processed continuously by the DICJ throughout the year.

Cost of a Gaming Licence in Macau, Fees, Capital and Tax

The cost of a gaming licence varies dramatically depending on the authorisation type. The table below outlines the principal cost categories. Where statutory fee schedules are not publicly available, amounts are marked for confirmation with the DICJ or local counsel.

Item Amount Notes
Minimum share capital (concession applicant) MOP 5 billion (approx. USD 625 million) Per ICLG Gambling Laws Report; must be fully subscribed
Gaming tax (special gaming tax) 35% of GGR Statutory rate under the Gaming Law; additional contributions may apply
Additional GGR contributions Up to 5% of GGR Allocated to urban development, tourism promotion and social purposes
Concession premium / tender deposit Varies per tender notice Set by government in each tender round; verify with counsel
Machine approval application fee Verify with DICJ Fee schedule not publicly consolidated; confirm per PS-1409 service listing
Junket promoter licence fee Verify with DICJ Financial guarantee amount set by DICJ; varies by promoter category
Professional fees (legal, consulting, compliance) Varies, budget USD 500,000–2,000,000+ Covers local counsel, compliance audits, vetting, translations; depends on complexity
Incorporation and registry fees Verify with Commercial Registry Standard Macau company formation fees apply

The eligibility capital requirement alone places the concession pathway beyond the reach of most applicants. Suppliers and junket promoters face substantially lower barriers, though financial guarantees and ongoing compliance costs remain significant. All applicants should engage a Macau-qualified gaming lawyer early to map the full cost profile and identify any government-set deposits or bonds applicable to their specific application category.

What Changes in 2026, Key Regulatory Updates for Applicants

Several legislative and regulatory changes since 2022 directly affect anyone assessing how to obtain a gaming licence in Macau this year:

  • Law 7/2022 (Gaming Law amendments). Abolished sub-concessions, capped concessions at six with a maximum 10-year term, tightened fit-and-proper standards, imposed new AML/CFT obligations on concessionaires and enhanced government supervision powers.
  • Law No. 20/2024 (Law on Illegal Gambling Activities). Criminalises the unlicensed supply of games, including the unauthorised supply of online games of chance or online betting. This law strengthens enforcement against unlicensed operators and reinforces that no B2C online gaming licences exist in Macau.
  • Gaming credit regime (2024). The granting of gaming credit is now legally reserved for concessionaires. Third-party gaming credit providers, previously a significant part of the VIP ecosystem, can no longer extend credit independently.
  • Enhanced AML/CFT requirements. Following the 2022 amendments, casinos must develop and implement comprehensive AML programmes subject to DICJ audit. Early indications suggest the DICJ is applying these requirements with increasing granularity during both application review and ongoing compliance inspections.
  • Junket promoter restrictions. Law 7/2022 significantly tightened junket promoter regulations, including enhanced financial guarantees and closer DICJ supervision. The number of active licensed junket promoters has contracted sharply as a result.

Common Pitfalls and How to Avoid Them

  • Weak source-of-funds documentation. Applicants frequently underestimate the depth of source-of-funds tracing the DICJ requires. Prepare a complete funds-flow narrative from original source to the Macau entity, supported by bank confirmations and auditor sign-off.
  • Incomplete UBO disclosures. Omitting indirect or nominee-held interests triggers delays and potential disqualification. Map the full ownership chain to natural persons before submission.
  • Late technical compliance for machines. Suppliers who submit equipment for DICJ testing without first obtaining accredited laboratory certification waste months. Complete laboratory testing before filing the DICJ application.
  • Failing fit-and-proper transparency. Non-disclosure of prior regulatory sanctions, litigation or financial difficulties in other jurisdictions is one of the most common causes of rejection. Disclose proactively and provide context.
  • Reliance on non-Macau formed entities. Attempting to bid through a foreign-incorporated holding company without establishing the required Macau sociedade anónima is a structural disqualifier for concession applications.
  • Confusing concession and supplier pathways. Equipment suppliers do not need a gaming concession; they need DICJ machine approval. Applying via the wrong pathway wastes time and resources.
  • Missing translation and notarisation requirements. All foreign-language documents require certified Chinese and/or Portuguese translation and apostille authentication. Late discovery of this requirement causes significant deadline pressure.
  • Underestimating AML/CFT manual expectations. Generic, template-based compliance manuals are routinely rejected. Tailor AML policies to Macau-specific regulations, DICJ guidance and the applicant’s specific business model.

Need Legal Advice?

This article was produced by Global Law Experts. For specialist advice on this topic, contact Pedro Cortés at Lektou, a member of the Global Law Experts network.

Sources

  1. Macao SAR Government, Permits / Licences / Services
  2. Gaming Inspection and Coordination Bureau (DICJ), History and Regulatory Notices
  3. ICLG, Gambling Laws and Regulations Report 2026 Macau
  4. Chambers Practice Guides, Gaming Law 2025 Macau SAR, China
  5. MDME, Gambling Laws of the World 2026 Guide (Macau)
  6. JSM, New Legal Regime for Granting Gaming Credit in Macau (2024)
  7. UNLV Gaming Law Journal, The Casino Gaming Concession System in Macao
  8. Lexology, A General Introduction to Gambling Law in Macau

FAQs

What are the steps to apply for a Macau casino concession or operating licence?
The process has four main stages: (1) pre-entry planning and local incorporation as a Macau sociedade anónima; (2) formal submission during a government-published public tender window; (3) DICJ regulatory review, fit-and-proper checks and AML/CFT assessment; and (4) negotiation and signature of the concession contract with the Macau SAR government. The entire process typically spans 6–12 months from tender opening to contract execution.
Suppliers submit a machine technical file to the DICJ under service reference PS-1409, together with a testing laboratory acceptance certificate confirming compliance with the Macau EGM Technical Standards. The DICJ conducts its own technical review and issues approval or rejection. The gaming machine approval procedure typically takes 4–12 weeks per batch of equipment.
Concession applicants must incorporate as a Macau limited liability company by shares with minimum share capital of MOP 5 billion. Required documents include audited financial statements, a comprehensive business plan, AML/CFT compliance manuals, criminal record certificates for all key persons and source-of-funds documentation. All foreign-issued documents must be apostilled and accompanied by certified translations.
No. There are no regulations currently governing or licences currently available for operators to offer online gaming services in Macau. Law No. 20/2024 further criminalises the unauthorised supply of online games of chance or online betting, reinforcing that the legal position prohibits B2C online gaming operations.
Foreign investors may participate in Macau’s gaming industry, but concession applicants must incorporate a dedicated Macau sociedade anónima. Managing directors must be Macau permanent residents. For supplier and junket applications, a local legal presence, either a branch office or a locally incorporated subsidiary, is required to facilitate regulatory communication and service of notices.
For concession tenders, missing the submission deadline published in the Official Gazette results in automatic exclusion from that tender round with no right of late submission. For DICJ administrative applications, incomplete filings are returned with a request for supplementary information, but repeated failures to comply with information requests may result in the application being closed.
Local gaming counsel should be retained at the earliest possible stage, ideally before the Macau entity is incorporated. A qualified practitioner will advise on corporate structuring, eligibility assessment, document preparation, DICJ liaison and, for concession bids, tender strategy and contract negotiation. Engaging counsel after submission is typically too late to remedy structural defects.
By Aisha Khan

posted 2 hours ago

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How to Obtain a Gaming Licence in Macau (concessions, Operating Licences & Permits), Step-by-step (2026)

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