Under Singapore laws, “gambling” is defined in Section 4 of the Gambling Control Act 2022 (“GCA”) to mean any of the following three categories:

• betting;
• engaging in gaming activity; or
• participating in a lottery,

each explained in Sections 5, 7, and 9 of the GCA respectively.

“Betting” means making or accepting a bet, involving payment or staking of money, money equivalent or any thing else of value on the outcome of any event or likelihood of anything occurring, regardless of the location, truthfulness or certainty.  “Thing of value” may include digital assets, virtual items, in-game credits, NFTs, loyalty points, data access, or rights capable of transfer or monetisation, even if no fiat currency is involved.  As such, a gaming studios, a marketplace for gaming, and “gambling-adjacent” platforms may need to consider the impact of the GCA.

“Engaging in gaming activity” means either (a) playing a game of chance for a prize or (b) playing a gaming machine, and thereby acquires a chance of winning any money or money equivalent or any thing else of value, whether or not the player risks losing anything or pays to participate.

“Participating in a lottery” means any arrangement where prizes are distributed by chance to participant(s), where participation depends on payment or giving of any money or money equivalent or any thing else of value, or on attendance or other qualification without payment.

Notably, the GCA adopts an all-encompassing approach by expressly including remote and online gambling conducted via telecommunications or electronic platforms. This overarching definition ensures that evolving digital products remain regulated.

The GCA is deliberately drafted in a technology-neutral and anti-avoidance manner. The statutory definitions are intended to capture function and economic substance rather than form, platform or labelling.  Products described as “games”, “rewards”, “tokens”, “points”, “prizes”, or “entertainment” may still constitute gambling if they involve consideration, chance and a prize or thing of value.

Singapore’s gambling regime comprises of three primary legislations – the GCA, the Gambling Regulatory Authority of Singapore Act 2022 (“GRAA”) and the Casino Control Act 2006 (“CCA”).

The GCA consolidates previous laws (i.e., Betting Act 1960, Common Gaming Houses Act 1961, Private Lotteries Act 2011 and Remote Gambling Act 2014) into one unified framework, regulating all aspects of gambling activities (other than casinos), including licensing regimes and class-licensed activities.

The GRAA establishes the Gambling Regulatory Authority (“GRA”), a Statutory Board, as the single agency for the entire gambling landscape in Singapore. It governs the GRA’s constitution, membership, function and powers.

The CCA governs the operation and regulation of casinos, gambling activities in casinos and the persons connected with casino gambling.

The GRA is the central regulator for all gambling activities. Established under the GRAA and conferred powers under GCA, and CCA, the GRA was reconstituted from the former Casino Regulatory Authority and gained expanded jurisdiction to regulate the gambling industry. This enables the GRA to stay ahead of technological and gambling trends, respond swiftly to emerging products, and adopt a holistic approach to gambling policy and regulation.

Licences are available for specific gambling operations and are issued by the GRA, with the duration determined by the GRA and specified in the licence itself.

Licences requiring application include:

• Betting operations, lottery and game of chance;
• Community organisations conducting gambling for social bonding and recreation;
• Gaming machine room;
• Tombola;
• Casino operations; and
• In relation to casinos, approvals for manufacturers and suppliers of gaming equipment, and testing laboratories.

Class licences apply to low-risk gambling services (e.g., lucky draws), allowing operators to operate without applying for a licence, provided they comply with all conditions specified in the class licence order.

For casinos, there are distinct requirements for B2C and B2B operators. B2C operators (i.e., casinos) require operating licences, while B2B entities (e.g., manufacturers and suppliers of gaming equipment) must be approved by the GRA under the CCA.

There are no specific licensing requirements for general software suppliers, unless they supply gaming equipment or gaming machine games used in casinos, in which case GRA approval is required under the CCA.  However, while non-casino B2B software suppliers are not separately licensed under the GCA, they may still be exposed to liability if their services are designed, marketed or customised primarily to facilitate unlawful gambling.

At present, GRA has no intention of issuing new licences to conduct casino gambling, or betting operations, lottery and game of chance. Furthermore, there must not be more than 2 casinos licences in force under the CCA at any particular time.

Singapore adopts a default position that all forms of gambling, whether services or products, are illegal unless specifically licensed or exempted.

Notwithstanding this, Section 12 of the GCA provides a limited exemption for “social gambling” when conducted in an individual’s home, on a wholly non-commercial basis, and among persons with pre-existing social relationships. Any deviation from the strict exemption criteria renders the activity unlawful.

Some commonly misunderstood activities that do not constitute a gambling product are

(a) Pure games of skill with no material element of chance

(b) Genuine free-to-enter promotions with no consideration (subject to advertising rules)

(c) Internal corporate incentive schemes with no public participation
However, these may still be regulated under other legislation/guidelines including those relating to consumer protection, advertising or criminal law.

Applications for gambling licences in Singapore are administered by the GRA and eligibility, application requirements, and costs vary depending on the licence type.

The process begins with identifying the appropriate licence. For licences regulated under the GCA, the GRA will conduct a suitability assessment to determine whether the applicant is fit to provide gambling services. In doing so, the GRA considers factors such as whether the applicant has been convicted of an offence specified in Section 55(1)(a) of the GCA, has been involved in criminal activity or subject to actions under Section 55(1)(c), or has been placed in receivership or liquidation.

For licences regulated under the CCA, the GRA must consider the matters set out in Section 45 of the CCA and regulation 3 of the Casino Control (Casino Licence and Fees) Regulations 2009 (“CCCLFR”). These include whether the applicant is of good repute, has sufficient financial resources to ensure the viability of the proposed casino, and possesses the business ability to establish and maintain a successful casino.

For certain low-risk activities, a class licence may apply automatically without a formal application or fee, provided that prescribed conditions are met.
Although not expressly stated in the legislation, a local presence is generally required because the applicant or licensee must provide the GRA with an address in Singapore for service of notices and documents.

Under Section 55 of the GCA, a responsible executive or key officer of an applicant or licensee must undergo a suitability assessment by the GRA to ensure that the individual is fit to be involved in providing gambling services. The factors considered in this assessment are outlined in Question 6 above.

Under Section 80 of the CCA, individuals performing regulated functions essential to casino operations must hold a Special Employee Licence (“SEL”) issued by the GRA in order to engage in such functions. The CCCLFR defines four categories of SEL – category A, B, C1, and C2 – based on the function of the employee.

Advertising and promotion of licensed gambling are generally prohibited in Singapore unless otherwise approved by the GRA. Licensed operators may advertise only within strict limitations aimed at protecting minors and vulnerable persons, preventing misleading claims, avoiding glamorisation of gambling, and discouraging irresponsible or excessive gambling behaviours.

Casino operators are subject to heightened restrictions under the CCA and Casino Control (Advertising) Regulations 2010, including prohibitions on mass-market inducements.

It is also an offence to advertise any form of unlawful gambling activities in or from Singapore, or from outside Singapore to persons in Singapore. If found guilty, an individual is liable to a fine of up to $20,000.

For remote gambling services, the GCA provides provisions for removing unlawful advertisements and empowers the GCA to issue blocking orders to internet service provider to request that such advertisement access be blocked.

The GCA has extraterritorial effect. Offshore operators, affiliates, advertisers, influencers, payment intermediaries and platform operators may be liable if they target, facilitate or enable gambling by persons in Singapore, regardless of where the operator is incorporated or hosted.

Marketing affiliates are generally not permitted in Singapore. Under Section 85(5) of the GCA, prohibited acts of advertising unlawful gambling include arrangements (whether by way of sponsorship, brand‑sharing or otherwise) under which a name is displayed in connection with an event or product. Certain statutory defences apply, such as where the advertisement by marketing affilitates was published at the direction of a licensee or by an intermediary without control over the content.

For casinos, Sections 110 and 110A of the CCA prohibits organising or conducting any casino marketing arrangement involving Singapore citizens or permanent residents unless licensed as an International Market Agent (“IMA”) by the GRA. The CCCLFR define the licensing framework for IMAs. Notably, there are currently no licensed IMAs in Singapore.

The GCA imposes stringent penalties for unlawful gambling operations. Any illegal conduct of gambling services may be punishable by fine not exceeding $500,000 and imprisonment for up to 7 years. Where the person is a repeat offender, the maximum fine increases to $700,000 and maximum imprisonment term increases 10 years.

Further, a gambler that engages in unlawful gambling may be liable to a fine not exceeding $10,000, to imprisonment of up to 6 months, or both.

Beyond operators, the GRA may take action against intermediaries including payment service providers, wallet operators, platform hosts and content distributors that knowingly or negligently facilitate unlawful gambling.

Under the GCA, key requirements include:

• Maintaining suitability of responsible executives and key officers (Section 55 of the GCA).
• Ensuring gambling services are provided only at approved venues or platforms (Section 64 of the GCA).
• Complying with advertising restrictions and prohibitions on unlawful gambling promotions (Section 85 of the GCA).

Under the CCA, casino licensees must:

• Ensure games and gaming equipment are approved by the GRA (Section 100 of the CCA).
• Implement responsible gambling measures (Part II of the Casino Control (Responsible Gambling) Regulations 2013 (“CCRGR”)).
• Obtain SEL for individuals performing regulated casino functions (Section 80 of the CCA).
• Comply with restrictions on casino marketing arrangements and IMA (Sections 100 and 110A of the CCA).

Failure to comply may result in suspension or revocation of the licence, financial penalties, or criminal liability.

Under the CCA and the Casino Control (Prevention of Money Laundering, Terrorism Financing and Proliferation Financing) Regulations 2009, casino operators must implement robust anti-money laundering measures. These include conducting customer due diligence, requiring verification of patrons’ identity and beneficial ownership for transactions of S$4,000 or more and enhanced checks for high-risk customers.

The GCA does not contain detailed AML provisions equivalent to the CCA. Nevertheless, the purpose of the GCA and the conditions within are aimed at limiting opportunities for crime or dishonesty associated with gambling and the conduct of gambling.

Singapore’s responsible gambling framework is embedded in both the CCA and GCA, supported by subsidiary legislation and GRA guidelines.

Under the GCA, some key responsible gambling requirements include:

• Age restrictions: Sections 30 to 35 of the GCA prohibits gambling by and with persons under 21 years old (except for certain betting and lotteries where the minimum age is 18).
• Licence conditions promoting safer gambling: Under Section 57(2) of the GCA, in granting a licence authorising the provision of a gambling service, the GRA may impose conditions such as stake limits, restrictions on inducements and requirements for operators to display responsible gambling messages.
• Advertising and inducement controls: Section 85 of the GCA prohibits unlawful advertising that induces and encourages unlawful gambling.
• Prohibition on credit betting: Section 37 of the GCA makes it an offence for persons to provide credit for unlawful gambling.

Some key responsible gambling requirements under the CCA and CCRGR include:

• Age restrictions: Section 132 of the CCA prohibits persons under 21 from entering casino premises.
• Responsible gambling programme: Regulation 5 of the CCRGR requires casino operators to implement measures including:
  • Systems for patrons to set expenditure or time limits;
  • Display of responsible gambling messages and help resources;
  • Patron education on responsible gambling;
  • Training of casino employees on responsible gambling measures; and
  • Regular review of the responsible gambling programme.
• Entry levies: Section 116 impose a S$150 daily levy or S$3,000 annual levy for Singapore citizens and permanent residents.
• Exclusion orders and visit limits: Sections 159 to 168 of the CCA provide for a list of excluded persons, as well as self-exclusion and family exclusion orders, which restricts entry to casinos.

Under the CCA, strict controls apply to ownership and control of casino operators to prevent criminal influence and ensure regulatory oversight:

• Transfer or disposal of shares: Under Section 42 of the CCA, the main shareholder of a casino operator must obtain written approval from the Minister of Home Affairs (“MHA”) before transferring or disposing its stake to the extent that after that transfer or disposal, the main shareholder’s stake is less than 20% of the total voting shares, is or equal to or less than the percentage of the voting shares held by any other shareholder.
• Acquiring substantial shares: Under Section 66 of the CCA, A person must obtain the approval from the GRA before becoming a 12%, 20% or indirect controller.
• Limitation of stake: The main shareholder of a casino operator must not hold any stake, participate in the management of or enter into any agreement for the management of the other casino.

There are no equivalent statutory thresholds under the GCA, but the GRA may impose ownership and control conditions as part of licence terms.

The GRA has wide-ranging enforcement powers, including:

• Inspection and investigative powers: Powers of entry, examination of records and seizure of evidence. Enforcement officers may also exercise powers of arrest, grant bail and require bonds where necessary.
• Blocking measures: Ability to block access to unlawful online gambling sites and direct payment service providers to block transactions related to remote gambling.
• Additional Sanctions: Authority to impose fines, disciplinary action and criminal prosecution, as well as suspend or revoke of licences, for breaches of licence conditions, regulatory requirements or applicable rules.

Singapore imposes specific taxes on different gambling activities, such as:

• Betting: 25-30% of the gross betting profit, depending on the type of betting activity.
• Lottery: 30% of the gross contributions received for the lottery.
• Gaming machines (non-casino): 9.5% of the gross amount wagered from every player.
• Tombola, continuous lucky draw and single/scheduled lottery: 30% of gross sales.
• Casinos: Gross gaming revenue is taxed monthly at tiered rates:
  • Tier 1: Tier 1 applies if the casino meets the targets relevant to the development of facilities and services of the casino operator’s integrated resort (“Development Targets“). Under Tier 1, premium players are taxed at 8% on the first SGD 2.4 billion of GGR, while other players are taxed at 18% on the first SGD 3.1 billion.
  • Tier 2: If the casino fails to meet the Development Targets, higher rates of 12% for premium players and 22% for other players apply for the period of non-compliance.

Yes. Singapore is expected to refine its gambling legislation to address emerging technologies and evolving gaming trends. Key proposals include the following:

• The MHA proposed the varying of the Gambling Control (Remote Games of Chance – Class Licence) Order 2022 (the “Order”) to allow class licensees to operate in-game marketplaces for player-to-player transactions and trading of prizes. Public consultation recently closed in August 2025, and the outcome remains uncertain.
• The GRA is in the process of developing class-licensed conditions and safeguards on mystery and blind boxes with the aim of regulating this popularised form of gambling. No timeline has been announced for implementation.
• The Casino Control (Amendment) Act was passed on 10 September 2024 and partially commenced on 30 October 2024. Remaining provisions will be operationalised at a later date., although unspecified. This amendment aims to enhance the operational effectiveness of Singapore’s casino regulatory regime, tighten the regulation of the casinos and licensees and strengthen protection for vulnerable groups.

The key regulatory developments proposed or on the horizon in the next 12-24 months largely align with the proposals outlined in Question 17. These include updates to remote gambling regulations, regulation of mystery boxes, and enhancements to casino oversight.

Due to increasing regulatory stringency, restrictions and sanctions on gambling operations, gambling market growth in Singapore remains relatively stagnant. At the same time, gaps persist in the regulation of newer gambling formats, such as blind boxes and in-game prize trading, creating uncertainty for businesses exploring innovative products and models. Regulators have acknowledged these challenges and are actively developing rules, safeguards, and licensing conditions to strike a balance between controlled gambling and consumer protection. However, until these frameworks are clear and fully implemented, the lack of clarity may pose risks to gambling market expansion.

Presently, the GRA has no intention of issuing new licences to conduct casino gambling, or betting operations, lottery and game of chance. As such, Singapore would not be a suitable jurisdiction for companies focused on these activities.

Singapore’s gambling regime is designed not to promote market growth, but to permit tightly controlled gambling in limited circumstances while minimising social harm, criminal abuse and regulatory arbitrage.

However, for other regulated forms of gambling, Singapore remains an attractive choice. Its strong regulatory framework and reputation for law and order provide a high level of certainty and stability for operators. While stringent licensing requirements and high compliance standards raise barriers to entry, they also ensure a well-regulated market that is not oversaturated, thereby creating opportunities for credible operators to succeed. In addition, Singapore’s advanced digital infrastructure and status as a regional financial and technology hub offer a stable, transparent, and secure platform for advancement and growth. These factors, combined with strict enforcement against illegal gambling, make Singapore a compelling jurisdiction for gambling start-ups seeking credibility and long-term sustainability.