Effective 1 June 2026, Federal Decree-Law No. 25 of 2025 removes Articles 1012–1019 from the UAE Civil Transactions Law, replacing decades of civil-law restrictions with a dedicated licensing framework administered by the General Commercial Gaming Regulatory Authority (GCGRA).

For operators, technology providers, investors, and gaming-related service companies, this is more than a regulatory update. It represents a structural shift that introduces a federally regulated licensing regime and establishes a clearer legal foundation for commercial gaming activities in the UAE.

What Is the GCGRA?

The General Commercial Gaming Regulatory Authority (GCGRA) is the sole federal authority responsible for regulating, licensing, and supervising commercial gaming activities in the United Arab Emirates.

Established under federal law, the GCGRA oversees all regulated gaming activities conducted within the UAE or offered to users located in the country. The creation of the authority marked the first time the UAE established a dedicated regulatory framework specifically for the gaming sector.

The GCGRA's jurisdiction covers land-based gaming facilities, lottery operations, sports gaming activities, online and remote gaming platforms, gaming technology suppliers, and key individuals holding senior positions within licensed entities.

Its objective is to create a transparent, secure, and well-regulated gaming ecosystem while ensuring compliance with responsible gaming and anti-money laundering standards.

What Activities Require GCGRA Authorization?

Under the GCGRA framework, businesses must obtain authorization before conducting any regulated gaming-related activity in the UAE.

These activities include:

- Operation of integrated resort gaming venues and gaming facilities

- Lottery products and lottery management services

- Sports gaming operations, including retail and digital platforms

- Online and remote gaming services

- Supply of gaming technology, software, hardware, and platform systems

- Senior executives, directors, compliance officers, and other key personnel working within licensed entities

The licensing framework applies equally across all emirates. Whether a business intends to operate in Dubai, Abu Dhabi, Ras Al Khaimah, or any other emirate, the GCGRA serves as the single federal licensing authority.

There are no exemptions for foreign operators, technology providers, software vendors, or digital-only businesses.

Types of GCGRA Licences

The GCGRA offers multiple licence categories covering different segments of the gaming value chain.

Gaming Facility Operator licences are designed for businesses operating integrated resort gaming venues and land-based gaming facilities.

Lottery Operator licences authorize the management of lottery products and lottery-related services within the UAE.

Sports Gaming Operator licences cover retail and digital sports gaming activities.

Online Gaming Operator licences apply to digital gaming platforms accessible to users within the UAE.

Gaming Technology Supplier licences are intended for B2B companies providing gaming systems, platform software, hardware, APIs, integration solutions, and related technology services to licensed operators.

Individual licences are required for key personnel, including directors, executives, and compliance professionals working within licensed entities.

In many cases, a business may require multiple licences depending on its operational structure. For example, an integrated resort that operates gaming facilities while developing proprietary gaming software may require both an operator licence and a technology supplier licence.

The approval of licensed online gaming platforms in recent years demonstrates that the GCGRA has actively begun implementing its licensing framework across multiple categories.

Eligibility Requirements

The GCGRA evaluates applicants through a comprehensive suitability assessment designed to ensure the integrity and stability of the regulated market.

Applicants are generally expected to demonstrate:

- A strong regulatory and compliance record

- Sufficient financial resources

- Clear ownership structures

- Detailed business plans

- Responsible gaming policies

- Anti-money laundering and compliance programs

- Appropriate technical infrastructure and security controls

The authority reviews both corporate entities and the individuals involved in ownership, management, and operational control.

Can Foreign Companies Apply?

Foreign companies may apply for a GCGRA licence.

However, applicants are generally required to establish a legal entity within the UAE and satisfy all relevant local commercial registration requirements.

The local entity must appoint an authorized representative to communicate directly with the regulator throughout the licensing process.

The GCGRA may also conduct cross-border regulatory reviews, including assessments of the applicant's licensing history, compliance performance, enforcement records, and regulatory standing in other jurisdictions.

The UAE's business environment, including foreign ownership opportunities and access to regional markets, continues to attract international operators and technology providers interested in entering the market through a regulated framework.

Suitability and Integrity Assessment

Directors, shareholders, beneficial owners, executives, and key employees are subject to ongoing suitability reviews.

The GCGRA typically evaluates factors such as:

- Criminal history

- Financial stability

- Industry experience

- Professional qualifications

- Integrity and reputation

- Potential conflicts of interest

Licensees must also notify the regulator of significant changes involving ownership, management, or operational control.

This ongoing oversight reflects standards commonly seen in mature regulated gaming markets around the world.

GCGRA Licence Application Process

The licensing process follows a multi-stage review structure.

Step 1: Initial Submission

Applicants begin by submitting an intake form through the GCGRA licensing portal.

The submission includes basic corporate information, proposed activities, licence category selection, and details regarding key individuals associated with the business.

Step 2: Preliminary Assessment

The regulator conducts an initial review to evaluate suitability and determine whether the proposed activities fall within the GCGRA's regulatory framework.

Additional documentation or meetings may be requested during this stage.

Step 3: Full Application Review

Qualified applicants are invited to submit a complete application package.

This typically includes:

- Corporate registration documents

- Ownership information

- Business plans

- Financial projections

- Responsible gaming policies

- AML/CFT compliance documentation

- Technical specifications

- Security controls

- Financial statements

The regulator then conducts a detailed compliance and due diligence review.

Step 4: Provisional Approval

Applicants meeting all requirements may receive provisional approval.

This allows businesses to prepare operational infrastructure, recruit staff, install systems, and complete implementation activities before launch.

However, live operations are not permitted at this stage.

Step 5: Final Certification

Before commencing operations, applicants must complete final inspections, system testing, compliance verification, and operational readiness assessments.

Only after final certification can licensed businesses begin offering regulated gaming services to the public.

Licence Fees and Ongoing Costs

The GCGRA does not currently publish a standardized fee schedule.

Licensing costs may vary depending on factors such as licence category, business scope, and operational complexity.

Applicants should anticipate costs associated with:

- Application submissions

- Licence issuance

- Annual renewals

- Regulatory contributions

- Individual licence requirements

- Compliance implementation

- Technical audits

- Legal advisory services

Prospective applicants are encouraged to engage directly with the regulator to obtain guidance specific to their business model.

What the June 2026 Civil Code Changes Mean

One of the most significant developments in the UAE's gaming regulatory landscape is the implementation of Federal Decree-Law No. 25 of 2025.

Effective 1 June 2026, the legislation removes Articles 1012–1019 from the UAE Civil Transactions Law.

Under the previous framework, gaming-related agreements were generally considered unenforceable under civil law. The removed provisions addressed matters relating to gaming activities, gaming-related obligations, and associated contractual relationships.

With the implementation of the new framework, the legal foundation shifts from civil-code restrictions toward a dedicated regulatory structure administered by the GCGRA.

For licensed operators, this provides greater legal certainty and establishes a clearer commercial framework for regulated gaming activities.

Importantly, the reform does not authorize unlicensed operations.

Any commercial gaming activity conducted without a valid GCGRA licence remains subject to enforcement under applicable criminal and regulatory laws.

The reform primarily clarifies the legal treatment of licensed activities operating within the approved regulatory framework.

Practical Impact on Operators and Investors

For licensed operators, the new framework reduces regulatory uncertainty and provides a more clearly defined legal environment.

For investors, it creates stronger confidence when evaluating gaming infrastructure projects, technology ventures, integrated resorts, digital platforms, and related business opportunities.

The establishment of a dedicated licensing framework also enhances transparency and provides greater predictability for long-term commercial planning.

At the same time, enforcement expectations for unlicensed activities are expected to become stricter as the GCGRA continues expanding its regulatory oversight capabilities.

AML, CFT, and Compliance Obligations

All GCGRA licensees are expected to maintain robust anti-money laundering and compliance programs.

Licensed entities must implement procedures covering:

- Customer identification and verification

- Enhanced due diligence for higher-risk customers

- Transaction monitoring

- Suspicious activity reporting

- Record retention

- Employee training

- Internal compliance controls

- Ongoing risk assessments

The regulator maintains oversight responsibility for compliance within the gaming sector and may conduct inspections, audits, and reviews of licensed businesses.

Failure to maintain adequate compliance controls may result in administrative action, financial penalties, suspension, or licence revocation.

How Legal Advisors Can Support Applicants

Due to the complexity of the licensing process, many businesses engage experienced legal and compliance professionals before beginning their applications.

Professional advisors can assist with:

- Corporate structuring

- Licence category selection

- Application preparation

- Compliance program development

- Due diligence management

- Regulatory communications

- AML/CFT implementation

- Operational readiness reviews

For international operators and technology providers, professional guidance can help streamline market entry while ensuring compliance with both GCGRA requirements and local business regulations.

Conclusion

The UAE’s gaming regulatory framework represents a major shift toward a federally licensed and professionally supervised market structure.

Through the GCGRA, the country has established a unified licensing regime covering operators, technology suppliers, online gaming platforms, integrated resort venues, and key industry personnel.

For operators, investors, and technology providers, the framework creates new opportunities while also introducing higher compliance expectations.

As the market continues to evolve, businesses seeking to participate in the UAE gaming sector will need to prioritize licensing, compliance, responsible gaming measures, and operational transparency in order to operate successfully within the new regulatory environment.