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Online Gaming in Singapore

Authored by Rajah & Tann Singapore LLP (Last Updated Jan2024)

Overview

Restricted

Singapore Online Gaming Overview

Heavily Regulated
Singapore allows for limited forms of gambling and only with state licensed operators. Gambling in Singapore is regulated primarily by the Casino Control Act 2006 (“CCA”) for casino gambling, and the Gambling Control Act 2022 (“GCA”) for all other forms of gambling, whether land-based or online. Oversight of the gambling landscape is exercised by a single regulator in the form of the Gambling Regulatory Authority of Singapore (“GRA”), a statutory board under the Ministry of Home Affairs. Among other things, the GRA is empowered to grant licences to parties which operate and offer games of chance, and class licences to parties engaged in lower-risk gambling offerings.

Market Size
For casino gambling, the gaming revenue at Singapore’s two integrated resorts was reported to be S$1.41 billion in the third quarter of 2023.

For non-casino gambling, the amount spent betting on lotteries and sports such as football in Singapore totalled S$10.3 billion in the financial year ended in March 2023. Singapore Pools (Private) Limited (“Singapore Pools”) remains the only legalised lottery and sports betting operator in Singapore.

In addition to Singapore Pools, there are various private clubs which are licensed to operate jackpot machines and other games like bingo and sweepstakes. These clubs all declare their revenue separately in their annual reports.

Competitive Landscape
There are only two licensed casino gaming services operators in Singapore, Marina Bay Sands and Resorts World Sentosa. The GCA does not prescribe restrictions on the number of licences that may be granted. However, Section 41(1) of the CCA provides that only two casino licences are to be in force at any particular time, at least until 31 December 2030.

In the non-casino gaming sphere, Singapore Pools is the only gambling operator authorised by the GRA to conduct and offer legalised remote and terrestrial gambling services, namely betting on sports and horse racing and public lotteries. Additionally, private establishments may also be granted licences to offer slot machines at their premises.

Localisation
Cash and e-payments are both used as means of payment of bets. Credit betting is prohibited, save for credit which a licensed casino may provide to premium players or players who are neither citizens nor permanent residents of Singapore. All forms of advertising, marketing and promotion of gambling in Singapore are subject to the approval of the GRA.

Top Key Attractions and Challenges
Attractions

  • Stable government
  • Relatively low corporate and casino tax rate, no capital gains tax
  • Excellent reputation as business hub and financial capital in Asia
  • Excellent air connectivity, no tourist visas required for stays under 90 days
  • Great weather, summer all year round

Challenges

  • Strong anti-unlicensed gambling stance by Singapore government
  • Low prospect of licences being awarded to private, for-profit commercial gambling operators
  • Levy imposed on Singapore citizens and permanent residents for entry into licensed casinos
  • All forms of advertising and promotion relating to gambling that is licensed or deemed unlawful under the GCA are prohibited unless otherwise approved by the GRA
  • High cost of living

Licensing & Regulation

Onerous regime / Unregulated (Restricted)

Singapore Online Gaming Licensing & Regulation

Licence Triggers
Under the GCA, any activity that falls under the definition of “gambling” would require licensing (including by way of class licences). However, the GCA provides exceptions for certain forms of land-based social gaming (see section on “Bingo Overview” above).

Array / Type of licence needed
In respect of land-based casino gambling, the CCA requires licences to...

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Enforcement

Irregular / Mixed impact

Singapore Online Gaming Enforcement

Regulating Bodies
The GRA is the main authority involved in regulating the gambling sector in Singapore. The GRA has the authority to direct the Infocomm Media Development Authority (“IMDA”) to issue access blocking orders to block illegal online gambling websites, and to direct the MAS to issue payment blocking orders against certain financial institutions or financial transaction providers if it...

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Marketing

Restricted

Singapore Online Gaming Marketing

Generally, all forms of advertising related to gambling whether from Singapore or a foreign country are subject to the approval of the GRA. Under Section 16 of the GCA, a gambling advertisement is considered as published in Singapore regardless of whether medium used is online or offline (e.g. newspaper, film, TV programme, radio, exhibition, and any other means). Under Section...

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Fees

High

Singapore Online Gaming Fees

Application fees
Casino Licence: SGD 1,100 (fresh application), SGD 850 (renewal)

Casino Special Employee Licence

Category A (Senior Management): SGD 400 (fresh application), SGD 350 (renewal) Category B (Middle Management): SGD 320 (fresh application), SGD 300 (renewal) Category C1 (operations personnel): SGD 270 (fresh application), SGD 240 (renewal) Category C2 (technical support services): SGD 270 (fresh application), SGD 240...

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Taxes

Average

Singapore Online Gaming Taxes

Licence Taxes
See answer under Products section below.

Sales Taxes
Sales tax in Singapore is also known as the Goods and Services Tax (“GST”). The GST is a broad-based consumption tax levied on the import of goods and supplies of goods and services in Singapore, unless the import or supply (as the case may be) is an exempted...

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Future Outlook

Positive

Singapore Online Gaming Future Outlook

Singapore has historically adopted a piece-meal regulatory approach towards gambling, with different areas or types of gambling being governed by different pieces of legislation. However, a substantial overhaul of the gambling laws in Singapore took place in 2022 with the enactment of the Gambling Regulatory Authority of Singapore Act (“GRA Act”) and the GCA. These were passed in the Singapore...

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Legal Expert

Rajah & Tann Singapore LLP

Office locations Cambodia / China / Indonesia / Laos / Malaysia / Myanmar / Philippines / Singapore / Thailand / Vietnam

Rajah & Tann is a regional full service law firm with offices in 10 countries staffed by close to 800 fee earners across different practice areas. The Singapore office has been actively representing and advising clients in the gaming industry since 2002, and has arguably the most experienced gaming law practice in the South East Asian region.

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