It has been over 10 months since the formation of the UAE General Commercial Gaming Regulatory Authority (GCGRA) and, following much interest and excitement in the initial announcement, what followed was, until now, a period of relative silence.

The GCGRA has now gone live with its new website (available at gcgra.gov), marking another key milestone in the UAE’s journey to becoming the first GCC country to become host to lawful commercial gaming activities. 

Key highlights are as follows. The website features:

1. Details of the first GCGRA licensee, the operator of the UAE national lottery (see The Game LLC, based in Abu Dhabi), have been published.
    
2. A page which explains the GCGRA’s definition of “Commercial Gaming”, and how this differs from “Promotional Activities”: 
   
   “Commercial Gaming” refers to “any game of chance, or combination of chance and skill, where an amount of money, in cash or cash equivalents, is wagered – i.e. placed as a bet – for the purpose of winning a sum of money or other valuable items” and “extends to agreements within such games that stipulate the loser must compensate the winner with money or any other item of value. Commercial games encompass gaming machines, internet gaming, electronic skill-based games, lottery games, event wagering (including bets placed on certain events such as sporting events, or horse racing), along with any other form of commercial gaming regulated and licensed by the GCGRA”.
    
3. A 16 page Licensing Guide, which sets out details of the licences available, conditions for securing those licences (including documentary requirements) and the process for doing so. Broadly, the licensing categories are as follows: 

• Gaming Operators (including gaming facility operators, lottery operators, lottery retailers, internet gaming operators and sports wagering operators);
• Gaming Related vendors (i.e. Suppliers of goods and service related to gaming equipment);
• Entities and / or individuals that qualify as “Key Persons” in relation to either of the above;
• Gaming Employees (with those licences being split into two "levels”: one for employees in supervisory roles and one for those involved, directly or indirectly, with the conduct of commercial gaming).

4. An intake form (for licence applications) which, interestingly, allows for applications to be submitted from any of the seven Emirates which form the UAE. 

5. A set of Advertising Standards for Commercial Gaming which cover:

• General restrictions;
• Advertising to underage persons (including the use of age verification tools and algorithms to minimise exposure); 
• Promotional marketing activities; 
• Opt-out conditions for targeted advertisements;
• Standards applicable to specific channels such as TV, radio, websites and streaming platforms;
• Sponsorship;
• Social media rules; and
• A hard restriction on the use of Arabic language in advertising materials unless otherwise [permitted] by the GCGRA.

6. A suite of 17 technical standards produced by Gaming Laboratories International, who are also the sole Certified Service Provider for the inspection and testing of commercial gaming equipment according to the GCGRA website.

Despite the impressive progress made by the GCGRA, it remains somewhat unclear how the licensing framework will permit GCGRA licensees to lawfully engage in commercial gaming activities when considering the overarching criminal prohibitions under UAE law against gambling. It remains possible that we will see UAE legislators move to amend those overarching laws in the coming months and years, but until that time the framework continues to sit in something of a legal grey area. 

If you would like further information on the latest developments, please do not hesitate to reach out to us.