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UAE market 'will require adjustments'¡ªbut still worth the bet, expert explains
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As the United Arab Emirates charts new territory with its ambitious entry into the world of regulated gambling, international eyes are watching closely¡ªand some are already placing bets. For Lu¨ªs Portela de Carvalho, Partner at Lektou and a specialist in gaming, media, and entertainment law, the UAE’s regulatory approach is not just noteworthy¡ªit’s a model of innovative, deliberate design.
With years of experience advising top-tier gaming companies, Portela de Carvalho brings a clear-eyed view of the opportunities and challenges ahead. In this interview with SiGMA News, he breaks down why the UAE’s high tax regime isn’t deterring serious operators, how cultural nuance shapes strategy, and why the window for early movers is closing fast.
A smart, strategic start
Unlike other jurisdictions where gambling regulation emerges from existing bureaucracies or siloed authorities, the UAE has taken a deliberately expert-led and open approach.
“What was done here was very smart,” Portela de Carvalho said. “They brought in the best¡ªindustry veterans, experienced regulators, and people with boots-on-the-ground knowledge.”
At the helm of this new regime is Kevin Mullally, a respected figure in the global regulatory sphere. “He’s a veteran of the industry,” Portela de Carvalho noted. “He is the right person to build something from scratch.”
And they didn’t stop with personnel. The UAE’s General Commercial Gaming Regulatory Authority (GCGRA) also implemented tight timelines and began issuing licenses within two years¡ªa remarkable pace given the complex cultural, religious, and political context of the region.
“They already have Advertising Standards published for around a year now,” he added. “That’s not something you’d expect this early on. It’s impressive.”
Not there yet¡ªbut getting there
As gambling regulation takes shape in the United Arab Emirates (UAE), one thing has become increasingly clear: the current Gaming tax regime isn’t built to be profitable. At least not yet. But that doesn’t mean it’s failing, Portela de Carvalho adds. Quite the contrary. The GCGRA is laying the groundwork for a market that’s expected to shift¡ªstrategically, structurally, and financially.
At the heart of this expectation is a shared belief among many in the industry: the current high tax burden will be amended, and the framework will evolve in response to stakeholder input.
“No one would invest in this market if they didn’t strongly believe that the regime will change,” said Portela de Carvalho to SiGMA News. “Right now, the regime is not profitable. You don’t need to be an expert to understand that¡ªjust open a spreadsheet.”
Yet despite this unprofitability, operators are already moving in. Why? Because they believe in what’s coming next ¡ª and so does Portela de Carvalho.
“The tax regime is very high. Too high to be sustainable,” he explained. “But the GCGRA is open to dialogue. They’ve been listening to the market, and I believe they will be in favour of amending the tax rate to make it viable¡ªparticularly for online operations.”
He was firm in his assessment: “As it is now, no one can make a profit. But that’s not the end of the story. This is a foundational phase, not a final one.”
Betting on change: why operators are still entering
Operators entering the UAE are making a calculated decision¡ªthey are betting on future regulatory flexibility.
“There’s no way companies would be setting up shop under these financial terms if they didn’t believe change was coming,” Portela de Carvalho said. “They’re taking the long view. They believe that the GCGRA’s openness and pragmatism will lead to a more balanced framework.”
This openness isn’t typical. “Most regulators don’t engage with the industry,” Portela de Carvalho observed. “They shut the doors. But here, the GCGRA has been actively seeking input from stakeholders, and that’s made all the difference.”
Understanding the local context
Still, regulation in the UAE can’t be divorced from its cultural and religious context, which is central to how gambling is perceived and structured.
“You won’t see local Emiratis playing,” Portela de Carvalho said. “I believe that’s not going to change, and it’s understood. The market is for expatriates¡ªIndians, Eastern Europeans, and others who make up the demographic.”
Operators need to build for that reality. “It’s crucial to have boots on the ground,” he added. “You can’t build your strategy for the UAE from a distance. You need people who understand the local sensibilities, values, and media environment.”
Marketing and advertising are similarly affected. “The Advertising Standards are specific to the region,” Portela de Carvalho explained. “You can’t just copy-paste campaigns from Europe. You have to respect the local framework.”
While the GCGRA has issued only a handful of licenses so far, Portela de Carvalho believes that the criteria are clear. “They’re focused on reputation. They want players that have already proven themselves in other jurisdictions¡ªno serious breaches, no shady practices.”
Financial capacity matters, of course, but it’s not the only factor. “In some jurisdictions, they only look at your bank account. Here, it’s different. They want operators who will cooperate to build a world-class framework. Operators who will respect the country’s values. That’s their goal.”
A thoughtful regulatory burden
One of the more debated points is the responsibility placed on operators to monitor affiliates and advertisers. Under GCGRA rules, operators are liable for their suppliers’ behaviour.
Portela de Carvalho believes this is not only necessary but smart.
“The regulator doesn’t have unlimited power or people,” he said. “They can’t monitor every single affiliate. So, giving that responsibility to the operators both burdens and empowers them. It forces the industry to self-regulate.”
He also sees this as an opportunity for better business practices: “Set internal standards higher than what the law requires. Use proper contracts. And leverage technology¡ªespecially programmatic advertising¡ªto ensure compliance.”
Legal advisors as strategic allies
Portela de Carvalho is not just a lawyer¡ªhe’s an advocate for a new kind of legal practice. “We’re not here to block decisions or just draft contracts,” he said. “We’re strategic partners.”
He’s been fortunate to work with clients who understand this. “More and more, young industry leaders call us before launching a strategy. They bring us in from day one. That’s how it should be.”
But there are still cases where legal is treated as a postscript. “When we’re called in too late, we still try to make it right¡ªbut it’s harder. Prevention is always better.”
He stresses the importance of clear communication. “If lawyers want to be heard, they need to speak the client’s language¡ªnot legal jargon. The goal is profit, and it’s our job to help clients reach that without falling afoul of the rules.”
“The time to go is now”
If a client came to him tomorrow unsure about investing in the UAE, Portela de Carvalho’s answer would be unambiguous.
“Yes. Go now,” he said. “Because very soon, the opportunity will close. There’s not unlimited space. And those who wait might miss the chance to shape the market’s direction.”
For him, the story of UAE gambling regulation is not about what it is today¡ªbut what it’s poised to become.
“It’s a young market,” Portela de Carvalho concluded, “but it’s moving in the right direction. And those who get in early¡ªsmartly, legally, and strategically¡ªwill have the advantage.”
