UAE has historically maintained strict prohibitions against gambling, as per both Islamic legal principles and the country’s longstanding criminal law framework. However, recent regulatory developments show a gradual change towards a controlled and regulated commercial gaming sector. A significant milestone in this transition is the issuance of the new UAE Civil Transactions Law (Federal Decree Law No. 25 of 2025), which will come into force on 1 June 2026.
Among the structural changes introduced by the new legislation, one of the most significant is the removal of all provisions relating to gambling and betting that were previously included in the earlier Civil Code. This legislative development depicts UAE’s wider strategy of creating a specialized regulatory framework for commercial gaming, separate from general civil law principles.
Gambling Under the Former Civil Transactions Law
Under the repealed Civil Transactions Law, gambling and betting were addressed in Articles 1012 to 1021. These provisions established the legal consequences of gambling-related agreements and disputes.
The main principles under the former law included:
- Invalidity of gambling contracts: Agreements based on gambling or betting were generally considered unenforceable.
- Recovery limitations: A person who voluntarily paid gambling losses could not usually reclaim them.
- Restitution in specific circumstances: Courts could allow recovery where the payment involved fraud, coercion, or illegal conduct.
- Judicial discretion: Judges had limited authority to order repayment in certain situations involving fairness or public policy considerations.
These provisions were consistent with the UAE’s traditional legal position that gambling contracts lacked lawful cause and therefore could not be enforced before courts.
The New Civil Transactions Law (2025) and Removal of Gambling Provisions
The newly enacted UAE Civil Transactions Law, replacing the previous civil code, introduces several structural reforms to modernize UAE’s private law framework. One of the notable changes is that all articles dealing with gambling and betting have been removed.
Unlike the earlier law, the new civil code does not contain any provisions specifically addressing gambling, wagering, or betting agreements. The omission is widely viewed as a deliberate legislative decision rather than a mere drafting change.
This change indicates that the regulation of gaming activities is being moved away from general civil law and into a specialized regulatory regime designed specifically for the gaming sector.
Emergence of a Specialized Gaming Regulatory Framework
The removal of gambling provisions from the civil code coincides with the creation of the General Commercial Gaming Regulatory Authority (GCGRA). This federal authority was established to regulate and supervise UAE’s emerging commercial gaming industry.
The GCGRA is responsible for:
- Licensing gaming operators
- Regulating lotteries, casinos, and online gaming platforms
- Establishing compliance standards
- Preventing financial crimes such as money laundering and fraud
- Ensuring responsible gaming practices
Through this regulatory authority, UAE government is developing a centralized system governing commercial gaming activities, including lotteries, internet gaming, sports wagering, and land-based gaming facilities.
The change showcases a regulatory model similar to jurisdictions such as Singapore and certain U.S. states, where gaming is not governed by general civil law but by dedicated gaming statutes and regulators.
Practical Implications of the Legislative Change
The omission of gambling provisions from the new civil code carries several practical implications.
- Removal of Legal Ambiguity
Previously, gambling-related disputes could theoretically fall within the framework of civil law provisions addressing wagering contracts. By removing these provisions, UAE legislature has eliminated confusion between civil law rules and specialized gaming regulations.
- Shift Toward Sector-Specific Regulation
Gaming activities will now be governed primarily through regulatory licensing regimes rather than general legal principles applicable to contracts. This approach allows regulators to impose specific operational, financial, and consumer protection requirements.
- Facilitation of the Emerging Gaming Industry
UAE has begun exploring commercial gaming as part of its broader economic diversification strategy. Removing outdated civil law provisions helps establish a clearer regulatory environment for licensed operators and investors.
By removing provisions that overlap with emerging gaming regulations, lawmakers aim to:
- Avoid duplication of legislation
- Provide legal clarity to investors and operators
- Strengthen regulatory oversight of gaming activities
- Ensure consistent enforcement mechanisms
This strategy aligns with UAE’s broader legal reform agenda aimed at modernizing commercial and regulatory frameworks.
Conclusion
The enactment of the new UAE Civil Transactions Law, effective from 1 June 2026, marks an important step in the modernization of the UAE’s legal system. By removing the gambling provisions that previously existed under the Civil Transactions Law, UAE has signalled its intention to regulate gaming through specialized regulatory mechanisms rather than general civil law provisions.
This legislative change supports the mandate of the General Commercial Gaming Regulatory Authority, which is expected to play a central role in shaping the country’s emerging gaming sector. The reform demonstrates UAE’s proactive approach to creating an intelligible and modern regulatory environment while maintaining strict oversight of gaming activities.
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