Macau's revised gaming law, Law No. 16/2022, came into force in December 2022, banning junkets from accepting deposits and restricting that activity to concessionaires1. The change was set out in a legal analysis by lawyers Bruno Almeida and Belmiro Leong, respectively a partner and associate at law firm Riquito Advogados, published by Macau Business1.
Gaming promoters, formally recognized under Law No. 16/2001 and regulated by Administrative Regulation No. 6/2002, had long played a central role in attracting clients and managing gaming rooms1. Since 2015, a wave of cases emerged after junket operators defaulted on deposits, raising questions over concessionaires' liability1. In November 2021, the Court of Final Appeal ruled concessionaires were jointly liable for deposits linked directly to gaming activity1. Deposits made for other purposes, such as investments or interest-bearing schemes, were excluded1.
Article 63 of the law introduced an interpretative provision confirming that liability applies only when funds or chips are used in casino games or result from them1. The lawyers said this "would put an end to a number of questions and theories about the actual scope of the concessionaires' joint liability"1.
"The assessment of the joint liability of the concessionaire shall be made in light of the interpretative rules."
The lawyers stressed that the provision has retrospective effect1. In September 2025, the Court of Final Appeal further ruled (Award No. 124/2022) that concessionaires cannot be held accountable under general tort liability for junket debts1. Although Macau's legal system does not rely on precedent, rulings of the Court of Final Appeal are expected to guide future cases1. The lawyers concluded that Award No. 124/2022 is expected to decisively consolidate the understanding that joint liability of concessionaires can only be enforced when plaintiffs can evidence their direct utilization in gambling1.
What it means for players
Under the law, a junket operator in Macau can no longer accept deposits, and only a concessionaire may do so1. Where money or chips were placed with a junket and were not used in casino games or do not result from them, the courts have held that a concessionaire is not jointly liable1. Deposits made for other purposes, such as investments or interest-bearing schemes, were excluded from the November 2021 ruling1. The September 2025 ruling went further, holding that concessionaires cannot be held accountable under general tort liability for junket debts1. The interpretative provision in Article 63 applies retrospectively1. Macau's legal system does not rely on precedent, but Court of Final Appeal rulings are expected to guide future cases1.
What happens next
No further legislative or court steps are set out in the analysis. It states that Award No. 124/2022 is expected to consolidate the position that joint liability of concessionaires can only be enforced where plaintiffs can evidence direct utilization in gambling1. The wider framework is covered in Recent and Pending Gambling Law Changes in Asia and Gambling Laws in Asia: What Is Legal in 12 Jurisdictions; for the local market, see Can I Gamble in Macau?.
