A Japanese government review committee concluded on December 22, 2023 that the Kyushu-Nagasaki integrated resort (IR) plan should not be certified, saying it does not meet the required standards. The plan was submitted by Nagasaki Prefecture and KYUSHU Resorts Japan Co., Ltd., referred to together as the applicant, and was accepted under reference R04-15300-00074 dated the 26th day of the fourth month of Reiwa 4, ahead of the application deadline of the 28th day of the fourth month of Reiwa 41.
The committee said the plan fails "requirement standard 4" on funding certainty. It found that the planned investors and lenders as of September 2023 differed substantially from those named at the time of application, that some planned investors had not submitted the letters confirming funding that should accompany the plan, and that many letters were addressed to parties other than the correct recipients. Many submitted letters were not legally binding or similar, and financing terms were as unclear as those from companies that had previously planned to invest but withdrew1.
"資金調達の確実性を裏付ける根拠が十分であるとは言い難いことから、要求基準4に適合しないとすることが相当である"
The committee also found the plan fails "requirement standard 11" on continuous operation using casino revenue and "requirement standard 15" on measures to address gambling harm. It said it could not confirm IR development and operating experience or expertise among planned investors other than CASINOS AUSTRIA INTERNATIONAL (CAI), and that even for CAI, IR operating experience could not be sufficiently confirmed. CAI's equity share was described as extremely small and the commitment level in its letter as insufficient, so its capital involvement in the IR business was judged inadequate. The committee added that most of the planned investment would come from investment companies, leaving unresolved concerns about whether returns to investors would take priority over channeling casino revenue into the IR business and over harm prevention measures1.
"カジノ事業の収益の活用によるIR事業の継続的な実施(要求基準 11)及びカジノの有害な影響の排除に関する措置の適切な実施(要求基準 15)のいずれについても裏付けとなる根拠が十分であるとは言い難いことから、これらの基準に適合しないとすることが相当である"
The committee's overall position was that because the plan does not meet the required standards, it is appropriate not to certify it under the basic policy1.
| Requirement standard | Committee finding |
|---|---|
| 4: Funding certainty | Investors and lenders changed substantially from application; some confirmation letters missing or misaddressed; many letters not legally binding |
| 11: Continuous IR operation using casino revenue | Insufficient basis; CAI equity share extremely small and commitment level insufficient |
| 15: Measures against gambling harm | Insufficient basis; no confirmed IR operating experience among other investors |
What it means for players
Japan has not opened any casino resort, and this decision keeps the Kyushu-Nagasaki project off the list of certified plans. There is no casino to enter in Nagasaki or anywhere else in Japan on the strength of this plan, and no operating date has been set. Rules on entry, play and conduct inside Japanese casinos will be set under the IR Development Act (Act No. 80 of the 30th year of Heisei) for any resort that is eventually certified, so nothing about access or play changes for locals, expats or visitors as a result of this finding. For background on how gambling is regulated in the country, see Can I Gamble in Japan? and Casinos and Integrated Resorts in Asia: Who Can Enter, What You Can Play and the Rules Inside.
What happens next
The committee's view is that certification should not be granted. No further steps, revised application or new timeline for the Nagasaki plan have been reported.
Sources1 sources
- 810000788.pdf, mlit.go.jp





