Betting on Betting: Thailand's Casino Ambitions and the Challenges Ahead
Thailand is advancing plans to legalise casinos within integrated entertainment complexes to boost tourism and generate additional state revenue.
The Entertainment Complex Summit took place from December 2-4, 2024 at Bangkok Marriott Hotel, The Surawongse, organised by Winna Media and key partners. The Summit brought together global experts and seasoned professionals from the gaming and gambling sectors to explore the potential benefits, opportunities and provide insights and strategies for establishing a thriving, well-regulated entertainment and gaming industry in Thailand.
Some promising figures were presented to demonstrate Thailand as the next global destination for gaming. CLSA, an investment group specialising in areas like asset management and corporate finance, estimated that 40 million visitors would generate USD 15 billion in gaming revenue annually. Thailand also benefits from a strategic geographical location, within a six-hour flight of numerous densely populated nations, each exceeding 30 million inhabitants.
In 2023 had gaming businesses been legalised, Thailand would have become the world's third biggest casino market.
- Jeffrey Kiang, Equity Research Analyst, CLSA
At least 4 of Macau’s Big Six are eying this new global opportunity, with Galaxy and MGM have expressed their interest. Las Vegas Sands, Wynn Resorts, Caesars Entertainment, Hard Rock Cafe, Genting Group as well as an investment group from South Korea are also reportedly considering ventures in Thailand.
TravConsult, a consultancy specialising in aviation, tourism, and retail, believes Thailand has the potential to succeed in the casino industry due to its renowned hospitality. However, successful execution will be key.
Ben Lee of IGamiX Management & Consulting suggests that the location of casinos will depend on the government's goals for distribution—whether they aim for a cluster of casinos or a more spread-out approach. He also emphasises the importance of establishing luxury destinations to compete with the global gambling market. Lily Choi-Lee of TravConsult further added that the brands leading the market will ultimately shape the profile of tourists attracted to the new era of tourism in Thailand.
While Thailand is new to the casino industry, international expertise will be crucial for achieving sustainable success in this new sector. Anthony Lawrence, Managing Director of Intelligence Macau, highlights that political work needs to be done to reach internal consensus, and experts should be brought in to share precedent success stories to develop the industry.
Public Hearing has concluded (August 2–18, 2024) here are some of the key highlights.
Firstly, the public consultation proposes the change from “Entertainment Complex” (EC) to “Integrated Resort” (IR) in line with international standards fostering a positive project image, after the completion of public consultations.
The government highlights the potential economic benefits of legalising casinos in Thailand, citing increased state revenue and tourism growth, especially given the success of such initiatives in neighbouring countries.
This stance is supported by strong public approval, with 80% of respondents in an online hearing endorsing the proposal, despite some opposition from youth NGOs. Some of the concerns remain about potential social issues associated with casinos, including increased gambling addiction, risks to young people, mental health problems, social inequality, and the possibility of business monopolies.
To be qualified as an entertainment complex, the project can dedicate a maximum of 5-20% of the total space to casinos, and must include at least four other entertainment options from a designated list:
Shopping centers,
Water parks or swimming pools,
Hotels,
Restaurants, bars, discotheques, and pubs
Sports arenas,
Gaming arcades,
Amusement parks,
Yachting clubs,
Areas for the promotion of Thai culture and OTOP products, and
Others as determined by the board
The Entertainment Complex Act will establish a policy board (“Entertainment Complex Policy Committee”—EC Committee), chaired by the Prime Minister and vice-chaired by the Deputy Prime Minister, with nine ex-officio members and up to six qualified experts.
The public hearing additionally suggested groups include civil societies operating within the areas of community development, human rights, children and youth, economics, sociology, and mental health as well as representatives from the National Child and Youth Development Promotion Committee, the Community Organizations Council, and the National Human Rights Commission of Thailand.
The EC Committee’s responsibilities include policy formulation, impact mitigation, license allocation, operational guidelines, preventing addiction and monopoly, and addressing conditions for granting or revoking licenses. Additional duties include overseeing operational hours, shareholder criteria, and license renewal or revocation procedures.
The legislation includes stringent measures to mitigate social impacts, such as preventing gambling addiction and money laundering. Proposed safeguards include requiring Thai shareholders to hold 30-51% ownership in each complex and ensuring the Thai workforce constitutes at least 80% to prevent foreign dominance. These measures aim to balance economic benefits with social responsibility, ensuring the initiative contributes positively to Thailand's economy and society.
To distribute income and promote tourism beyond Bangkok, the government proposes establishing entertainment complexes in regions such as Phuket, Chiang Mai, Chonburi, Rayong, and Hua Hin; while limiting licenses to no more than 2-3 in Bangkok.
One spot in the capital apparently has been claimed by the Royal Turf Club of Thailand (RTCT)’s 6-billion-dollar “The Royal Siam Haven”.
The consultation recommends granting the EC Committee the authority to oversee additional games, such as boxing, horse racing, sports betting, and skill-based games like poker. It also suggests a comparative study of international casino operations while continuing to evaluate the feasibility of online gambling. Some case studies cited in the government primary research include Antigua, Las Vegas, Macau, Malaysia, and Singapore.
Some key ambiguities in the law remain to be clarified, for instance:
Gambling is permitted only within entertainment complexes operated by licensed entities. The following types of casino operations are allowed:
Using gaming machines that employ mechanical, electrical, light-based, or any other form of energy, operated by touching, sliding, pressing, flicking, pulling, shooting, throwing, rocking, spinning, or any other method that can determine a winner and a loser, whether by counting points, using any kind of markers, or otherwise
Using devices that can determine a winner and a loser, whether by counting points or using any kind of markers, or otherwise.
And
Classification of online gambling (or “gaming”) activities into 8 categories:
Online Casino Games: All types of gambling found in traditional casinos, such as slots, roulette, and card games, but offered online
Day Trading: Buying and selling financial instruments like stocks and currencies within the same trading day, with the aim of profiting from short-term price fluctuations. It's considered a form of gambling due to the inherent risk and speculative nature of these transactions
Online Sports Betting: Wagering on the outcome of various sporting events, including international sports, local or traditional sports, and horse racing
Betting Exchanges: Online platforms where individuals can bet against each other on the outcome of real-world events, such as elections or award ceremonies
Online Bingo: Digital version of the classic bingo game, where players mark off numbers on virtual cards as they are randomly called out
Online Lotteries: Lotteries through online platforms, with the chance to win prizes based on the outcome of lottery draws, both within Thailand and internationally
Skill Gaming Sites: Online games that require skill and strategy, such as e-sports (competitive video gaming) and other online games where players compete against each other. The inclusion of this category suggests that competitive gaming where prizes or money are involved could be considered a form of gambling
Practice Sites: Online simulation of gambling environments where players can practice and hone their skills in various casino games without risking real money. These sites often use virtual currencies or tokens for betting. The text suggests these sites can serve as a gateway to online casinos once players gain confidence and experience
Business operators wishing to obtain a license must be incorporated in Thailand, have a minimum paid-up capital of THB 10,000 million (approx. USD 270 million), and participate in a bidding process. The validity of the license is still under debate but could range from 10-60 years.
For casino entry, Thai nationals must pay THB 1,000 - 2,000 (USD 30-60), with a maximum cap of THB 5,000 (USD 150). Additionally, it is recommended to introduce an annual membership fee which could be set between approximately THB 20,000 to 40,000 (approximately USD 667 to 1,333), and meet registration requirements, while ‘vulnerable populations’, including minors and individuals under court orders or family requests, will be excluded.
The above provisions are to be determined and finalised in the parliament over the coming months. The Finance Ministry aims to present the draft legislation to the Cabinet during the next parliamentary session on December 12, 2024. If the law passes its three readings, which could happen as early as April 2025, and casinos can thus be legalised in September 2025.
In line with Thailand's legislative efforts to legalise casinos, the Entertainment Complex Bill has garnered active engagement from the private sector. Omri Morgenshtern, CEO of Agoda, has expressed support for the initiative, emphasising that, if implemented correctly, it could substantially benefit the country’s tourism industry. He highlighted that a well-regulated approach could lead to a 10-15% increase in tourist arrivals. He asserts that such developments would enhance Thailand's tourism offerings by creating comprehensive experiences comparable to those in Macau and Las Vegas, featuring extravagant shows, diverse cuisine, and luxury accommodations.
Morgenshtern noted that casinos have the unique advantage of attracting visitors year-round, which could help mitigate the effects of seasonal tourism fluctuations. With Thailand targeting 40 million foreign arrivals and 3.4 trillion baht in tourism revenue, he believes that the inclusion of casinos could be instrumental in achieving these goals, provided global travel demand remains strong.
In addition to interest from global corporations such as Las Vegas Sands and Wynn Resorts, local Thai businesses are also aligning their strategies to participate in the development of large-scale entertainment complexes. This shift reflects a collective recognition of the potential economic benefits these projects could bring to Thailand's tourism and entertainment sectors. There are several prominent Thai businesses actively pursuing the development of entertainment complexes across the country including;
Royal Turf Club of Thailand (RTCT) - RTCT has announced plans for "The Royal Siam Haven," a THB 200 billion (approximately USD 6 billion) entertainment complex in Bangkok. The project will feature a horse racetrack, a six-star hotel, a golf course, a yacht club, luxury dining options, a theatre, a medical tourism hospital, and a learning centre. There will be a total of 6 Sports and Entertainment Complex projects located in 6 provinces throughout Thailand, namely: Bangkok in Lat Krabang district or Nong Chok district Phuket is divided into 2 areas; a private island and an area on the coast next to the sea mainly for VVIP members and guests of association only Kanchanaburi in Sai Yok district, next to the Kwai River Chiang Rai, Chiang Sean area Khao Yai for horse breeding and propagation farm, standard horse race track, hotel, and resort in Eastern Economic Corridor (EEC) project.
RS Group - Through its subsidiary, Andaman Entertainment, it is investing in a comprehensive entertainment complex in the Phuket–Phang Nga Province, with an initial registered capital of THB 100 million (approximately USD 2.9 million). The project aims to become a new landmark.
Siam Park City Group - The operator of Siam Amazing Park has proposed allocating approximately 800,000 square metres for an entertainment complex in Bangkok. Plans include hotels, casinos, dining destinations, sports areas, wellness resorts, grand arenas, and cultural centres.
U-Tapao International Aviation Company Limited - a joint venture, comprising Bangkok Airways Public Company Limited, BTS Group Holding Public Company Limited, and Sino-Thai Engineering and Construction Public Company Limited, is spearheading the "Airport City Project" as part of the Eastern Economic Corridor (EEC) initiative featuring a department store, duty-free shops, hotels, an exhibition centre, serviced apartments, a medical hub, and a Formula One racetrack.
The Mall Group - in discussions with international casino investors, including Las Vegas Sands, Wynn Macau, and Marina Bay Sands Group from Singapore.
Proud Group Company Limited - exploring investment opportunities in entertainment complex projects in Phuket and Phang Nga.
Impact Exhibition Management Company Limited - Managing real estate in the Muang Thong Thani area, the company advocates for this locale as a suitable site for an entertainment complex. The area boasts comprehensive facilities, including hotels, a shopping centre, and spaces for exhibitions and concerts, with future enhancements such as the Purple Line transit and expressway to further improve accessibility.
Royal Turf Club of Thailand (RTCT)’s vision for "The Royal Siam Haven" in Bangkok.
Our Two-Cents
The path to legalisation of casinos will not be smooth. The initiative to legalise casinos through the Entertainment Complex Bill faces challenges, compounded by political instability and internal divisions within the government. Inconsistent policies and shifting priorities further contribute to uncertainty surrounding the project's progression. While the draft bill has advanced to the parliamentary approval stage, the legislative process remains fraught with hurdles. These issues, combined with the broader unpredictability of the political landscape, cast substantial doubt on the feasibility and future of the proposed initiative.
Thailand's approach to regulating "entertainment" has been complex and sometimes contradictory. Alcohol sales, for example, are restricted at certain times, while cannabis, despite officially being for medical use only, is widely available. This context suggests that casinos will likely face resistance and regulatory hurdles reflecting public opinion. Successfully navigating these complexities will be vital for the long-term viability of the casino industry in Thailand's dynamic market.
Furthermore, it is noteworthy that despite the considerable interest expressed by various international operators, prominent domestic players in the hospitality and development sectors, including established names like Minor International, Dusit Thani, Central Group, and The Mall Group, have yet to publicly indicate any intention to participate in this market. This absence raises questions about their perspectives on the industry's potential and the challenges it may present.
To thrive, Thailand's nascent casino industry needs decisive government action: clear objectives, a commitment to responsible development, and a market-driven approach.
Take for example Macau's legislative approach to casinos which prioritises a market-driven model over strict government control. This framework emphasizes stability in areas such as taxation, regulations, and operational limitations. Crucially, it provides clear assurances to investors regarding the number of casino licences that will be issued, fostering a predictable and transparent business environment. This approach encourages investment and competition while maintaining responsible oversight of the industry.
Casino businesses are rational economic creatures. The challenge for Thailand lies in establishing a responsible gaming industry that learns from the successes and failures of other countries, balancing economic benefits with the well-being of its citizens.