What the law actually requires of an operator.
The plan, its five mandatory elements, the annual filing date, and the fine attached to missing it — separated from the policy article they are commonly confused with.
1 ·Two articles, two duties
The single most common error in English-language accounts of Macau responsible gaming is to attribute the whole regime to Article 42-A. It is split, and the split matters, because the obligations that carry a sanction sit in the second article rather than the first.
Article 42-A restricts disclosure — gambling-related information or activities may be disclosed only within the games-of-fortune zones of casinos, and disclosure outside the Macao SAR must comply with the law of the place concerned. It then requires the concessionaire, before operating, to prepare a responsible gaming promotion plan and to review and improve it periodically.
Article 42-B says what the plan must contain, and requires it to be filed.
2 ·The five mandatory elements
Article 42-B(1) enumerates what the plan must include.
| Element | What it requires |
|---|---|
| Player information | Information for players on responsible gambling behaviour and on the problems of gambling dependence and addiction. |
| Keeping barred persons out | Measures ensuring that persons subject to an entry interdiction are in fact prevented from entering. |
| Exclusion information | Information about self-exclusion and third-party exclusion, and the means of applying for each. |
| A specialised responsible-gaming group | A dedicated group to provide assistance and counselling. This is a standing structure, not an ad-hoc response. |
| Employee training | Training for employees on responsible gaming. |
Two of these are structural rather than documentary. A specialised responsible-gaming group is a team that has to exist and be staffed. Employee training has to be delivered and, in practice, evidenced — because the plan's execution is reported annually.
3 ·The 31 December filing, and the fine
The only hard recurring date in the regime
Article 42-B(2): concessionaires must deliver to the DICJ, annually and by 31 December, a report on the execution of that year's responsible gaming plan and the plan for the following year. Article 48-C(1)(2) makes failure an administrative offence carrying MOP 100,000 to MOP 500,000.
Two documents, one deadline, a fixed penalty. It belongs on the compliance calendar, and the evidence behind it — training records, interaction logs, exclusion-list checks — has to be retrievable when the report is written, not reconstructed afterwards.
4 ·The concession review
Responsible gaming is not only a standing duty; it is also a factor in how a concessionaire is judged over time. Under Article 22, concessionaires are subject to a triennial review by the DICJ of general compliance with the concession contract, and the discharge of corporate-social-responsibility obligations is assessed within it. A programme that exists on paper but cannot be evidenced is a weak position to take into that review.
5 ·Sources
- 1.Responsible gaming policy — disclosure restriction and the duty to prepare a plan — Law 16/2001 as amended by Law 7/2022, Art. 42-A, BO 25/2022, 22 Jun 2022
- 2.Plan content — the five mandatory elements — Law 16/2001 as amended by Law 7/2022, Art. 42-B(1), BO 25/2022Player information · keeping barred persons out · exclusion information · specialised responsible-gaming group · employee training
- 3.Annual filing by 31 December — Law 16/2001 as amended by Law 7/2022, Art. 42-B(2), BO 25/2022Execution report for the year ending plus the following year's plan
- 4.Sanction for failure to file — Law 16/2001 as amended by Law 7/2022, Art. 48-C(1)(2), BO 25/2022Administrative fine MOP 100,000–500,000
- 5.Triennial review and CSR discharge — Law 16/2001 as amended by Law 7/2022, Art. 22(1)(11), BO 25/2022
- 6.Concessionaire duty of supervision — Law 10/2012, Art. 17, BO 35/2012, 27 Aug 2012
Interpretation and recommendations are Surveillance Intelligence Asia's own analysis.