Partially Regulated
The primary legislation governing gambling activities in Hong Kong is the Gambling Ordinance Cap 148 (Gambling Ordinance).

Under the Gambling Ordinance, all gambling activities are illegal except:

• Those expressly authorised by the government under the Betting Duty Ordinance (Cap 108) (i.e. authorised horse racing, authorised football betting and the Mark Six Lottery)
• Those licensed by the public officers appointed by the secretary for home affairs (e.g. tombolo, mahjong/tin kauparlours – some further information provided in the general licencing section)
• Those exempted under Section 3 of the Gambling Ordinance (e.g. social gambling).

There are a limited number of such licensed premises and the overall policy towards gambling in Hong Kong remains restrictive. Currently, the Hong Kong Jockey Club is the only racing club and legal bookmaker authorised by the government.

Other ordinances which regulate gambling or activities that may be regarded as gambling include:

• The Betting Duty Ordinance (Cap 108)
• The Chit-Fund Businesses (Prohibition) Ordinance (Cap 262)
• The Amusement Game Centres Ordinance (Cap 435)
• The Government Lotteries Ordinance (Cap 334)
• The Broadcasting Ordinance (Cap 562)

Market size
Hong Kong currently have a population of 7.4 million. From April to June 2022, the Census and Statistics Department reported that the median household income dropped to HKD 27,100, marking a 4.2% decrease from the previous quarter. The University of Hong Kong released a study in December 2022 on Hong Kong People’s Participation in Gambling Activities. The study found that amongst participants Mark Six Lottery was the most common form of gambling (73%), followed by social gambling (50.6%), and betting on Hong Kong Jockey Club (HKJC) horse racing (29.5%) and HKJC football (16.3%). Less than 1% reported online gambling and 0.5% reported participation in online casinos and online football betting, which are considered illegal gambling activity in Hong Kong.

Competitive landscape
The Hong Kong Jockey Club (HKJC) is the only racing club and legal bookmaker in the territory, so it has a monopoly. HKJC monopoly rights are specific to Hong Kong itself but in parallel it participates in an international pari-mutual betting scheme called the World Pool allowing it to offer pool betting on large horse racing events such as Ascot to an international pool of customers. HKJC is looking to further expand its World Pool offering for UK and Ireland races after generating HK$4.7bn ($600m/€566m/£490m) in turnover during 2023. The World Pool represents 17% of the total turnover on Hong Kong racing.

Localisation
With the proliferation of offshore betting sites, in particular for football betting, section 8 of the Gambling Ordinance was amended in 2002 to make it clear that it is an offence to bet in Hong Kong with an unauthorised bookmaker, regardless of whether the bookmaker is located in Hong Kong or offshore.

Notwithstanding this, the current legislative framework does not expressly regulate online (remote) gambling; hence, foreign operators providing remote gambling services do not need to obtain a licence from government. However, this does not make it legal for any user in Hong Kong to use foreign gambling services. A foreign operator may still commit an offence if they receive, negotiate or settle a bet placed from Hong Kong. There are no restrictions in the legislative framework on the media through which gambling can be provided (e.g. internet, mobile devices etc.).

Top Key Attractions and Challenges
Attractions

• There are licences available for some skilled games and lottery – more details in the product and licencing section.
• Hong Kong has an attractive corporate tax system – 8.25% for assessable profits under HKD 2M and 16.5% on the exceeding part.
• Foreign gambling contracts can be enforced through the Hong Kong courts as long as they are legal under the applicable governing legislation.
• Marketing activities for gambling and gambling related services are not prohibited in Hong Kong.

Challenges

• The market is limited, as Hong Kong Jockey Club is the only racing and legal bookmaker in the territory. Outside of this, most gambling activities are social gambling. More details of this is available in the product section.
• Given influence of China, it is likely that the market in Hong Kong will remain restrictive.