Gambling Contracts Are Now Enforceable in the UAE: What the 1 June 2026 Law Change Means

Last updated: 24 July 2026

On 1 June 2026, the UAE replaced its entire civil code. Buried in that overhaul is a change with direct consequences for gaming: the old rule that made every gambling agreement legally void has been deleted, not replaced. For the first time, a bet placed with a licensed UAE operator sits inside ordinary contract law rather than outside it. The criminal ban on unlicensed gambling, however, has not moved.

Key takeaways

• Federal Decree-Law No. 25 of 2025, issued on 30 December 2025, took effect on 1 June 2026 and replaced the 1985 Civil Code in its entirety.
• Articles 1012 to 1021 of the old code, which declared gambling and betting agreements void and let losers reclaim their money, were not carried forward.
• Gaming contracts with GCGRA-licensed operators are no longer automatically void; they are now governed by ordinary contract principles and the regulator's own framework.
• The Penal Code's prohibition on gambling outside the licensed system is unchanged. Unlicensed gaming remains a crime, not a contract dispute.
• No court has yet tested the new position, so some practical questions remain open.

What exactly changed on 1 June 2026

The UAE issued a new Civil Transactions Law as Federal Decree-Law No. 25 of 2025 on 30 December 2025, and it entered into force on 1 June 2026. This was not a patch or an amendment. As Squire Patton Boggs put it in a client update, the law is a "wholesale legislative re-codification" that replaces the 1985 Civil Code in full rather than amending it selectively.

The new code modernises contract rules across the board — a lower age of majority, pre-contractual disclosure duties, framework agreements — but most of that has nothing to do with gaming. The gaming relevance sits in what the drafters left out.

What the old law said about gambling

The 1985 code contained a dedicated run of articles, 1012 to 1021, dealing specifically with gambling and betting. Their effect was blunt: any agreement relating to gambling or prohibited betting was void. A casino debt, a wager, a promise to pay winnings — none of it could be enforced in a UAE court. The code went further and allowed a loser to reclaim what they had paid within a specified period, a rule that turned every gambling loss into a potential claim.

That civil rule sat alongside the criminal ban, making gambling both illegal to conduct and unenforceable as a private deal. When the General Commercial Gaming Regulatory Authority (GCGRA) was created in September 2023 and began issuing licences, the criminal side was addressed through licensing, but the civil code's void rule remained on the books — an awkward fit for a country running licensed lotteries and online gaming.

Why the gambling chapter disappeared

The new code simply omits Articles 1012 to 1021. They were not reworded, moved or replaced elsewhere in the civil law. Charles Russell Speechlys, analysing the law on 28 January 2026, describes the omission as "consistent with a policy of removing duplication in favour of specialized frameworks". Squire Patton Boggs makes the same point from the other direction: matters now governed by specialised laws are deliberately excluded from the Civil Code to reinforce statutory coherence.

In plain terms, the UAE has decided that gaming is a regulated industry with its own rulebook — GCGRA licences, conditions and technical standards — and that the civil code no longer needs a catch-all chapter voiding gaming contracts by default. A Greenberg Traurig alert, reported by iGamingToday on 21 January 2026, was the first widely cited analysis to flag the deletion.

What this means for players

If you play with a licensed operator — The UAE Lottery run by The Game LLC, or the internet gaming and sports wagering platforms run by Coin Technology Projects LLC, the only company on the GCGRA register for those categories — your position changed on 1 June 2026 in a quiet but real way.

Your relationship with the operator is a contract like any other. The platform's terms, its payout obligations and your obligations under those terms can now, in principle, be enforced in a UAE court. Before June, a licensed operator refusing to pay a valid win could have pointed at the civil code and argued the entire agreement was void; that argument no longer exists. Licensed operators also gain certainty the other way: payment obligations and agreed terms are enforceable against players too.

The honest caveat is that this is new ground. No reported court decision has yet tested how UAE judges will handle a licensed gaming dispute under the new code, and licence conditions and the GCGRA's own dispute channels remain the first port of call in practice.

What has not changed

The criminal law is untouched. Federal Decree-Law No. 31 of 2021, the Crimes and Penalties Law, still defines gambling and punishes participation with up to two years' imprisonment or a fine of up to AED 50,000. The GCGRA is blunt about the boundary: commercial gaming conducted without one of its licences is illegal, and consumers using unlicensed sites may face penalties.

So the June change does not legalise anything that was illegal before. It does not make your account with an offshore casino enforceable — dealing with an unlicensed operator remains a criminal matter, not a contractual one, and the old civil safety net for losers is gone too. If anything, the gap between licensed and unlicensed play is now sharper: one side has contracts, courts and a regulator; the other has none of the three.

What is still unknown

Two questions remain open as of July 2026. First, the courts: how judges will treat licensed gaming disputes, and whether the deletion has any effect on legacy claims from before 1 June 2026, is untested. Second, further tidying: analysts who flagged the change expect more federal laws to be adjusted as the GCGRA's framework settles, so the statute book around gaming may not be finished moving.

FAQ

Are gambling debts now enforceable in the UAE? Debts under contracts with GCGRA-licensed operators are no longer automatically void, so ordinary contract enforcement applies in principle. Debts to unlicensed operators remain outside the law entirely.

Did the UAE legalise gambling on 1 June 2026? No. The Penal Code ban on gambling is unchanged. Only gaming run under a GCGRA licence is lawful, exactly as it was before June. What changed is the civil status of licensed gaming contracts.

What were Articles 1012 to 1021? The old Civil Code's gambling chapter. It declared gambling and betting agreements void and allowed a loser to reclaim money paid. The new Civil Transactions Law omits the chapter entirely.

Can I sue a licensed operator for unpaid winnings now? The old civil-code argument that the whole agreement was void no longer exists, so contractual claims are possible in principle. No court case has tested this yet, and GCGRA complaint channels come first in practice.

Can I still reclaim losses from a gambling site? The old code's reclamation rule was deleted with the rest of the chapter. For licensed play, losses are governed by contract; for unlicensed play, you were never protected and now have even less to stand on.

Does this apply to all seven emirates? Yes. The Civil Transactions Law is federal legislation, and the GCGRA is the sole federal gaming regulator. There are no emirate-level gaming regulators.

Further reading

• What is legal in UAE gaming right now
• Is online gambling legal in the UAE right now?
• GCGRA licence types: five categories, April 2026
• UAE gaming licence tracker 2026
• Illegal gaming risks in the UAE
• How to spot unlicensed gaming offers in the UAE

Sources

• Squire Patton Boggs, "Client Update on the New Civil Law in the UAE": https://www.squirepattonboggs.com/insights/publications/client-update-on-the-new-civil-law-in-the-uae-federal-decree-law-no25-of-2025/
• Charles Russell Speechlys, "United Arab Emirates issues a new Civil Transactions law": https://www.charlesrussellspeechlys.com/en/insights/quick-reads/102mefg-united-arab-emirates-issues-a-new-civil-transactions-law/
• iGamingToday, "UAE's new civil code quietly deletes the old gambling section ahead of June 2026 start date": https://www.igamingtoday.com/uaes-new-civil-code-quietly-deletes-the-old-gambling-section-ahead-of-june-2026-start-date/
• SiGMA, "UAE silently removes gambling and betting from new civil law": https://sigma.world/news/uae-removes-gambling-betting-new-civil-law/
• Mondaq, "UAE Commercial Gaming Law: GCGRA Licences, Online Gaming, Sports Wagering And Lotteries": https://www.mondaq.com/gaming/1729372/uae-commercial-gaming-law-gcgra-licences-online-gaming-sports-wagering-and-lotteries
• BSA Law, "UAE Enacts a New Civil Transactions Law (Federal Decree-Law No. 25 of 2025): Key Highlights": https://bsalaw.com/insight/uae-enacts-a-new-civil-transactions-law-federal-decree-law-no-25-of-2025-key-highlights/
• GCGRA, official site: https://www.gcgra.gov.ae/