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January 16, 2025

Thailand’s Cabinet Approves Principles of the Draft Entertainment Complex Act

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On January 13, 2025, Thailand’s cabinet approved in principle the draft Entertainment Complex Act, as proposed by the Ministry of Finance. This landmark legislative proposal, which would allow casinos as part of larger “entertainment complexes,” will now proceed through further parliamentary review and approval.

Key provisions of the draft act are described below.

  • Corporate structure: Entertainment complexes must be operated by Thai-registered limited companies or public limited companies with a minimum paid-up capital of THB 10 billion. Directors of the licensed entity must be individuals and have the qualifications and none of the prohibited characteristics specified in the draft act. The draft act does not impose restrictions on foreign-majority ownership structures; however, it is worth monitoring whether any amendments addressing this matter are introduced during the legislative process.
  • Operating conditions: Each entertainment complex must be located in an area designated under a royal decree. It must also include at least four types of entertainment businesses listed in the annex to the draft act (e.g., shopping mall, hotel, sports stadium, amusement park), along with a casino. The allocation of casino space must comply with regulations to be specified at a later date.
  • Licensing conditions: Licenses will be valid for 30 years, renewable in increments of up to 10 years. The license issuance fee is THB 5 billion, the annual fee is THB 1 billion, and the renewal fee is THB 5 billion. The Entertainment Complex Policy Committee, chaired by the prime minister, will review and approve applications.
  • Online gambling restrictions: Licensees are prohibited from offering gambling through internet-connected systems or electronic devices that allow access from outside the casino premises.
  • Labor requirements: Thai and foreign employee ratios must adhere to prescribed regulations.
  • Land privileges: Lease agreements for land use are limited to 50 years. Renewal is permitted for up to 49 additional years, starting from the end of the initial term.
  • Entry fee for Thai nationals: Thai nationals must register and pay a fee of THB 5,000 per visit to access casino facilities.

Legislative Process and Timeline

As this matter continues to be widely reported on in the press, it is worth keeping in mind the stages that the draft Entertainment Complex Act has left to go through:

  • Council of State review: The cabinet will submit the amended draft to the Council of State within the next few weeks.
  • Second cabinet review and approval: After review by the Council of State, if no further comments are made, the bill will be resubmitted to the cabinet for final approval—expected to occur possibly around late February or early March 2025.
  • House of Representatives deliberation: Once approved, the bill will proceed to the House of Representatives for a deliberation period that may last for up to 180 days. The deliberation period comprises three readings.
  • Senate review: After passage by the House of Representatives, the bill will be submitted to the Senate for three additional readings, which may take up to 60 days.
  • Royal assent: Upon Senate approval, the bill will be forwarded to the king for royal assent and published in the Government Gazette.

The exact timing of these stages may vary widely, but passage of the draft act likely will not be possible until at least the second half of 2025.

For more details on the draft Entertainment Complex Act, or on any aspect of gaming regulations in Thailand, please contact Tilleke & Gibbins at [email protected].

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