1. From Regulation to Revenue: An Introduction to Games of Chance Regulation
The games of chance industry in Serbia is undergoing significant changes, making the understanding of fundamental terms and key legal principles indispensable for every organizer. From defining games of chance and understanding social responsibility to the introduction of new legal frameworks, every aspect of regulation has a direct and lasting impact on business operations.
This guide is designed to provide a clear and comprehensive overview: from the fundamental terms and principles shaping the industry of games of chance, through the central role of social responsibility, to an in-depth analysis of the legal changes that set new rules for the game.
For business owners, this text is more than an insight into regulations – it is a strategic tool for understanding changes, adapting to new requirements, and identifying growth opportunities in an increasingly complex business environment.
2. Key Overview of Regulation: How Does the Law Define Success in the Gaming Industry?
Before entering the world of games of chance, it is essential to understand fundamental legal terms. That is why we have prepared a pocket dictionary of the Law on Games of Chance (the “Law”) to help you peek behind the scenes of this industry and see how luck and law go hand in hand!
Games of Chance
Games where participants pay to have the chance to win the prize – whether in money, goods, services, or rights. The outcome depends solely on luck or uncertain circumstances, with no influence from the players’ knowledge or skills.
Explore the various types of games of chance and their distinctive features below:
I. Classic Games of Chance
Games that involve a larger number of participants, all aiming to be the sole or joint winners of a pre-defined fund of winnings.
Classic games of chance include:
1. Basic Classic Games of Chance – lottery, instant lottery, and other lottery-based games, sports forecast betting, lotto, keno, and similar games, bingo, tombola and other similar tombola-based games.
Example: participating in a lotto game where players select numbers hoping for a match during the draw.
2. Other Classic Games of Chance – SMS lotteries, fonto, and other games of chance listed in the official catalog of games of chance.
Example: taking part in an SMS lottery where sending a message to a designated number gives a chance to win a prize.
II. Special Games of Chance
Games in which participants play against each other, or against the organizer, in order to win a prize dependent on the stakes.
Special games of chance include:
1. Games of chance organized in casinos
Games where players play against the house, or against one another, using gaming tables with small balls, small dice, cards, or similar props, which are organized exclusively in the area of the casino.
Example: playing poker in a casino where players compete with each other using cards.
2. Games of chances organized on automatic equipment
Games played on automatic equipment, in which players by paying a certain amount acquire the ability to obtain wins depending on the game rules.
Example: playing on automatic equipment in a slot machine club, inserting coins, pulling a lever, and hoping for a winning combination.
3. Games of chance involving betting
Games where participants bet on the outcomes of sports events, real life, or virtual events proposed by the organizer. The circumstances determining the outcome must not be known in advance to anyone, and independent of any influence by players or organizers. The amount of winning is determined at the time of paying for the stake and cannot be modified later.
Example: betting on Real Madrid to defeat Barcelona in El Clásico, with predefined odds and potential winnings.
III. Prize Games in Goods and Services
Organized by legal entities or entrepreneurs for advertising and other purposes, where participants have an equal chance to win pre-determined prizes by purchasing certain products or goods owned by the organizer or by using the services or conveniences of the organizer.
Example: Entering a supermarket prize game where customers receive a chance to win household appliances for purchases above a certain amount.
Skill-Based Games
These games’ outcomes depend solely on participants’ knowledge, skills, or abilities. They are conducted publicly under clear rules with direct participation by qualified contestants and overseen by a commission appointed by the organizer. Skill-based games are not considered games of chance.
Example: television quizzes such as “Who Wants to Be a Millionaire,” chess competitions, or esports tournaments, where participants rely on their knowledge and strategy to win.
Entertainment Games
Games played on computers, simulators, video game machines, pinball machines, or other similar devices that are coin or token-operated, as well as billiards, darts and other similar games. Players pay to participate, but winnings consist of additional free plays of games of the same type rather than monetary prizes or goods. These games are not governed by the Law.
Example: playing pinball in a gaming arcade, where high scores earn free rounds.
Objectives of Organizing Games of Chance and Distribution of Funds
Games of chance are organized with a threefold objective:
- entertaining participants,
- providing opportunities for winnings,
- generating revenue for the budget of the Republic of Serbia.
A portion of the funds, constituting 40% of the revenue for the budget of the Republic of Serbia, represents a significant source of financing for various social and humanitarian activities. These funds are utilized, among other purposes, to support the Red Cross of Serbia, the development of sports and youth programs, assistance to organizations for persons with disabilities, the improvement of social welfare institutions, and the implementation of other projects of social and national importance.
Example: imagine revenue from the national lottery financing the renovation of a sports center in your town, offering modern facilities for youth sports while simultaneously funding meal programs for senior citizens in socially vulnerable areas. In this way, money invested in games of chance directly benefits the community through visible and impactful projects.
Catalogue of Games of Chance and Rules
Games of chance may only be organized if they are listed in the official catalog of games of chance and have established rules in compliance with the Law. The Games of Chance Administration (the “Administration”) drafts the catalog, while the Ministry of Finance of the Republic of Serbia (the “Ministry”) decides whether a specific game qualifies as a game of chance.
Organizer of the Games of Chance
An organizer is a legal entity or entrepreneur authorized under the Law to organize games of chance based on a license, approval, or consent from the relevant authority.
Games of Chance Administration
The Administration, as part of the Ministry, oversees state administration tasks related to games of chance across the country.
The Administration has the following tasks:
Organizing Games of Chance and Transferring Rights
The organization of games of chance is the exclusive right of the Republic of Serbia unless otherwise stipulated by the Law. This means that the state maintains primary control over the organization of these games but does not assume the obligation to guarantee participants’ winnings.
However, the Republic of Serbia may transfer its right to legal entities or entrepreneurs with registered address in Serbia, strictly in accordance with the Law. The transfer of rights is carried out through licenses, approvals, or consents from the competent authority. It is important to note that licenses and consents are distinct -the difference between them plays a critical role and is often misunderstood (for a detailed overview, refer to the table below).
It is crucial to emphasize that transferred rights cannot be freely transferred further unless provided for by the Law. Any attempt to dispose of these rights contrary to legal provisions is considered null and void.
Games of Chance by Means of Electronic Communication
This category includes all classic and special games of chance conducted through the Internet, telephone, television, radio, SMS, and other forms of electronic communication.
3. Player and Business Protection: How to Ensure Responsibility in Gaming?
The games of chance industry represent a complex sector requiring strict standards of responsibility to maintain social responsibility and ensure the protection of all participants. Organizing games of chance must align with legislation that not only safeguards players’ rights but also ensures industry stability and growth. The Republic of Serbia, as the regulator, undertakes numerous measures to guarantee responsibility in games of chance and protect the key interests of players and organizers.
4. Significant Changes Ahead: What Does the New Law on Games of Chance Bring to the Organizers and Participants?
The Law on Amendments and Supplements to the Law on Games of Chance, adopted in November 2024 following intense negotiations and objections, entered into force on 6 December 2024, with its implementation commencing on 6 January 2025. This law introduces significant changes and additions to the existing legal framework, stemming from years of practice analysis and the need to enhance regulation within this industry. The objective of the new law is not only to modernize the games of chance sector but also to introduce stricter control mechanisms, increased obligations for organizers, and additional responsibility instruments. Furthermore, the new law incorporates new prohibitions that strengthen the responsibility of organizers while contributing to greater transparency and professionalization of this industry.
Among the most significant innovations of the law are newly introduced concepts, which for the first time provide clearer legal regulation and greater legal certainty in this area. For example, rules concerning the transfer of rights to organize games of chance in the event of status changes are now clearly defined. Particular attention is drawn to the regulation of tournament organization, which, for the first time, includes detailed rules for organizers of special games of chance in casinos.
Additionally, the law introduces a range of entirely new definitions that modernize and clarify the legal framework for games of chance. For the first time, terms such as “cash machine,” “bonus,” “multi-slot machine,” “ticket,” “player verification,” “jackpot,” “self-exclusion,” “tournament,” and others are clearly defined.
These are just some of the numerous changes introduced by the new law. Below, we present the most important amendments that every organizer must take into account to align their operations with the new regulations.
1) Display of Posters on Addiction Prevention
Organizers of Games of chance are required to display posters on addiction prevention not only inside the premises where games of chance are organized but also on the exterior of the premises.
2) Significant Fee Increases
One of the most important changes introduced by the new law concerns the increase in fees related to the organization of games of chance. These increases, which demand additional financial resources, represent a significant challenge for organizers and were the subject of intense negotiations during the law’s adoption.
Below is a table presenting examples of increased fees, providing a clearer overview of the specific changes. For more detailed and comprehensive information regarding all fee amendments, we refer you to the text of the Law on Amendments and Supplements to the Law on Games of Chance.
3) Real-Time Video Surveillance
Organizers of special games of chance in casinos, on automatic equipment, and betting are required to provide the Administration with a link through which authorized representatives of the Administration can monitor video surveillance in real-time, i.e. live.
For organizers of special games of chance conducted via electronic communication means, it is mandatory to provide the Administration with access to their databases or a mirrored database with replication data (Mirror Server), which is located within the territory of the Republic of Serbia.
It is also important to note that the legally prescribed retention period for video recordings has been extended.
This obligation is closely linked to another regulation – the Law on Personal Data Protection – and when implementing video surveillance, special care must be taken to ensure the protection of the personal data of individuals being recorded.
4) Prohibition of Serving and Consuming Food and Alcoholic Beverages
In premises where special games of chance on automatic equipment and special games of chance involving betting are organized, the serving or consumption of food and alcoholic beverages containing more than 5% alcohol by volume, as defined by the law regulating excise duties, is prohibited.
Additionally, it is stipulated that the aforementioned premises for organizing special games of chance must not have direct access to areas where food or alcoholic beverages exceeding the specified alcohol percentage are served.
To ensure transparency and compliance with these rules, organizers are required to display a notice in a visible location within the premises where the special games of chance are organized, indicating the prohibition on serving and consuming food and alcoholic beverages.
In case of non-compliance with these provisions, a monetary fine ranging from RSD 100,000 to RSD 2,000,000 is prescribed.
5) Self-Exclusion and Self-Limitation for Players
The newly introduced institute represents a responsible gaming provision, allowing players to voluntarily exclude or limit their access to activities related to participation in special games of chance organized via electronic communication means.
Organizers of special games of chance conducted through electronic communication means are obligated to provide players with the option of self-exclusion or self-limitation and to comply with such requests (by disabling access to the user account or limiting deposits in accordance with the request). Additionally, organizers must electronically submit data on these players and details of their requests to the Administration. Failure to comply with the legal provisions regarding this measure carries a fine ranging from RSD 100,000 to RSD 2,000,000.
6) Player Age Verification
To protect minors and strictly enforce the prohibition of their participation in games of chance, the new law introduces an obligation for organizers of special games of chance conducted via electronic communication means to implement rigorous age verification measures for players.
During the registration of an account of record – a unique account that the organizer opens and maintains for each player, containing all relevant transaction data – verification of the player’s age is mandatory. This procedure is carried out by verifying the date of birth from the player’s identification document, using electronic communication means.
7) Capital Structure Changes
Are you considering the purchase of shares or stakes in organizers of special games of chance on automatic equipment, via betting, or special games of chance via electronic communication means? Or perhaps you plan to join as a new shareholder or stakeholder in such entities? Pause for a moment and take note of the new legal obligations.
Under the new law, every such step requires prior approval from the Administration. To obtain this approval, it is mandatory to submit an application along with the required documentation, exclusively in electronic form through the Administration’s information and communication system.
Failing to comply with this obligation could be costly – the new law prescribes strict penalties for organizers who allow changes to the ownership structure without the Administration’s approval. Fines range from RSD 100,000 to as much as RSD 2,000,000.
5. New Rules, New Horizons: The Future of the Games of Chance Industry in Serbia
The new Law on Games of Chance is not merely a legal framework – it is a strategic challenge for organizers. Success in this evolving regulatory environment will depend on organizers’ ability to thoroughly understand the new institutes and rules and to implement them consistently and effectively in practice.
These changes require not only adaptation but also strategic thinking about the future direction of business operations. Those who approach these changes responsibly, systematically, and with professional support will have the opportunity not only to ensure compliance but also to lay the foundations for long-term sustainability and competitive advantage in an industry undergoing significant transformation.
The future of the games of chance industry in Serbia lies in the hands of those who recognize the importance of innovation, responsibility, and adaptability. Are you ready to rise to the challenge?
