Legalization of online games - El Salvador

Article text

Brief summary

The regulatory vector of online games in El Salvador looks evolutionary: the role of the National Charity Lottery (LNB) is increasing, it is publicly visible as a "showcase" of state games and a point of coordination, while there are discrepancies in open sources: some industrial directories already interpret online games as fully allowed under the auspices of the LNB, others - write about the ongoing design of the regime. Conclusion: the market is moving towards formalization, but it is reasonable for operators to prepare for step-by-step legalization with a focus on KYC/AML, reporting and responsible play.

What is already there (supporting facts)

LNB as an institutional center. Official communications and LNB activity (circulations, social projects, news) confirm its role in the state segment and the electronization of products.

Growth in LNB financials. According to Diario El Mundo (August 26, 2025), LNB revenues grew from $18.8 million to $61.3 million, which indirectly indicates the expansion of the product line and distribution channels.

Regulatory signals. Back in 2021, the Ministry of Finance issued an initiative on a new LNB law with direct permission for sports betting, online games and an electronic lottery; part of the industry maps 2024-2025. already describes models where LNB is the regulator of the online segment.

Payment environment after Bitcoin law reform. In 2025, a package of amendments was adopted: the adoption of BTC became voluntary, taxes - only in USD. This reduces regulatory uncertainty for operator payment scenarios.

💡 Why do sources diverge? Some of the publications are consulting/overview, some are news about draft norms. Before the advent of a single consolidated "code" of online games, interpretations differ, which is typical for markets at the setup stage.

Legal framework: where we will come logically

The basic "umbrella" is Ley de Juegos/organic LNB norms. The historical law on games and organic powers of the LNB is the basis on which you can build by-laws for online products (licensing, reporting, advertising, RGP).

Who will be the regulator? In practice - LNB (as a "single window") in coordination with the Ministry of Finance/financial intelligence on AML. Several industry maps already reflect this configuration.

Payments. After the reforms of the Bitcoin law, an emphasis on cards/e-wallet is expected, with optional support for crypto channels (with enhanced AML and source of funds).

Scenarios for the legalization of online gambling (2025-2030)

1. Status Quo + (Step-by-Step Electronization) - Likely Base Case

LNB expands electronic lotteries/bets under its own auspices, partner operators are allowed for model permits/sub-licenses. Clear requirements for KYC/AML and RGP, cautious advertising mode.

2. Limited multi-operator model

A limited number of licenses are opened with quarterly/annual reports, technical certification and centralized audits of RNG/payment flows in LNB. Probably - a separate scale of payments/deductions for social programs. (Logic of industry consensus and regulatory maps of the region.)

3. Full competitive market

Wide issuance of licenses (casino online, sportsbook, live games) with strict capital requirements/responsible advertising and an inter-operator register of self-exclusion. A scenario is possible but will require more institutional resources and time.

What it means for stakeholders

State/LNB

Unified register of licenses and procedure card (technical requirements, certification, log storage, reporting, data protection).

Advertising code: time/audience restrictions, prohibition of images of minors/religious symbols, mandatory warnings.

RGP standard: deposit/time limits, self-exclusion, reality check, inter-operator register.

Compatibility with payment compliance (banks/PSP), including crypto channels with enhanced AML.

Operators and providers

Readiness for KYC/AML-by-design, decision log and SAR/STR procedures.

RNG/platform (laboratory) certification, secure hosting, anti-fraud.

Bilingual support (ES/EN), RGP UX tools "default."

Payment portfolio: cards + e-wallet + optional PTS/stablecoins with an explicit "source of funds" policy.

Players

Transparent rules, visible odds/wagers, quick takeaways, 2FA.

Clear complaint/mediation channels and access to transaction history.

Possible License Preparation Checklist (Business)

1. Legal matrix. Describe target products (casino, sportsbook, live), LNB partnership model, data and logs.

2. Technical circuit. RNG/platform certification, storage of event logs ≥ 5 years, incident reports.

3. KYC/AML. Risk scoring, thresholds for manual checks, verification of the source of funds, sanctions/PEP screenings.

4. RGP. Default limits, 2-click self-exclusion, session timer, quiet sound/animation.

5. Payments. Maps/e-wallet, transparent commissions; for crypto - separate accounting on-chain/Lightning, test conclusions.

6. Advertising. Politics without "promises of fortune," without teenage/religious imagery, frequency limits.

7. Reporting. Quarterly KPIs: GGR/payments/RGP metrics/complaints, independent audit.

Risks and bottlenecks

Source discrepancies: some of the maps claim that "online is already completely legal," while law enforcement detail is still being drawn up; it is important to check the current regulations and license conditions.

Payment requirements after BTC law reforms: USD mandatory for taxes, BTC voluntary - billing and accounting settings.

Compliance costs: KYC/AML, certification, log storage - increase the cost of entry, but are critical for trust.

Risk of "gray" operators: VPN access, lack of local permitting practices → disputes and reputational losses.

Forecast to 2030

Base case: gradual expansion of electronic products and point licenses under the LNB umbrella; hard RGP/AML, careful advertising.

Optimistic scenario: a formal multi-operator model with a transparent register and regular statistics, an increase in the share of online in the gross revenue of the sector.

Conservative scenario: preservation of the status quo with the dominance of state products and limited integration of private operators.

FAQ (short)

Are online games already "legal"?

Depends on the interpretation of sources: a number of maps describe the regime as operating under the LNB, but specific licensing conditions and by-laws at the time of entry are important for business. Check the current rate/register.

Who will be the regulator?

With a high probability - LNB (in coordination with the Ministry of Finance/Financial Intelligence), which is already reflected in industry reviews.

BTC can be taken?

After the 2025 reforms, the adoption of BTC is voluntary; taxes - in USD. The decision on crypto channels is up to the operator/his bank, subject to AML.

Online gambling in El Salvador is moving towards a formalized model under the auspices of the LNB. The payment environment has become more predictable after the reforms of the Bitcoin law, and the institutional "build point" is already obvious. Businesses should prepare for phased legalization: KYC/AML-by-design, certification, strict RGP and transparent advertising. It is these "bricks" that will ensure quick market access as soon as the final rules and the register of licenses become public and stable.