Small scale of industry compared to neighbors - Paraguay

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1) Bottom line: the Paraguayan market is smaller in terms of hardware and online capacity

If you look at the "tangible" metrics, Paraguay is noticeably inferior to its neighbors in terms of the number of sites and the fleet of equipment. According to the World Casino Directory, Paraguay has 19 licensed properties, ~ 1,965 slots and 68 gaming tables. In Argentina - 147 objects, ~ 29,372 slots and 1,259 tables; in Uruguay - 29 objects, ~ 3,520 slots and 211 tables. This clearly captures the smaller scale of Paraguay's infrastructure.

2) Online landscape: Paraguay still has a "narrow neck"

The online part of the market has long been held back by the admission architecture. In sports betting, there is a model of a national exclusive concession - holder DARUMA SAM (Apostala); the regulator directly confirms the exclusivity of the competition, and industry media indicate a prolongation until 2028. Even after the 2025 reforms, this design objectively limits the number of B2C players in the market.

For comparison, Argentina issued decentralized online licenses by province/city (LOTBA in Buenos Aires, etc.), which created a "wide" market of many operators and brands.

In Uruguay, online casinos are prohibited, and the only legal online product is Supermatch bets under the auspices of La Banca (state monopoly). This makes Uruguayan online similar in structure to Paraguay (narrow), but Uruguayan offline is compensated by tourist clusters like Punta del Este.

3) Tourism: fewer flows - lower and "non-game" revenue

The demand for casinos in the region is closely related to tourism. Paraguay received 2.2 million visitors in 2024 (including tourists and day visitors), which is less than the typical volume of neighbors with sea resorts.

Uruguay in the "high" season of 2025 reported about> 1.13 million tourists in the first months (summer peak), and Punta del Este traditionally accumulates a significant share of solvent traffic for casinos. Argentina remains a major magnet of the region in terms of inbound tourist flow, although the dynamics of 2024-2025 fluctuated due to exchange rate factors.

Conclusion: the smaller tourist base of Paraguay (without ocean resorts) is one of the important factors in the modest "stack" of casinos and the limited growth of gambling revenue.

4) Regulatory framework: there are reforms, but the effect is with a lag

In 2025, Paraguay carried out institutional reform: CONAJZAR was built into DNIT, its role was clarified (authorization of games, approval of regulations, sanctions), Decreto Nº 3846/2025 was published for the application of the updated law. This strengthens control and transparency, but the scale of the market is growing after the fact - as contests and investment cycles.

5) Where Paraguay is inferior in key parameters (summary)

Offline casino infrastructure: Fewer properties and hardware (slots/tables) than Argentina and even Uruguay.

Online competition: narrow - one concessionaire in sports betting; online casinos are only formalized by competitions after updating the law. Argentina is already multi-jurisdictional and competitive; Uruguay is a monopoly of online betting, but strong offline due to the tourist cluster.

Tourist funnel: without a "strong sea" and large-scale international hubs, traffic is lower - and this affects GGR.

6) What is changing and what niches Paraguay has

New tolerance architecture. The 2025 reform (law + decree) expands the CONAJZAR tools: approve new types of games/modalities, harden clandestino and administer canons through DNIT. This creates the basis for growth, but requires the launch of contests and investments.

Border cities as a "gateway" of traffic. Ciudad del Este, Pedro Juan Caballero and others can increase attendance (shopping + casinos), but this does not reach the scale of Uruguayan resorts.

The gambling industry of Paraguay in 2025 is objectively smaller than neighboring markets in terms of the number of sites, slots/tables and the width of online. The reasons are the historical model of admission (narrow in sports betting), more modest tourism and a smaller fleet of offline infrastructure. The 2025 reforms (CONAJZAR in DNIT and Decreto 3846/2025) aim to increase transparency and competition; there is growth potential, but it is realized through contests and projects, and not "on the click." Against the background of Argentina (large, fragmented and multi-license ecosystem) and Uruguay (narrow online, but strong tourist resorts), Paraguay remains a compact market where niche strategies (border clusters, hotel + casino, local entertainment) look the most realistic.

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