Market Reform Outlook (Uruguay)

Market Reform Outlook

1) Current baseline

Structure: controlled model with a strong role for the state; offline casinos and lottery/pool products operate in an understandable regulatory loop.

Online: field is limited; multi-license model for private. com-brands are poorly/pointwise developed.

Market: small in population and LTV, focused on classic games and football/horse racing bets.

Consequence: limited external competition, moderate pace of innovation, cautious approach to advertising and payments.

2) Drivers of change

Fiscal: search for stable budget revenues (licenses, GGR taxes, RG/sports/culture contributions).

Technological: the growth of mobile "micro sessions," live casinos and crash games; the need for a modern payment stack.

Consumer: Waiting for more content choices, quick payouts and personalization.

Tourism: synergy "casino-resort + sports/cultural events"; cross-channel monetization of guests.

Regulatory: control of gray online, unification of advertising rules, strengthening RG/AML.

3) Options for a reform model (from conservative to liberal)

Model A - Moderate Evolution

Pilots of online products under state/paragos operators; private partners - B2B.

Limited quotas for live casinos and instant games, mandatory RG limits.

Bets: resolution of part of the markets (pre-match/live) with clear limits on express/odds.

Pros: low risks, fast start of pilots, controllability.

Cons: Limited competition and slow revenue gains.

Model B - Controlled Multi-Licensing

3-6 target licenses (casino online, betting, live-dealer), priority to local JV.

Centralized register of self-excluded, uniform KYC/AML standards, advertising code.

Payment stack: cards/bank + 1-2 alternatives; crypto - strictly by AML screening.

Pros: increased investment, competition, UX/content; control is maintained.

Cons: implementation complexity, higher supervision requirements.

Model C - Wide Discovery

Free access for foreign operators when meeting the requirements for localization, taxes, payments and RG.

A wide range of content (live shows, virtual sports, fantasy/e-sports).

Pros: Maximum choice, fast GGR growth.

Cons: high risks of overheating advertising, pressure on local market players, complex regulation.

4) Taxes and fees: "the right fork"

License (entry): fix + annual fee (segment-specific).

GGR tax: benchmark 10-20% (balance of fiscal goals and investment attractiveness).

Earmarks: 1-2% on Responsible Gaming, sports/culture, prevention of gambling addiction.

Deductions: permissible bonuses/freebets - within the established ceiling, so as not to blur the base.

5) Advertising, sponsorship, affiliates

Unified advertising code: age restrictions, watershed hours, ban on "get rich quick."

Sports sponsorship: allowed under RG disclaimers; a ban on children's/youth teams.

Affiliates: registration and responsibility for creatives; CPA/RevShare transparency; Blacklist of violators.

Influencer marketing: only certified creators with audience verification (18 +).

6) Payments and compliance

KYC/AML by design: verification before the first significant conclusion; PEP/sanctions-screening.

Methods: bank/cards - by default; e-wallets/vouchers - subject to local rules; crypto - limited, with strict on-chain screening.

Threshold transactions: sources of funds for large amounts; Transaction logging reporting to providers.

Antifraud: 3-D Secure/biometrics, behavioral analytics, deposit/loss/time limits.

7) Responsible Play (RG)

Unified register of self-exclusion (inter-operator).

Mandatory tools: limits, reality-check, timeouts, player reports.

RTP/volatility labeling in the lobby; "clear bonus rules" (vager, max win, deadlines).

Independent hotline and financing of NGOs from targeted deductions.

8) Impact on tourism and offline segment

Resort clusters: hotel + casino + events co-brands, VIP/congress tourism packages.

Cross-channel: a single wallet/loyalty status offline ↔ online, QR links from the hall to the application.

Events: poker series, live show tournaments, integrations with football/tennis calendars.

9) Scenarios 2025-2030

Scenario	What's going on	Economy	Risks
Conservative	Pilots online, B2B partnerships, hard limits	Moderate growth, stable fees	Innovation Gap, Grey Online
Moderate and reformist	3-6 licenses, uniform RG/AML/advertising, sports sponsorship	Substantial GGR growth, new jobs, investment	Requires strong oversight and IT infrastructure
Liberal	Free access for. com at localization	Maximum offer, fast growth	Risk of overheating of advertising/social. behavioral costs

10) Implementation roadmap

Stage 0 - Preparation (0-6 months)

Impact assessment, draft tax model, license matrix, consultations with banks/financial regulator.

Draft advertising code and RG standards; selection of technical platforms (KYC, anti-fraud, monitoring).

Stage 1 - Pilots (6-12 months)

Limited number of operators/verticals; sandboxes for live/crash with a reduced rate limit.

Unified KPI reporting, AML/KYC stress test, payment audit.

Stage 2 - Scaling (12-24 months)

Launch of controlled multi-licensing; an inter-operator register of self-exclusion.

Prohibition of "dark" advertising, certification of affiliates, register of creators.

Step 3 - Optimization (24 + months)

Adjustment of taxes/quotas according to KPI; content expansion (e-sports/fantasy/virtual sports).

Integration of offline loyalty, development of tourist products and MICE segment.

11) KPI of the regulator and the market

Fiscal: license fees, GGR taxes, earmarks (RG/sports/culture).

Market: share of "white" online, ARPU/LTV, share of fast payments ≤ 24 hours.

Social: RG metrics (self-exclusions, average game time, share of responsible limits).

Compliance: share of verified accounts, AML incidents/sanctions, license revocation.

Tourism: hotel loading, VIP/package check, event frequency.

12) Risks and mitigation measures

Overheating ads → strict time windows, fines, limiting creativity.

Laundering/fraud → on-chain screening for crypto, 3-D Secure, behavioral analytics.

Social costs → NPO financing, access to therapy/consultations, mandatory RG tools.

Pressure on local operators → JV priority, content quotas, transition periods.

IT failures/cyber risks → platform certification, bug bounty, redundancy and audit.

13) Comparison with neighbours (lessons for Uruguay)

Argentina: regional licenses → competition and tax base; but uniform RG standards are needed.

Brazil: scale and aggressive opening of betting → rapid growth; it is important to prevent the promo from overheating.

Chile: phased reform with public consultations; a useful template for the road map.

On the horizon 2025-2030, the most viable scenario for controlled multi-licensing: a limited number of licenses, uniform requirements for RG/AML/advertising, a transparent tax on GGR and the priority of local JVs. This approach increases investment attractiveness, expands choice for players and strengthens the budget - while maintaining manageability and social responsibility.