Timor-Leste Online Gaming Licence 2026: Revoked by Resolution 54/2025, 2016 Decree-Law Still in Force

Where Timor-Leste stands, by date

Timor-Leste had an online gaming licence for less than six months. The record is short enough to fit in one table.

Date	Instrument or source	Effect
20 April 2016	Decree-Law No. 6/2016, Jornal da República Série I N.º 15	Gaming law in force. Lists “jogos virtuais” among social games, caps concessions at two, revokes Decree-Law 6/2009 (art. 74)
11 April 2025	Announcement by Golden River Universe Lda, carried by the state news agency TATOLI	First offshore gaming concession, signed by the Vice Prime Minister and Coordinating Minister for Economic Affairs, supervised by the IGJ
1 October 2025	Council of Ministers	Approves Government Resolution No. 54/2025
2 October 2025	Jornal da República Série I N.º 40 A	Resolution 54/2025 published in Portuguese, Tetum and English
3 October 2025	Point 6 of the resolution	In force, the day after publication
22 October 2026	Government website, our search	No Council of Ministers approval of a new gaming law found

The concession lasted 173 days from the announcement to the cabinet decision. The prohibition has now lasted 386 days. The April 2025 concession is known from the company’s own announcement. We searched the 20 Série I issues of the Jornal da República from April 2025 that we could retrieve and found no published instrument for it. That says what we could find, not what exists.

What Resolution 54/2025 says, point by point

The resolution runs to one page in each language. Its preamble says the 2016 Decree-Law does not reflect the realities of online gaming and betting, that the risks of crime, social instability and exploitation of vulnerable people outweigh the economic benefit, that the reputational cost deters investment and tourism, and that the licensing and contract-monitoring bodies lack the means to control online gaming systems. It calls the 2016 framework one that “has not kept pace with the rapid technological developments”, and it cites articles 15 and 58(d) of Decree-Law 6/2016 on deficient operation of gaming. The Council of Ministers communiqué of 1 October 2025 adds the headline grounds: risks to security, social stability, economic integrity and international reputation.

The operative part, adopted under art. 115(1)(o) of the Constitution:

1. Revokes the concessions, licences and authorisations granted for online gaming and betting, with immediate effect.
2. Cancels the procedures for granting them that were under way.
3. Orders that no new concessions, licences or authorisations for online gaming and betting be granted.
4. Tells the supervising ministry and the security forces to enforce these measures.
5. Orders a review of the gaming legislation, “namely” Decree-Law 6/2016 of 20 April.
6. Enters into force the day after publication.

Two details matter for anyone reading it as temporary. The resolution has no end date. Resolution 53/2025, printed on the same gazette page and setting up a crisis-management office, does: it lapses at midnight on 6 January 2026. The cabinet put a sunset on one measure and not on the other. And point 3 is worded as a prohibition, not a pause, so it lasts until something of equal or higher rank replaces it.

The law under review is 6/2016, not 6/2009

Some licensing pages still describe the review as concerning Decree-Law 6/2009 of 15 January. That decree is not in force. Article 74 of Decree-Law 6/2016 reads, in full, “É revogado o Decreto-Lei nº. 6/2009, de 15 de janeiro.” Resolution 54/2025 names 6/2016 twice: in the preamble and in point 5.

The difference is practical. Any amendment the government drafts will amend the 2016 text, so the 2016 numbers below are the baseline a reopened regime would start from, or depart from on the record.

What Decree-Law 6/2016 already sets

The 2016 Decree-Law was written for lotteries, bingo, gaming machines and traditional games such as cockfighting. It does mention virtual games. Read as an online operator would, it says this:

Topic	Rule	Article
Scope	Social and entertainment games include “concursos e jogos virtuais”	3(1)(a)
Casinos	Excluded from the Decree-Law	3(3)
Games by technology	Games and draws via mobile or other communication services need IGJ authorisation and a fee fixed by ministerial dispatch	13(3)
Supervisor	Minister responsible for tourism; inspection through the IGJ	6, 7
Who may apply	Legally constituted and domiciled in Timor-Leste, fit and proper, with technical and financial capacity	10, 11
Monopoly and cap	Social games reserved to the State; at most two concessions nationwide	17(1)-(2)
How a concession is awarded	Public tender chaired by the Inspector-General; or, exceptionally, by the Minister without tender for a proposal of “eminent national interest”, with the obligations published in a ministerial diploma	17(3)-(4)
Capital	USD 400,000 minimum share capital and a USD 250,000 permanent bank balance	22(1)
Bond	At least USD 400,000, by deposit in a Dili bank or first-demand guarantee	25(2)(a), 26
Award fee	10% of the bond, so USD 40,000 at the minimum bond	30
Term	Authorisations up to five years unless granted by concession contract; never more than fifteen	14
Revenue split	10% tax on gaming prizes; 15% social contribution on the concessionaire’s net revenue, 25% for slot machines	51(1)
Revocation	Includes deficient operation of the activity	15(3)(c), 58

None of these figures was written with remote gaming in mind, and the resolution itself says the framework did not keep pace. They are still the law. A new decree-law could rewrite every row. Until one is published, an operator weighing a Timor-Leste reopening should assume the two-concession cap, local domicile and the USD 400,000 bond, not the open multi-licensee model that offshore marketing implied.

Penalties for operating without authorisation

Running or playing a game without authorisation is a contravention under art. 61(a). Fines run from USD 1,000 to USD 20,000 (art. 63(1)), with seizure of equipment and funds, suspension and, for unauthorised operation, permanent closure as accessory sanctions (art. 64). The fine rises by one third when minors under 16 are found where the game is run (art. 66), which lifts the ceiling to USD 26,666.67. A voluntary payment is 25% of the maximum, so USD 5,000 for the art. 61(a) band (art. 69(3)). The Inspector-General decides the case (art. 59(2)), and criminal liability is separate (art. 60).

These amounts are small next to the bond. The exposure that matters more is point 4 of the resolution, which brings the security forces into enforcement, and the payment and banking consequences of holding a licence that no longer exists.

What would have to happen before licensing reopens

On the published record, three things, in this order:

1. A new or amended decree-law in the Jornal da República, replacing or amending Decree-Law 6/2016 for online gaming. Point 5 asks for it. No draft has been approved by the Council of Ministers as far as the government site shows on 22 October 2026.
2. An instrument lifting point 3 of Resolution 54/2025, or a decree-law that overrides it.
3. A published route: a tender notice in the Jornal da República (art. 18(2) requires one) or a ministerial diploma for a direct award under art. 17(4).

Without the first, nothing below it can happen lawfully. Anyone quoting a timeline, a fee or a sub-licence slot today is quoting something the gazette does not contain.

Practical checks

1. Operators and platforms: treat any Timor-Leste licence offered for sale, or held by a counterparty, as revoked since 3 October 2025. Ask for the Jornal da República reference of any instrument that supposedly revived it.
2. Payment and compliance teams: a Timor-Leste licence number on a merchant file is not a licence. Point 1 makes no exception for sub-licences, B2B grants or pending renewals.
3. Comparing options: for regimes that are issuing licences, see the Philippines PAGCOR framework, the Anjouan and Curaçao profiles and the all-jurisdictions cost comparison. Belize is the other case on this site where the government says no online licences are being issued.

What we could not verify

• Whether any instrument for the April 2025 concession was published. We found none in the April 2025 gazette issues we could retrieve, and the concession is known from the company’s announcement.
• The terms of that concession: duration, fees, and whether it relied on art. 17(4).
• Whether a draft amendment to Decree-Law 6/2016 exists inside government. None has been approved and published as of 22 October 2026.
• The ministerial dispatch fixing the art. 13(3) fee for games run by technological means.