[CLOSED] PUBLIC CONSULTATION ON AMENDMENTS TO THE GAMBLING CONTROL (REMOTE GAMES OF CHANCE – CLASS LICENCE) ORDER 2022
1. The Minister for Home Affairs proposes to vary the Gambling Control (Remote Games of Chance – Class Licence) Order 2022 (the “Order”) to allow class licensees to operate in-game marketplaces for player-to-player transactions. Pursuant to Section 61(2) of the Gambling Control Act, the Gambling Regulatory Authority (“GRA”) is publishing this written notice to invite interested persons to make representations about the proposed variation.
Background
2. The Gambling Control Act (“GCA”) came into effect on 1 August 2022. Under the GCA, lower-risk gambling services are regulated under a class licensing regime. A class licence authorises an operator to which the order applies, to provide a gambling service, or a class or description of gambling service, without having to apply for a licence. However, the operator must meet the conditions spelt out in the relevant Class Licence Order before offering the gambling service, or the class or description of gambling service.
Current Class Licence Order for Remote Games of Chance
3. Currently, operators can offer remote games of chance (“RGOC”) under the Order if their games meet the conditions under any one of the following two types of RGOC. Below is a non-exhaustive summary of these conditions:
- RGOC which are free of charge (“Type 1 RGOC”):
- Involves an interactive game of chance that is played for a prize;
- Is conducted in Singapore, or can be accessed by or delivered to players who are physically in Singapore; and
- Does not involve any design element or game mechanic which is specified in the First Schedule to the Order and does not display or use any image of a gambling article specified in the Second Schedule to the Order.
- RGOC which allow players to pay for chances to play (“Type 2 RGOC”):
- Involves an interactive game of chance that is played for a prize;
- Is conducted in Singapore, or can be accessed by or delivered to players who are physically in Singapore;
- There are no monetary prizes, and prizes are designed for use within the same game or related games only; and
- Operator does not, alone or under arrangement with any associate, provide a service whereby the prize is readily converted or made readily convertible into money, money equivalent or any thing else of value1. The only exception is if the thing of value converted from the prize is used in in-game transactions when playing the same game or related games.
4. For more details on the conditions for each type of RGOC, please refer to the Order via the Singapore Statutes Online website (https://sso.agc.gov.sg).
Proposed Variation of Conditions
5. GRA has reviewed the class licence conditions for RGOC.
6. The condition in paragraph 3(b)(iv) above disallows class licensees offering Type 2 RGOC from providing in-game marketplaces for players to transfer and trade prizes (such as in-game weapons) among themselves in exchange for money or money equivalent.
7. However, such in-game marketplaces are sometimes included as part of the design of games to enhance the player experience. Many players use these in-game marketplaces to trade and obtain game items to enhance their gaming experience. These player-to-player transactions are also taking place on third-party platforms outside the game environment. They do not pose law-and-order or social concerns.
8. Therefore, GRA proposes to amend the condition in paragraph 3(b)(iv) to allow operators of Type 2 RGOC to provide in-game marketplaces for players to trade prizes among themselves in exchange for money or money equivalent. Operators will not be allowed to buy back prizes from players through these marketplaces so as to avoid gambling inducement.2 We will also require that prizes exchanged in in-game marketplaces be designed for use within the game or related games only.
Invitation to Provide Feedback
9. Members of the public are invited to provide feedback on the proposal by 20 August 2025 via email to feedback@gra.gov.sg.
10. All feedback received will be considered. However, we will not be able to individually acknowledge or address every one of them. Instead, we will aggregate them, in subsequent communication about the outcome of this public consultation exercise.
1 As explained in the explanatory statement for the GCA, the term “any thing else of value” is intended to include things of value but not capture things that would generally be considered inconsequential. For example, while it is intended to include things such as a trophy, holiday, tickets or merchandise, it is not intended to include recognition prizes consisting solely of a certificate or title or other intangible items.
2 If players are allowed to sell prizes (obtained from playing Type 2 RGOC) back to the operator, it induces players to pay for more chances to play, since there is “guaranteed monetisation” of the prizes.

