Gambling has been illegal in Vietnam for the bulk of its modern history. This, however, may be changing. Here’s what foreign firms should know about legalized gambling in Vietnam and what to watch moving forward.

On a good day, individual lottery ticket vendors in Vietnam can reportedly make VND 300,000 (US$15) selling tickets on the streets of Vietnam’s cities and towns. Tickets are sold for around VND 10,000 a piece with the lottery vendor pocketing about VND 1,000 and the rest being returned to their distributor. It’s not a huge income, but it’s income nonetheless and it’s legal.

Indeed, though gambling in Vietnam is common, legal gambling for Vietnamese citizens has for a long time been limited to the lottery.

Officially established in 2011, the national lottery provider, Vietlott, came about right when Vietnam was on the precipice of a mighty economic boom. Manufacturing was just taking-off and in the years after, average incomes rose dramatically, and Vietnam’s consumer class bloomed.

With disposable incomes the likes of which Vietnam had never seen before, entertainment spending rose dramatically, a subsector of which was gambling.

Whereas in the past, this pursuit had been limited to small games of chance in street-side stalls, usually with dice or cards, this would no longer cut it for Vietnam’s thriving upper-middle and wealthy classes. But with few other options, gamblers looking for a bigger, better, and more luxurious thrill were forced to head abroad.

Regional players raise stakes

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In the early part of the 21st century, casinos began to spring up along Vietnam’s border with Cambodia.

These casinos lured in Vietnamese with means (and many without) from the country’s financial hub, Ho Chi Minh City. Just a short drive from the city, thousands of dollars were crossing the border and landing in the hands of Cambodian casino moguls but also organized crime figures.

Indeed, myriad reports emerged in Vietnamese media detailing crimes at the hands of loan sharks in pursuit of debt repayment.

Wealthier Vietnamese, however, went even further abroad with Asian gambling Mecca – Macao – just a hop, skip, and a jump to the north or Singapore, just a short puddle-jump to the south, with millions, maybe even billions of dollars flying out of the country too.

But that’s not to say Vietnam was necessarily losing out. Though relatively small compared to regional gambling bigwigs, Vietnam was also starting to develop its own casinos. These were, however, restricted to foreigners only, and were few and far between, mostly in key tourist destinations.

Online gaming hits jackpot

With casinos limited to foreigners and traveling to gambling hotspots time-consuming and too expensive for most Vietnamese, the population was well primed for online gambling.

The internet took off in a big way in Vietnam with penetration going from 34 percent in 2013 to 75 percent in 2023. This offered the emerging economy the opportunity to leap-frog a number of the technological hurdles more advanced economies had had to overcome.

Global digital integration, however, brought with it a slew of cross-border services like social media, on-demand videos, and, of course, online gambling. Vietnamese bettors could access online casinos all over the world and they did.

That is not to say that they necessarily had to digitally go that far afield. Though illegal, the lucrative online gambling trade was irresistible to many willing to take the risk and local, web-based casinos began to pop up online too.

Electronic poker machines

But casinos and online platforms weren’t all that was proliferating in Vietnam. Rounding out the gaming establishment trifecta were electronic gaming machine venues.

In key cities and towns, small venues with electronic poker machines were beginning to appear and when Decree 86/2013/ND-CP was issued in 2013 to regulate the electronic poker machine industry, there were already a reported 43 venues in operation.

This decree would serve to make those establishments official, ensure proper licensing, and allow for the government to take a cut through licensing fees. It also, however, made clear that Vietnamese citizens would not be allowed to use these machines to gamble, leaving the buzzing and whirs of the electronic cash cows to tourists and expatriates.

It would be another four years before Vietnamese would be, in principle, permitted to enter gaming establishments for the purposes of having a flutter.

Government rolls dice on allowing locals to play

In 2017, there were two key policy developments in quick succession that opened up legalized gambling to Vietnam’s almost 100 million-strong populous.

The first was Decree No. 03/2017/ND-CP on Casino Businesses, which allowed residents to enter and gamble in specific casinos on a trial basis. These venues, however, needed to be licensed and approved, which would take some time—two more years, in fact.

The second was Decree No. 06/2017/ND-CP, just weeks later, which would pave the way for legal sports betting. It essentially outlined how a sports betting business should be formed and what local bettors would be permitted to bet on—specifically, horse racing, greyhound racing, and international soccer. It was, however, in parts vague, and establishing a sports book business came with stringent requirements.

For example, sports betting was limited to a handful of sports with a maximum bet of VND 1 million (US$42). Firms also needed charter capital in excess of VND 1 trillion ($42 million) to establish a horse racing or football betting business or VND 300 billion ($12.7 million) in the case of greyhounds.

As a result, by the time the World Cup rolled around in 2018, no local sports betting agency had a license, and therefore no Vietnamese could gamble legally on the football.

Sports betting still a favorite

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Perhaps acknowledging that sports betting was unavoidable, a second piece of legislation was passed the day the 2018 football World Cup kicked off. This was an update to the Law on Physical Training and Sports, with a section added that more or less reiterated what was already in Decree 06. Though it added very few new regulations, it did further solidify the legal guardrails for establishing a sports betting business.

This was, however, too late to allow for legal gambling on the 2018 World Cup.

With this in mind, it was no wonder that illegal bookmakers were ‘mushrooming on city streets’, according to local media outlet Tuoi Tre. On a side note, the same article went on to report a correlation between World Cup betting and an increase in suicides and a rise in crime, though details were suspiciously vague.

But whereas sports betting would remain on the wrong side of the law for some time to come, the first casino in Vietnam to allow local gamblers was just months away from opening.

Covid and the Corona Casino gamble

The ironically named Corona Casino in Phu Quoc, opened its doors in January of 2019 just months before Vietnam closed its borders to foreign tourists to stymie the spread of the Coronavirus.

The Corona Casino, however, had an ace up its sleeve. It had been approved for the aforementioned trial program whereby Vietnamese people would be allowed to gamble in the casino. This came with strict regulations that included:

• Gamblers had to be at least 21 years of age;
• They had to prove an income in excess of VND 10 million (US$422) per month or that they were in the level three tax bracket; and
• They had to buy a ticket priced at VND 1 million (US$42) per day or VND 25 million (US$10.56) for one month.

But despite being relatively strict, these regulations were negligible and the Corona Casino reported a pre-tax profit of US$4.67 million in its first six months of operation. It went on to record strong growth year on year up to 2021 when Coronavirus outbreaks around Vietnam saw domestic travel grind to a halt.

That said, it was able to resume business as vaccination rates rose and was able to complete its three-year trial run.

Opinions on the outcome of the trial have been few and far between. The Ministry of Finance, (MoF). however, at the end of 2022 came out in favor of extending the trial for another two years.

“The trial program… has proved to be a correct policy that satisfies the needs of a group of citizens and increases government revenue,” the ministry reportedly told the Politburo, according to VN Express.

There appears, however, to have been little movement one way or another. VinPearl, which is invested in the resort, was reporting that the facilities were still accessible to Vietnamese nationals as recently as May of this year and it looks as though the government may be letting it ride.

MoF doubles down with football betting business

But the MoF wasn’t content to stop at casinos. In January of this year, it took another step toward greater legalized gambling, licensing Vietnam Lottery to pilot a sports betting business for international football tournaments.

This was almost six years after Decree No. 06/2017/ND-CP had been issued, during which time sports betting had flourished.

In fact, a TGM Research study last year found that 45.12 percent of the population of Vietnam had been involved in sports betting activities in the 12 months up to October of 2022. Though, notably, 2022 was a World Cup year so numbers were likely higher than usual.

Regardless, the demand for sports betting services had become incredibly clear and the move to license a local provider would likely pay dividends for the authorities. That said, how the newly licensed Vietnam Lottery will utilize this licensing first, is unclear, alongside when the first bets might be taken.

Still, change seems to be in the air and Vietnam could very soon, be very flush with opportunities in the field of legalized gambling.

What foreign investors should know

For foreign firms, the legalized gambling space in Vietnam stands to be challenging but lucrative. With this in mind, foreign investors should remember that:

• Keeping track of developments is important. Foreign firms should be aware that Vietnam still has a long way to go with respect to creating the necessary laws and regulations to make gambling commonplace. Keeping abreast of local media and the development of laws and regulations pertaining to gambling may be key to obtaining a first-mover advantage. This can best be done by subscribing to the Vietnam Briefing.

• Navigating gaming regulations can be tricky. With respect to establishing a gambling venue in Vietnam, be it a casino or electronic gambling center, navigating regulations can be difficult. There are often a number of separate government departments involved with overlapping rules and requirements. The support of well-trained professionals can make the journey from inception to approval much easier.

• Tax law in Vietnam can be complicated. Casinos and electronic gaming venues, as well as cross-border service providers, each have their own specific tax requirements. These can best be understood by engaging the services of an on-the-ground tax professional like the experts at Dezan Shira and Associates.

Viva Las Vietnam

There is a sign above the doorway of the Winner’s Club at the Hanoi Hotel that reads ‘foreigners only’. On the other side of the threshold, electronic gaming machines buzz and whirl with bright lights and loud noises marking wins and losses as they respond at random to the hard currency being pumped through their mechanical frames.

But whereas Vietnamese are banned from gambling in most circumstances, certain clear tells are visible that suggest change may be afoot. Foreign firms should be patient but pay attention, in a Southeast Asia plump with casino moguls, foreign players may need to move quickly and as such should make sure they are well prepared.