Home Digest 4H Agency Bosnia and Herzegovina Unable to Modernize Gambling Laws Quickly

Bosnia and Herzegovina Unable to Modernize Gambling Laws Quickly

Shaped by the 1995 Dayton Agreement, Bosnia and Herzegovina maintains one of Europe’s most unique political frameworks and a complex legislative structure overseen by the rotating Tripartite Presidency.

Yet, 30 years after its formation, Bosnia and Herzegovina’s legislative system faces a critical challenge in modernising its gambling laws – one that will require alignment and compromise from the autonomous regions of the Federation of Bosnia and Herzegovina (FBiH), Republika Srpska (RS), and the Brčko District.

Ivan Kurochkin, Partner and Head of the Consulting Department, 4H Agency,dissects Bosnia and Herzegovina’s challenge of whether a fragmented governance structure can effectively regulate gambling while addressing diverse social concerns and vested interests in taxation policies and licensing requirements.

Gambling Market: Pristine Uniqueness

The gambling market in Bosnia and Herzegovina is uniquely fragmented due to the country’s administrative and political structure. While gambling is legalised in all three entities within the country, differences in regulation, taxation, and market access still create challenges for both local and international operators.

Current Bosnia and Herzegovina’s gambling industry is set for major growth, with online market revenues expected to reach around €45 million by 2025. This expansion is driven by the rising popularity of online gambling, which is attracting in more players, particularly younger ones. The main factors behind this trend include the widespread use of smartphones and the growing interest in digital gaming experiences, making the industry even more attractive and promising for businesses.

One of the main trends in Bosnia and Herzegovina’s online gambling market is the growing popularity of sports betting. Since sports have always played an important role in the country’s culture, the ability to place bets on various events online has attracted more and more players. This trend is also fueled by the rise of mobile gambling, which allows users to bet on their favorite teams and athletes anytime, anywhere. 

Another noticeable shift is the increasing demand for online casino games: virtual slot machines, poker, roulette, and other classic casino games are drawing in new players who enjoy the thrill of gambling. Improvements in technology and the introduction of live dealer games have made online casinos feel even more like the real thing, adding to their appeal.

Rules of a Fragmented Regulatory Framework

The industry is regulated separately within the Federation of Bosnia and Herzegovina, Republika Srpska, and the Brčko District. Each region enforces its own gambling laws and different licensing requirements with distinct regulatory frameworks:

  • Federation of Bosnia and Herzegovina (FBiH) – Regulated by the Tax Administration under the Ministry of Finance. The Law on Games of Chance (2015) governs all gambling activities.
  • Republika Srpska (RS) – Overseen by the Republic Administration for Games of Chance under the Ministry of Finance. The Act on Games of Chance (2019) establishes regulatory requirements.
  • Brčko District (BD) – Managed by the Tax Administration within the Directorate of Finance, under the Law on Games of Chance (2022).

Each entity operates independently, making Bosnia and Herzegovina one of the most complex gambling jurisdictions in Europe. Generally, the following verticals are regulated as follows:

  • Online Gambling – Regulated across all three entities. Online betting and casino games require local licenses, but only for companies that also have land-based operations.
  • Land-based casinos – Operators can obtain licenses in all three entities. However, in Republika Srpska concessions are granted on the basis of a public tender.
  • Land-based betting – Regulated in all three entities. Local licensing is required for organising betting in betting shops.
  • Gaming Machines – Regulated in all entities.
  • Lotteries – Stated-owned. Lottery games are organized exclusively by the authorities of each of the three entities.
  • Supplier Licensing – No specific supplier licensing exists, but all gaming software and machines must be certified by authorized laboratories.

Responsible Gambling and Advertising

  • Age Restrictions – A strict 18+ policy applies across all entities.
  • Self-Exclusion and Limits – Republika Srpska and Brčko District mandate self-exclusion options, while the Federation of B&H lacks specific requirements.
  • Advertising Restrictions – All entities restrict advertising targeting minors, but Republika Srpska has the most comprehensive and restrictive responsible gambling advertising framework.

Despite the above-mentioned RG measures, Bosnia faces a serious problem with gambling addiction. According to research, nearly half of Bosnia and Herzegovina’s residents have tried gambling at least once, either in one of the many gambling halls or online. Estimates suggest that more than 500,000 people visit betting shops and engage in gambling activities daily in the country.

Presidencies aware of visible flaws and loopholes 

In recent months, growing concerns over gambling-related issues have led political parties and the government to push for tighter regulations in Bosnia and Herzegovina. 

Lawmakers are currently debating several amendments to the Gambling Act aimed at addressing regulatory loopholes and improving social protections. One of the key issues is the widespread violation of the legal requirement that gambling venues maintain a minimum 100-meter distance from schools and religious buildings. 

Due to vague enforcement procedures and a lack of coordination between municipalities and the Ministry of Finance, hundreds of establishments continue operating in restricted areas. Activists from Ticket to ZIS initiative have identified around 600 such locations and are advocating for stronger oversight. 

They argue that inconsistent distance measurement methods and automatic permit renewals for older establishments have allowed the gambling sector to bypass regulations. Despite legal provisions assigning oversight responsibilities to the Tax Administration and Ministry of Finance, enforcement remains weak, leading to calls for urgent reform.

In addition to this initiative, legislators are also considering broader regulatory measures, including a proposal to prohibit betting shop operations on Sundays. The amendment, introduced by Dennis Gratz of the Democratic Front, aims to align gambling industry work schedules with labor laws that recently restricted retail operating hours to Monday through Saturday. Supporters argue that this measure would improve employee work-life balance and create consistency across industries. 

However, critics warn that limiting Sunday operations could negatively impact tax revenues and force operators to shift their focus toward digital betting platforms, which remain unaffected by physical location restrictions. This legislative move contrasts with trends in other jurisdictions, such as Northern Ireland, which recently lifted its ban on Sunday betting.

Bosnia and Herzegovina’s proposed gambling reforms reflect a growing societal emphasis on consumer protection, labor rights, and regulatory consistency. Ultimately, the Bosnian gambling market faces ongoing challenges:

  • Fragmented Regulation – Operators must navigate different requirements for each entity, creating a complex licensing process.
  • Limited International Presence – The absence of major international gambling brands due to the relatively small market and regulatory uncertainty.
  • Potential for Regulatory Unification – Industry discussions continue regarding the possibility of harmonizing gambling laws across all entities, which could improve market accessibility and compliance.
  • Potential Tightening of Legislation – problems with gaming addiction may lead to stricter regulations in areas such as advertising, responsible gaming, and more.

Conclusion: Harmonisation can paint a brighter picture 

Bosnia and Herzegovina’s gambling sector is complex and challenging. As mentioned, there is no unified state regulation of gambling, Since the country is politically divided into regions, its regulation remains fragmentated. While the country offers regulated gambling opportunities across its three entities, but the fragmented regulatory landscape complicates market entry.

We think that future reforms could focus on greater harmonization of laws and increased regulatory oversight to improve transparency and attract international operators. As more consumers shift to online platforms, reflecting a growing preference for convenience and easy access, the future of iGaming in Bosnia and Herzegovina looks promising, aligning with both local and global industry trends. Whether such changes will materialize remains an open question, but the Bosnian gambling market is undoubtedly one to watch in the coming years.

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