SPORTS LAW & GAMBLING – THE INTERNATIONAL PICTURE 

    In the previous article of this series; we explored the relationship between Sports Law and Gambling along with regulation frameworks introduced to address the various legal, social and sporting concerns arising from gabling activities.  

    In this article, we turn to international perspective and examine how gambling, more particularly sports betting, is regulated in different jurisdictions, with a focus on United States of America, the United Kingdom and Australia.  

 

• UNITED STATES OF AMERICA (USA)

    As we are aware, the USA comprises 50 states, each possessing considerable legislative autonomy. Consequently, the regulation of sports betting varies significantly across the country. With the passing of the landmark Supreme Court decision in Murphy v. NCAA (2018), which struck down the federal prohibition on state-authorised sports betting, individual states have been able to determine whether and how sports betting may be permitted within their respective jurisdictions. 

 As of 2025, approximately 38 states permit some form of sports betting with around 30 states permitting online or mobile wagering. This has, in many jurisdictions, resulted in the transition from an extensive illicit betting market towards a regulated and taxable framework.  

However, there is no uniform regulatory model across the United States. Each state determines its own licensing requirements, permitted forms of wagering, taxation structure and compliance obligations. While certain states primarily link sports betting to licensed casinos or physical establishments, others permit wagering through online and mobile applications. 

States have also introduced measures aimed at protecting the integrity of sporting events, including restrictions on certain types of wagers, requirements concerning the use of official league data and mechanisms for monitoring suspicious betting activity. 

Another important aspect of the American model is the allocation of gambling revenues. Certain states direct a portion of gambling-related tax revenues towards responsible gambling initiatives, addiction treatment, education and other public-interest programmes. 

Thus, the American approach can broadly be characterised as one of state-level regulation, commercialisation and taxation, accompanied by increasing emphasis on sporting integrity and responsible gambling. 

 

• UNITED KINGDOM (UK)

 The United Kingdom has adopted a comparatively structured and centralized approach towards gambling regulation. 

The principal legislation governing gambling is the Gambling Act 2005, which established a comprehensive licensing and regulatory framework covering various forms of gambling. The regulatory framework is administered primarily by the UK Gambling Commission. 

Licensed operators are required to comply with extensive obligations concerning responsible gambling, prevention of money laundering, advertising and consumer protection. The regulatory framework also places considerable emphasis on identifying and addressing gambling-related harm. 

The UK has, in recent years, continued to strengthen its approach towards consumer protection. Measures such as the prohibition of gambling payments through credit cards, enhanced financial vulnerability and affordability checks, and the introduction of a statutory levy to fund research, prevention and treatment relating to gambling harm reflect a broader harm-reduction approach. 

The UK model therefore attempts to strike a balance between permitting a regulated gambling industry and protecting consumers from the potential adverse consequences of gambling. 

 

• AUSTRALIA

Australia presents yet another regulatory model. 

Sports betting is legal and has become closely integrated with Australia’s sporting environment. Betting has historically been accessible through licensed bookmakers, retail outlets and, in certain contexts, betting facilities associated with sporting venues. 

However, the increasing visibility and accessibility of sports betting has also generated concerns regarding the normalization and over-commercialization of gambling, particularly its exposure to young people and sports audiences. 

Consequently, Australian authorities have progressively introduced measures aimed at strengthening responsible gambling practices, restricting gambling advertising and maintaining the integrity of sporting competitions. 

The Australian experience demonstrates an important regulatory challenge: how can a jurisdiction permit a commercially established betting industry while preventing gambling from becoming so embedded within sport that it is perceived as an inseparable part of the sporting experience? 

 

• DIFFERENT JURISDICTIONS, SIMILAR CONCERNS 

A comparison of these three jurisdictions demonstrates that there is no single international model for regulating sports gambling. 

The United States largely follows a decentralized, state-based model; while the United Kingdom operates through a comprehensive licensing and regulatory framework; furthermore, Australia has permitted betting to become deeply integrated into its sporting ecosystem while increasingly introducing safeguards to address the resulting concerns. 

Despite these differences, certain common themes emerge: 

• Protection of sporting integrity 
• Consumer protection 
• Responsible gambling 
• Prevention of money laundering and financial crime 
• Regulation of gambling advertising 
• Prevention and treatment of gambling-related harm 
• Monitoring of suspicious betting activities 

Ultimately, the legal regulation of sports gambling is not merely about determining whether betting should be permitted or prohibited. It involves addressing the more complex question of how gambling can coexist with sport without compromising the integrity, values and social character of sporting activities. 

As sports and betting markets continue to become increasingly interconnected, the role of Sports Law will inevitably extend beyond regulating sporting disputes and institutions to addressing the wider legal, commercial and social consequences of this relationship. 

The international experience, therefore, offers an important lesson: regulation may differ across jurisdictions, but the need to preserve sporting integrity remains universal.

~ Adv. Sanika Lalit