Legal casino gambling age in Comoros
The Union of the Comoros, an archipelago state in the Mozambique Channel, has no dedicated gambling statute, no gambling regulator at national level and no national lottery or betting monopoly that could be identified from official sources. Its constitution makes Sunni Islam the religion of the State, and the gambling market that does exist is very small. Despite this, the name of one of its islands, Anjouan (Ndzuwani), has become widely known in the international online gambling industry. A body calling itself Anjouan Gaming says it has issued more than 1,650 internet gaming licences, while the Central Bank of the Comoros describes the island’s offshore finance authority as fictitious and Comorian authorities have been reported as saying that such licences lack a legal basis. This guide sets out what can be verified about the law, the land-based sector, the Anjouan licensing dispute and the position of people gambling from the Comoros.
Key points
- Article 97 of the 2018 Constitution states that “Islam is the State religion”; criminal offences and penalties, and the basis and rate of taxes, must be set by law (Article 89).
- No Union law specifically licensing online gambling, and no national gambling regulator, could be identified. Nor could a national lottery or a state betting concession.
- A 2010 IMF assessment found a single casino in Moroni with 15 slot machines, and reported that a casino on Anjouan had closed. Its current status could not be verified.
- Anjouan-issued internet gaming licences, based on a 2005 island act, are disputed. The Central Bank of the Comoros calls the Anjouan Offshore Finance Authority a fictitious structure, and Union authorities have described the licences as lacking a legal basis.
- According to trade reporting, the Anjouan licensing scheme lists the Comoros itself among the territories its licensees must not serve.
- Mayotte, which the Comoros claims, is administered by France as an overseas department and is not covered by this guide.
Last reviewed: 13 October 2026.
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Historical development
The Comoros consists of three islands under Union administration: Ngazidja (Grande Comore), where the capital Moroni is located, Ndzuwani (Anjouan) and Mwali (Mohéli). Article 6 of the constitution also lists Maoré (Mayotte) as part of the national territory. Mayotte, however, remains under French administration; Article 122 provides that the institutions of Maoré will be established once what the constitution calls the occupation of the island ends. Gambling in Mayotte is governed by French law, so it is outside the scope of this guide.
Commercial gambling in the Comoros has historically been tied to tourism. In the early 1990s a South African hotel group opened resort hotels on Grande Comore. According to Travel News (14 June 2022), their facilities included watersports, dive sites, “family entertainment and a casino”. Political instability later ended the project, and the hotels were mothballed in 2001. A joint venture announced in 2005 to revive them was shelved within a year.
The late 1990s and 2000s were dominated by a separatist crisis on Anjouan. A Union constitution of 23 December 2001 gave the islands substantial autonomy, but according to the IMF Anjouan remained outside the Union’s control until March 2008, when the separatist government was overturned. Offshore financial legislation, including the island’s gaming act of 2005, dates from this period of contested authority. This matters because the legal status of those texts is still disputed (see below).
The International Monetary Fund’s 2010 anti-money laundering assessment of the Comoros gives the clearest official snapshot of the land-based sector. Its findings were dated March 2010 and published in October 2010. It recorded that “there is only one casino located in Moroni”, that “another casino was located on Anjouan, but it is now closed”, and that the Moroni casino had “only 15 slot machines in operation” with a daily turnover of less than €2,000. We could not find a more recent official statement on whether any casino currently operates in the Comoros.
Legal framework
Constitutional setting
The current constitution was adopted by referendum in 2018 and replaced the constitution of 23 December 2001. Its preamble refers to “a sole religion (Sunni Islam)”. Article 97 states that “Islam is the State religion”, and that the State takes its religious rules from Sunni principles and the Shafi’i school. Article 98 makes the Mufti of the Republic “the highest religious authority of the State” (Constitution of the Comoros, 2018). Classical Islamic jurisprudence prohibits games of chance played for stakes, so this constitutional identity shapes the social context of gambling. The constitution itself, however, contains no express provision on gambling.
For gambling law, three constitutional rules are relevant. First, Article 89 reserves to statute “the determination of crimes and misdemeanors as well as the penalties applicable to them”, as well as “the base, rate and modalities of tax collection of any nature”. Second, the islands enjoy “free administration and autonomy of management” (Article 99). Their exclusive competences, listed in Article 102, include island economic planning, tourism, traditional fishing, road maintenance and fairs and markets. Gambling, banking and criminal law do not appear in that list. Third, the earlier division of powers was set out in Organic Law No. 05-003/AU of 1 March 2005. Under Article 15 of that law, the Union legislates on “droit pénal et procédure pénale” (criminal law and procedure), on commercial and company law, and on “droit bancaire et de l’assurance” (banking and insurance law).
Criminal law
The Comoros adopted a new Penal Code by Law No. 20-038/AU of 29 December 2020, promulgated by Decree No. 21-018/PR of 16 February 2021. It replaced the earlier code of 1981–1982, which was amended in 1995. Many francophone codes derived from the French code of 1810 contain offences of keeping a gaming house or running an unauthorised lottery. We were unable to confirm from the text available for this review whether the 2020 code contains equivalent provisions, or how they are worded. The portion of the published text we could read contained no reference to games of chance, lotteries or betting. For that reason this guide does not state any specific gambling offence or penalty under Comorian criminal law. Readers who need certainty should consult the official text through the Ministry of Justice or a local lawyer.
Anti-money laundering law
The clearest statutory reference to casinos is in anti-money laundering (AML) law. The IMF reported that Ordinance No. 09-002/PR of 6 March 2009 extended AML obligations to designated non-financial businesses and professions (DNFBPs), a category that includes casinos. It also noted that implementing regulations for casinos were “still pending” at the time (IMF Country Report No. 10/320). The Comoros has since been assessed by the Inter-Governmental Action Group against Money Laundering in West Africa (GIABA): a mutual evaluation report was published in May 2024, following an on-site visit from 12 to 26 July 2023, and a second enhanced follow-up report in May 2026. The full texts are distributed by GIABA and were not reviewed for this guide.
Regulator and licensing model
No dedicated gambling regulator for the Union of the Comoros could be identified. We also found no published licensing regime, list of licensed operators or fee schedule issued by a Union ministry for casinos, betting or lotteries, and no state-owned lottery, sports pool or betting company. This does not prove that no authorisation mechanism exists. Older francophone systems often authorise individual casinos by ministerial decree, for example. It does mean that no such mechanism is publicly documented in sources we could verify.
In the terms used in comparative gambling law, the Comoros therefore fits neither a monopoly model (a single state-controlled operator) nor a licensing model (a regulator granting licences to competing private operators). The more accurate description is an unregulated or residual model. A very small land-based sector existed, recorded in 2010, and no specific legislation governs remote gambling for the domestic market.
The Anjouan licensing scheme
The Comoros attracts attention abroad because of internet gaming licences issued in the name of Anjouan. According to Asia Gaming Brief (17 June 2024), the legal basis claimed for these licences is the “Computer Gaming Licensing Act 007 of 2005”. The same report gave licence fees, including set-up costs, of €17,000 a year, and said “there is no gaming tax”. Trade press reported that Anjouan Gaming, the body administering the scheme, had issued more than 1,650 licences by July 2026, of which nearly 1,500 were active (Focus Gaming News, 20 July 2026). It issues both B2C (business-to-consumer, i.e. operator) and B2B (business-to-business, i.e. supplier) licences (Focus Gaming News, 23 September 2026).
The legal standing of this scheme within the Union is contested:
- Central Bank of the Comoros. In a communiqué on illegal offshore banking activity, republished by the Ministry of Finance on 10 December 2025, the Banque Centrale des Comores (BCC) described the Anjouan Offshore Finance Authority, a similar authority on Mohéli and related service entities as fictitious structures. It said that licensing banks and financial institutions is within its exclusive competence, and that it had referred these structures to the prosecutors in Moroni, Mutsamudu and Mohéli. The communiqué concerns banking, not gaming.
- Warning on gambling licences. Focus Gaming News reported in January 2026 that Comorian authorities had warned about entities selling gambling and financial licences in Anjouan’s name, and said that these licences “lack any legal basis” and rely on “outdated laws from 2005”. The report quotes the central bank as saying the offshore authority has “no physical or legal existence” in the country. It does not identify the specific official or the date of the warning, and we could not locate the original statement.
- IMF assessment. The IMF’s 2010 report found that offshore financial institutions on Anjouan and Mohéli “were created in violation of the Union’s law”, and that legislation enacted by the separatist regime in the criminal and banking fields is “without effect”. It also noted that the island law creating offshore companies had been “legally adopted by the Parliament of Anjouan” and had not been repealed. The report does not discuss the 2005 gaming act.
- Anjouan Gaming’s position. In a statement reported by SBC News on 10 June 2026, the body said that an Anjouan licence “is not, and has never been presented as, a universal authorisation to operate in every country in the world”, that “no licensing authority can exempt an operator from local law”, and that “licensees remain responsible for lawful conduct in their chosen markets”.
No court decision resolving the status of the 2005 act could be found. The safest reading of the sources is that Anjouan licences are issued under an island text whose validity Union authorities dispute. They are not a Union licence, and they do not authorise gambling services aimed at residents of the Comoros.
Online gambling
No Comorian law expressly authorises, licenses or prohibits online gambling offered to residents, and no domestic online operator licensed by a Union authority could be identified. Several points nonetheless follow from the sources.
- Anjouan licences exclude the Comoros. According to Asia Gaming Brief, the Anjouan scheme lists the Comoros among its “restricted or prohibited” territories, along with countries such as Australia, France, the United Kingdom and the United States, and it requires licensees to block players from those territories by IP address. An Anjouan-licensed site that accepts Comorian residents would therefore be breaching its own licence terms.
- No blocking regime. We found no evidence of ISP blocking lists, payment blocking or advertising rules aimed at online gambling in the Comoros.
- Payments. Electronic money is supervised by the central bank. The BCC communiqué lists the institutions it regards as lawfully established in the Union, including electronic-money institutions (BCC communiqué). We found no official statement or reliable report on the use of mobile money for online betting in the Comoros, and no rule specifically restricting it.
- International scrutiny. Anjouan licences feature heavily in discussion of unlicensed gambling in regulated markets. SBC News reported in June 2026 that many Anjouan licence holders serve customers in markets such as the United Kingdom without a local licence. In September 2026 Anjouan Gaming said it had strengthened its licence conditions after the Financial Action Task Force (FATF) published a report on money-laundering risks in gambling (Focus Gaming News).
Position of players
The legal position of an individual in the Comoros who gambles online cannot be stated with precision, because the relevant criminal provisions could not be verified. What the sources do support is narrower:
- No Union authority licenses online gambling for residents. A resident who plays online is therefore never dealing with an operator authorised and supervised in the Comoros.
- Operators holding Anjouan licences are, according to the published scheme terms, not permitted to accept players from the Comoros.
- We found no reported prosecutions, fines or other enforcement action against individual players, and no public warnings directed specifically at players.
In practice, a player in the Comoros has no domestic regulator to complain to, no dispute-resolution route recognised by Union authorities, and no assurance that winnings will be paid. Social norms are also relevant. In a country whose constitution establishes Sunni Islam as the State religion, gambling carries strong religious disapproval, whatever its precise criminal status.
Taxation
Under Article 89 of the constitution, the basis, rate and collection of any tax must be set by law. We could not identify any Comorian tax law specifically on gambling turnover, gross gaming revenue (GGR, the amount operators keep after paying out winnings) or players’ winnings. No published figures for gambling tax receipts were found either. The “no gaming tax” feature advertised for Anjouan licences, as reported by Asia Gaming Brief, concerns the island scheme’s fees for offshore operators. It is not a statement of Union tax law and should not be read as one. Questions about the tax treatment of any income should be directed to the Comorian tax administration or a local adviser.
Consumer protection and responsible gambling
We found no national self-exclusion register, no statutory responsible-gambling obligations for operators and no dedicated gambling helpline or treatment service in the Comoros. As far as can be verified, the consumer-protection tools common in regulated markets, such as deposit limits, reality checks, age verification under a domestic licence and access to an ombudsman, are not available to residents through any Comorian scheme.
Anjouan Gaming states that its licensees must take part in an independent alternative dispute resolution (ADR) scheme for eligible player disputes and observe responsible-gaming measures (Focus Gaming News). Those commitments apply under a licence that does not permit service to the Comoros, so they offer residents little practical protection. Anyone in the Comoros concerned about their own or someone else’s gambling may find general guidance, including on self-help and blocking tools, in our responsible gambling guide.
Recent and upcoming developments
- GIABA mutual evaluation (May 2024). The Comoros’ AML/CFT regime was assessed after an on-site visit in July 2023, and a second enhanced follow-up report followed in May 2026 (FATF; FATF).
- Central bank warning republished (10 December 2025). The Ministry of Finance republished the BCC communiqué describing the Anjouan and Mohéli offshore authorities as fictitious (Ministry of Finance).
- Warning on Anjouan gambling licences (reported January 2026). Comorian authorities were reported to have said that gambling licences sold in Anjouan’s name lack a legal basis (Focus Gaming News). The status of any follow-up action is not known.
- Anjouan Gaming statements (June–September 2026). The body said its licences are not a global authorisation (June), reported more than 1,650 licences issued (July) and announced stricter licence conditions after the FATF gambling risk report of 9 September 2026 (September) (SBC News; Focus Gaming News; Focus Gaming News).
- No domestic reform identified. As of 13 October 2026 we found no bill, decree or announcement proposing a gambling law, regulator or national lottery for the Union of the Comoros.
Casino listings for players in Comoros
The listings below are generated automatically from our casino database. They do not show that any operator is licensed or authorised in the Union of the Comoros. No Union authority licenses online casino games, and no official register exists to check. Anjouan-issued licences are disputed by Union authorities, and under their own terms they exclude players in the Comoros. The listings must not be read as an indication that playing from the Comoros is lawful or protected.
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Sources and further reading
- Constitute Project, Comoros’s Constitution of 2018 (English translation; accessed 13 October 2026).
- Ministère de la Justice, Union des Comores, Loi organique N°05-003/AU du 1er mars 2005 portant modalités d’application de l’article 9 de la Constitution de l’Union des Comores (2005; accessed 13 October 2026).
- Union des Comores, Loi n°20-038/AU du 29 décembre 2020 portant Code pénal (2020; text hosted by Droit-Afrique, accessed 13 October 2026).
- International Monetary Fund, Union of the Comoros: Detailed Assessment Report on Anti-Money Laundering and Combating the Financing of Terrorism, IMF Country Report No. 10/320 (2010).
- Financial Action Task Force / GIABA, Comoros’ measures to combat money laundering and terrorist financing (Mutual Evaluation Report) (2024).
- Financial Action Task Force / GIABA, Comoros’ progress in strengthening measures to tackle money laundering and terrorist financing (2nd Enhanced Follow-Up Report) (2026).
- Ministère des Finances, Union des Comores, Communiqué de la Banque Centrale des Comores sur l’exercice illégal d’activités bancaires offshores (10 December 2025).
- Focus Gaming News, Anjouan license scam: Comoros warns of fake gambling permits (7 January 2026).
- Focus Gaming News, Comoros: Anjouan Gaming surpasses 1,650 internet gaming licences (20 July 2026).
- Focus Gaming News, Comoros’ Anjouan Gaming tightens licence rules after new FATF gambling risk report (23 September 2026).
- SBC News, Anjouan denies global reach of licences (headline abridged) (10 June 2026).
- Asia Gaming Brief (F. Schuengel), The Pre-Regulated Playing Field: A Look at Online Gambling Jurisdictions in 2024 – Anjouan (17 June 2024).
- Travel News, Comoros hopes to compete with MRU (14 June 2022).
