Am I allowed to organize a lotto game (bingo night)?


Belgium outlaws running games of chance without a licence (see Article 4 of the Gambling Act). Kienen may only be offered in a gambling establishment. Violating this ban is punishable by imprisonment and/or a fine. However, the legislator provided an exemption in Article 3.3: 


3. Card and board games played outside Class I or II gambling establishments, and games run by amusement parks or carnival/fairground operators at carnivals/fairgrounds, trade fairs or other fairs in similar circumstances; or games organised occasionally and not more than four times per year by local associations on the occasion of special events or by a de facto association for a social or charitable cause; or by not-for-profit associations for a social or charitable cause, requiring only a very small bet and affording the player or gambler only a low-value material advantage.


The Crown determines, in application of points 2 and 3, the detailed conditions of the type of establishment, the type of game, the amount of the bet, the profit that can be obtained and the average hourly loss.


The Department of Justice is currently studying a draft Royal Decree fixing the amount of this very small bet and low-value material advantage.


Note that games that do not meet the definition of a game of chance (presence of a bet, possibility to win/lose, presence of a chance or non-chance element) are not banned. For example, a free black jack evening. If you wish to advertise such events, please communicate clearly to avoid creating confusion with the Police and ensure you are not faced with a Police raid.


Nevertheless, in the absence of a Royal Decree, the Gambling Commission (Kansspelskommissie) has set priorities for its repressive policy. It is highly advisable to contact the local Police or Public Prosecutor’s Office if you meet the specified conditions.


The Gambling Commission has decided that the following files will be prioritised, i.e. when:

•    The Police or Public Prosecutor’s Office have doubts and information that the bets and payouts are higher than notified in the circular from the College of Prosecutors-General (0.20 ct per game and maximum of €6.20 profit)

•    There are only cash games and no tournament

•    Minors (-18 years old) are present

• A commercial circuit is in operation

• There is advertising of illegal websites or facilities acting as sponsors

• People known from the criminal circuit are acting as organisers or are present


A file is not a priority when:

• There is a tournament, once per month, costing not more than €20 for registration or membership.


It makes no difference whether the amounts are in money or material prizes. Both are considered forms of profit and, i.a., go to justify classification as a game of chance. If you are excessive with material prizes it is more likely that the Police or Public Prosecutor will react.