Abstract:
You and your friends operate a sports-event prediction app. Users pay to access analysis and then place bets on football matches. Could you be convicted of “operating a casino”? Do not assume that taking only a 1% commission makes it safe. This article outlines three legal red lines: operating without an ICP license may constitute the crime of illegal business operations; knowingly providing “insider” analysis while aware that users are betting on football may make you an accomplice to the crime of gambling; and if authors’ titles and track records are fabricated, you may even be implicated in fraud. After reading, you will understand how to avoid the risk of imprisonment in this seemingly highly lucrative business.

Keywords:
Crime of illegal business operations; crimes of gambling and operating a casino; determination of fraud; boundary between “selling tips” and paid knowledge services

 Special Disclaimer:This article is an original work by Attorney Shao Shiwei. It reflects only the author’s personal views and does not constitute legal consultation or legal advice on specific matters. For article reprints, legal consultations, or peer exchanges, please add: sswls66.

 

Main Text:

The 2026 FIFA World Cup hosted by the United States, Canada, and Mexico will be held from June to July 2026. In practice, during major sporting events such as the World Cup, public security organs intensify their crackdowns on illegal and criminal activities related to football betting. In China, the only lawful football betting option is the China Sports Lottery. Other activities, such as establishing offshore gambling websites, acting as private bookmakers, or operating credit-based betting platforms, constitute illegal and criminal conduct.

 

In practice, however, there is a gray-area business model: providing paid sports-event prediction services. Under this model, authors who have joined the platform publish articles containing event intelligence analysis and score predictions, and users must pay to unlock these articles.

 

I recently discussed this type of business with the owner of a technology company. He mentioned that friends of his operate paid-knowledge platforms offering analytical predictions for football matches and stocks. Even during ordinary periods, their average monthly transaction volume can reach RMB 10–20 million. As the platform operator, even with only a 1% commission, monthly profits exceed RMB 1 million. During major events such as the World Cup, revenues would be even higher. Moreover, the technical cost of building such an app is not high.

 

Thus, it may appear to be a highly lucrative business opportunity.

 

 

I. Author of this article: Attorney Shao Shiwei

 

 

1

 

Paid Sports Event Predictions: Are They Illegal in China?

 

In fact, such sports event prediction services have existed in the market for many years and are not a newly emerging niche business.

 

Moreover, some sports event prediction companies offer paid prediction services to ordinary users, with some evenpublicly committing to refund the prediction fees and partially compensate customers for their losses if the predicted results are incorrect.

 

From the operators’ perspective, they merely conduct predictions and analyses of sports events, forecasting scores and outcomes. They do not inquire whether customers, after paying to view the analytical content, purchase lottery tickets or engage in illegal sports betting. The platform only collects fees paid by users for accessing paid articles as knowledge-based content, and, as the platform operator, it takes only a small commission.

 

However, operators are well aware of why bettors actually pay—users are not truly interested in the analysis itself; rather, they seek to know, based on the author’s or key opinion leader’s (KOL’s) viewpoint, which team will win, so that they can use this conclusion for illegal sports betting. In some cases, when users become overly engaged, they may repeatedly pay high prices, spending substantial amounts to purchase these conclusions.

 

Therefore, how should such businesses be characterized under Chinese law, and what distinguishes them from the “sale of tips” within the online illegal sports betting industry chain? If one operates a business purely focused on “selling tips” (i.e., only predicting match outcomes without recommending lottery purchases or participating in betting), what risks might arise?

In particular, could such activities involve criminal legal risks such as the crimes of gambling, operating a casino, or illegal business operations?

 

 

 

2

 

What Is the Difference Between Sports Event Predictions and the “Sale of Tips” for Illegal Sports Betting?

 

Within the online illegal sports betting industry chain, the “purchase and sale of tips” has long been a traditional gray-market industry existing for decades.

 

So, what does the “sale of tips” for illegal sports betting mean? It refers to certain tip sellers who claim to possess so-called insider information on illegal sports betting. To attract bettors to believe in the accuracy of their information, these tip sellers may fabricate false “track records” to induce bettors to purchase their tips at high prices. These tip sellers essentially profit from this information asymmetry.

 

Why draw an analogy between sports event predictions and the sale of tips for online illegal sports betting? This is because many operators providing sports event prediction services themselves consider their business activities to constitute the “sale of tips,” for the following reasons:

 

To induce users to pay for their articles (sports match prediction analyses), authors who join the platform often claim to provide “exclusive” or “top-secret” information and adorn themselves with various titles to enhance their perceived authority among users. Users pay precisely for this perceived authoritative status and exclusive information. Furthermore, within the paid content, authors explicitly provide readers with their predictive views on the outcomes of specific sports matches.

 

The platform is fully aware that authors guide users to make payments in this manner. However, because the platform’s commission increases with user payments, it often tacitly permits such content. To mitigate legal risks, the platform packages these services under the guise of “paid knowledge” or “Knowledge Planet.”

 

Thus, there are indeed similarities between the two. If an author’s paid content emphasizes that its predictions are based on insider information and are absolutely accurate, and if the author fabricates past performance records or even their own titles to attract more paying users, such paid content more closely resembles the characteristics of selling tips for illegal sports betting. In such circumstances, would the platform operator face relevant criminal legal risks?

 

 

 

3

 

Three Legal Red Lines for Sports Prediction Platforms: Illegal Business Operations, Gambling, and Fraud

 

Sports match prediction services have long occupied a legal gray area. This means that determining whether such services are unlawful remains highly contentious. The following analysis, grounded in judicial practice, examines the boundaries of legal risks that operators may face:

 

1. Does developing a sports prediction platform without obtaining the required licenses and qualifications constitute the crime of illegal business operations?

 

The Baoshan District People’s Court of Shanghai previously handled a case [1] in which Gong established a website without permission from the administrative department for industry and commerce, providing analysis of match outcomes, odds information, and real-time match updates for football leagues such as Serie A, the Bundesliga, Ligue 1, and the Premier League. Gong charged monthly membership fees and per-match fees. During the trial, there were divergent views on the characterization of Gong’s offense: some argued that it constituted the crime of gambling, while others held that it constituted the crime of illegal business operations.

 

The court ultimately determined that Gong committed the crime of illegal business operations on the grounds that engaging in commercial internet information services requires obtaining the relevant administrative license. By providing football betting-related information to internet users for profit without such permission, Gong disrupted the normal regulatory order of the football lottery market.

 

In light of this case, Attorney Shao raises two questions for consideration.

 

First, regarding the crime of illegal business operations:

Compared to the above case, a more common scenario in practice involves operators adopting more covert methods: they obtain relevant administrative licenses and complete registration and filing procedures, but not under the service category of “sports match prediction.” Instead, the platform publicly displays ordinary content such as cleaning services or homework tutoring to complete registration and listing on app markets. Paying readers are solicited directly by the authors, and users must actively search for the author’s name on the platform to locate the relevant content. In such circumstances, does this constitute illegal business operations?

 

Second, the crime of gambling

The court ultimately held that Gong did not constitute the crime of gambling because not all members engaged in football betting after obtaining the information; some members participated in football lottery sports betting. Therefore, it could not be proven that Gong knowingly provided information and collected membership fees, match fees, and other charges while aware that others were gathering crowds to gamble.

 

Attorney Shao believes that Chinese law does not explicitly prohibit the business model of charging fees for predicting football match outcomes, and predicting football match outcomes itself falls within the scope of freedom of speech. Expressing views on sporting events and charging fees is similar to the work of sports commentators. Precisely because of such judicial viewpoints, cases in practice where this type of model is characterized as the crime of gambling are rare. Cases where predicting sports match outcomes is characterized as the crime of gambling are typically of the following nature.

 

2. Are there any actual cases where a sports prediction platform was characterized as an "online casino"?

 

In March 2025, Legal Daily [2] reported that the Duyun City People's Court of Qiannan Prefecture, Guizhou Province, adjudicated a case involving gambling using football matches: Suo recruited gamblers by publishing football match information on WeChat Moments, engaged in gambling based on predictions of football match outcomes, set rules referencing online odds, acted as the banker, and accepted bets from others via WeChat. The court characterized this conduct as the crime of gambling.

 

In this case, the reason Suo was characterized as committing the crime of gambling rather than the crime of operating a casino was that he temporarily organized gambling sessions by posting on WeChat Moments.

 

For platform operators providing paid knowledge services for sports predictions, if they are characterized as engaging in long-term, continuous operations, attracting an unspecified majority of participants, and collecting venue fees, commissions, and other charges, they are more likely to face legal risks associated with the crime of operating a casino.

 

3. Will inaccurate predictions or fabricated track records constitute the crime of fraud?

 

If there is fabrication of expert identities, fabrication of historical track records, or failure to fulfill promised win rates, it may involve suspicion of fraud; however, if the predictions are based on genuine analysis of public data and tactical analysis, Attorney Shao believes that even if they are inaccurate, they should not constitute fraud.

 

 

 

4

 

Conclusion

 

The Constitution guarantees citizens' freedom of speech. Platform authors conducting predictive analysis of sporting events and charging fees can be regarded as a knowledge-payment business model. Since Chinese law does not explicitly prohibit such a business model, and neither the platforms nor the authors themselves engage in conduct inducing users to bet on football, engaging in such operations is not inherently non-compliant from a legal perspective.

 

However, the crux of the issue lies in the fact that if the author's content itself has an inducive nature, or if the paid content substantially exhibits the characteristics of "selling tips" for football betting, it may expose the platform to significant legal risks.


 

[1] Using the Internet to Publish Football Betting Information for Profit with Serious Circumstances Constitutes the Crime of Illegal Business Operations - China Court Net  https://www.chinacourt.cn/article/detail/2005/08/id/176506.shtml

[2] Sports Events Are Not Gambling! A Man in Guizhou Was Sentenced for Using Sports Events for Gambling  http://www.legaldaily.com.cn/Rule_of_Law_in_Guizhou/cotent/2025-03/26/content_9156110.html

 

 

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About the Author:

Attorney Shao Shiwei has long specialized in criminal defense and compliance matters in the Web3 and virtual currency sectors, accumulating extensive practical experience in economic crimes, cybercrimes, and novel cases involving virtual currencies.
He specializes in handling major, difficult, and complex criminal cases involving allegations of operating casinos, fraud, illegal business operations, and occupational embezzlement.
He provides legal services including full-process criminal defense, establishment of corporate criminal compliance systems, and prevention and control of criminal legal risks for individuals and enterprises.
Since commencing his practice, he has handled more than 300 criminal cases, with over 60 cases achieving substantive defense outcomes such as case dismissal, non-prosecution, application of suspended sentences, or reduction of charges.