Japan Again Tells MGM Osaka to Refine Its Visitor Forecasts and Plan Its Non-Gaming Spending

Japan's tourism ministry says the Osaka integrated resort still meets the required standards, but for a third year it finds the demand forecasts have only been checked, not reworked. Those forecasts still promise 20 million visitors a year, while the planned initial investment has risen by 40% since the plan was first filed.

• Japan's Ministry of Land, Infrastructure, Transport and Tourism (MLIT) has again asked MGM Osaka to refine its demand forecasts, sharpen its plans to attract overseas visitors and start working out how casino earnings will be invested in non-gaming business, in an evaluation the Japan Tourism Agency published on 9 October
• The ministry found the forecasting work had gone no further than confirming that the underlying assumptions had not changed, the same finding it made for the two previous years
• The plan still projects about 20 million visitors and about ¥520 billion (approximately $3.3 billion) in revenue a year, 80% of it from gaming, while the initial investment has risen from ¥1.08 trillion in the 2022 plan to about ¥1.513 trillion (approximately $9.5 billion)
• Construction began in April 2025 and the resort on Yumeshima is scheduled to open around autumn 2030; the review does not change that timetable
• The review lands as prefectures prepare for Japan's second licensing window, from 6 May to 5 November 2027, with Aichi the furthest advanced of the prospective hosts

The Ministry Says Osaka Is on Track but Has Not Revisited Its Numbers

MLIT has completed its annual review of Osaka's approved area development plan for the Yumeshima integrated resort (IR), run by MGM Osaka, the joint venture of MGM Resorts International and ORIX. The evaluation, dated 9 October and published by the Japan Tourism Agency under Article 37 of the IR Development Act, assesses fiscal 2025, the year to March 2026. It is the ministry's assessment, not a decision of the Casino Regulatory Commission, which licenses casino operations, and it neither approves anything new nor alters the schedule.

The ministry confirmed that detailed design was complete, construction had started and the plan still met the required standards. It recognised progress on capital from the core shareholders and on liquefaction works on the reclaimed island, and again asked Osaka and the operator to consider several outcome targets measured by objective indicators.

On the forecasts, the wording is almost identical to a year ago. The ministry said the work had stopped at confirming that the assumptions behind the estimates were unchanged, though it noted an intention to refine the data. It asked that refinement consider specific groups such as business travellers, not only aggregate demand, that assumptions be updated promptly when the market outlook shifts, and that promotion aimed at foreign visitors be made concrete. Its fiscal 2024 evaluation, published in August 2025, found the same for fiscal 2023 and 2024.

On non-gaming, the ministry accepted that with the casino not yet open there was nothing to report. It nevertheless asked for casino earnings to be invested steadily in non-casino business, having regard to the operator's finances, and for work to begin on deciding what that money will fund. It also asked for a broad customer base that does not lean on visitors of any one nationality, wording unchanged from 2025. The review noted preparations for an Osaka addiction centre and awareness work on illegal online gambling, and urged Osaka and the operator to make harm-reduction measures more effective.

The Forecasts Have Stayed Still While the Costs Moved

The plan's operating assumptions have barely shifted since it was filed in April 2022, with an opening then set for autumn or winter 2029, Asia Gaming Brief reported. For the third year of operation it projects revenue of about ¥520 billion, ¥420 billion (approximately $2.6 billion) of it from gaming, and about 20 million visitors a year, 14 million domestic and 6 million from overseas, according to the plan summary Osaka filed in July 2026.

Costs have moved. In September 2023 Osaka raised the initial investment to ¥1.27 trillion (approximately $8.0 billion) and moved the opening to autumn 2030, citing building-material prices, Asia Gaming Brief reported. In September 2025 a further notification put it at about ¥1.513 trillion, according to Osaka's published comparison of the two plans: shareholder equity rose from about ¥740 billion to ¥983 billion, borrowing stayed at about ¥530 billion, and projected third-year net profit fell from about ¥85 billion to ¥67 billion (approximately $420 million). Both were filed as minor changes, which need no fresh approval.

MGM's own line is that the project is on course. Chief executive Bill Hornbuckle described MGM Osaka in July as "the largest integrated resort in the world" and said it was "on track for 2030 opening", in the company's second-quarter results.

Three Years of Checking Is Not Forecasting

The most consequential sentence in the evaluation is the one the ministry has now written three times. The forecast of 20 million visitors and ¥420 billion in gaming revenue comes from a plan filed before Japan reopened to foreign tourists in late 2022, and before costs rose by 40%. Confirming that assumptions are unchanged is not testing whether they still hold. The ministry does not say the numbers are wrong, and with opening years away a full rebuild may be premature. But repetition makes a review requirement look like a formality, and Osaka's own plan concedes the timetable could slip by one to two years.

The Non-Gaming Question Is Really About Margin

The non-gaming request is a condition of the original approval, and the ministry ties it to the operator's finances. That matters more than it did in 2023: a resort costing ¥1.513 trillion that expects ¥67 billion of net profit in year three has less room to channel casino earnings into conference halls and attractions. The case for Japan's IR model is that gaming pays for tourism infrastructure. Until the operator says what that money will fund, the case rests on an intention, not a plan.

Osaka Is the Template the 2027 Round Will Be Measured Against

Japan's second window allows up to two more areas, and candidates are thin. Aichi wants operator proposals by 23 March 2027, the town of Oto is asking Fukuoka to bid without an operator, and Yokohama looks set to sit the round out. Any new bid will face the same review and the same annual evaluations, and a ministry that keeps asking Japan's only approved resort to firm up its demand case is signalling the scrutiny later entrants should expect on overseas visitors and non-gaming spending.

The ministry has found nothing that stops MGM Osaka, and building continues. What it has not yet seen, after three evaluations, is a forecast reworked to match a resort that now costs ¥1.513 trillion.