/ gambling / The reduction of the Italian gaming AWPs is now approved

The reduction of the Italian gaming AWPs is now approved


A considerable reduction of Italian gaming machines, the so called AWPs, obtained the final validation with the publication of the relevant decree on the Official Gazette.

A potential reduction of AWPs (the so called Comma6A) gaming machines had been rumoured in Italy for quite a long time. This is part of the initiatives of the Italian government aimed at ensuring a better control of these machines which so far can be located in any bar, hotel, tobacco shop, with no major limitation, save for the maximum number of gaming machines that can be installed on the basis of the size of the location.

The decree ordering the reduction of AWPs

After some delays, it has now been adopted a decree which provides for a reduction of the number of AWPs to

  • 345,000 by 31 December 2017 and
  • 265,000 by 30 April 2018.

In order to achieve such goal, each concessionaire (i.e. the operators holding the so called network gaming licenses connecting the machines to the servers of the regulator) shall

  • by 31 December 2017 reduce at least by 15% the number of authorizations relating to AWPs it held as of 31 December 2016 and
  • by 30 April 2018 proceed to a further reduction in order to achieve a reduction of 34.9% of the number of authorizations relating to AWPs it held as of 31 December 2016.

Then, if the total number of authorizations held as of 30 April 2018 results to be lower than 265,000 as a consequence of the reductions outlined above, concessionaires will be entitled to apply for further authorizations.

What is the impact on the Italian gaming market?

The reduction of the number of AWPs is expected to have a negative impact mainly on small concessionaires. Also, the goal of the Government is the removal (or reduction) of the line of intermediaries (e.g. distributors, service providers etc.) between the concessionaires and the operators of the locations where AWPs are located. This is because such intermediaries are often very small entities which as such are more difficult to control and are more likely to perform illegal activities.

On the contrary, the reduction might be welcomed by larger concessionaires and operators since they will just get rid of the low performing machines and still remain profitable because they can rely on better economies of scale.

No impact on the videolottery market

The change above does not affect videolotteries (VLTs) and the reason for that is also because VLTs can be located only in gaming halls, betting shops, bingo halls and in general locations dedicated to gaming activities as opposed to AWPs that have no major restriction as to their location. Also, concessionaires paid € 15,000 per each right of installation of VLTs and therefore if the Government was willing to reduce the number of VLTs, it would have had to refund such amount which is unlikely to happen.

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IT, gaming, privacy and commercial lawyer at the leading law firm DLA Piper. You can contact me via email at giulio.coraggio@gmail.com or giulio.coraggio@dlapiper.com or via phone at +39 334 688 1147.

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