How to get ready for new Italian online gaming licenses

The upcoming Italian online gaming licenses raise the question of what can be done now in preparation of the launch of the tender by AAMS. 

The upcoming new online gaming licenses

The tender for new online gaming licenses is expected to launched very soon. But entities willing to enter the Italian online gaming market shall not just “sit and wait” since, according to the information from the regulator, the licensing terms are expected to be similar to those of the previous tender. Likewise, the regulatory environment where licenses will operate has to be the same applicable to existing operators.

This is why I published in a previous post a list of FAQs on the applicable licensing regime and the terms and price of the new licenses are indicated in this article.

What can you do right now to get ready?

The activity below can be already done to be ready for the tender:

1. Arrange the required paperwork

Especially in the case of foreign online gaming operators, it might be quite time consuming the arrangement of the necessary

  1. corporate documents, also because they need to translated in Italian, the translation needs to be certified and the documents have to be notarized and apostilled;
  2. affidavits which require the collection of signatures from the ultimate beneficial owners that can be a hard task in the case of a large number of UBOs; and
  3. bank guarantee that can be issued by a foreign bank, but needs to include a specific wording referring to Italian law which needs to be validated by them.

2. Review the technical documents and start developing the platform

The award of Italian licenses does not allow to immediately launch the platform. These are “umbrella” licenses covering all the games that can be offered online through non-exclusive licenses (i.e. scratch cards, lotto and superenalotto are excluded, but it is possible to operate as resellers of them), but the actual offering of each category of games is subject to a subsequent technical approval.

The technical approval requires the certification of the platform and games and the development and approval of the so called “protocols of communication” which are the list of messages that the platform needs to exchange in real time with the servers of the regulator and whose proper functioning needs to be verified by the Italian gaming authority, AAMS.

Based on the experience of my clients, the development of those protocols can take between 3 and 6 months, and this is why some operators decide to launch their platform using a third party that “translates” the messages originating from their servers into the language of the protocols of communication and sends them to the regulator.

3. Select you certification entity

Another time consuming practice is the certification of the platform which, based on my experience, can take at least 3 months. Even if the operator uses a casino supplier that has been already certified for other operators, it will need to certify its gaming account system and the integration between its gaming account system and the platform of the casino operator.

A time saving solution might be to purchase an integrated solution from a casino supplier which includes also the gaming account system, but then the operator is “locked” with the games of a single supplier in a market where most of the operators are offering a variety of games from different suppliers.

In order to start the process of certification, it is necessary to select the testing lab from the list available here and I suggest to get estimates from more than one of them to compare prices.

I hope this is helpful. And as usual, if you found this article interesting, please share it on your favorite social media.


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Giulio Coraggio

I am the head of the Italian Technology sector and the global head of the IoT and Gaming and Gambling groups at the world-leading law firm DLA Piper. IoT and artificial intelligence influencer and FinTech and blockchain expert, finding solutions to what's next for our clients' success.

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