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The countdown has begun: just a few days remain before the submission deadline for the Italian tender for remote gambling licenses.
This is a unique opportunity to access the EU’s largest gambling market — but time is running out to complete a fully compliant license application.
At DLA Piper, we are assisting several leading international and domestic operators as they finalize their submissions under the rules issued by the Italian Customs and Monopolies Agency (ADM).
Applicants are now focused, among others, on three particularly time-intensive and complex tasks — each of which requires coordination across legal, tax, technical, and regulatory domains.
1. Drafting the Pooling (Avvalimento) Agreement
A cornerstone of the gambling license application is the avvalimento agreement, which allows applicants to rely on the capacities of a third party to fulfill tender requirements. While the concept is familiar in public procurement, its application in this tender is particularly nuanced.
Applicants must define:
- Which services will be provided by the auxiliary enterprise;
- What infrastructure and certifications (e.g., ISO 27001 for information security or ISO 9001 for quality management) are lent;
- Which key individuals and resources will be provided to the applying entity.
These decisions are strategic in nature and must be legally formalized with clear obligations, risk allocation, and audit rights. Drafting this agreement is a major undertaking — and one that must be aligned with ADM’s expectations and Italian administrative law principles. It cannot be too generic and it cannot be amended over the course of the tender process.
Our public law and gambling regulatory teams at DLA Piper have supported numerous clients in this process, helping them structure robust avvalimento agreements that ensure legal certainty and meet the technical thresholds of the Italian gambling license tender.
2. Preparing the Investment Plan
Perhaps the most challenging aspect of the application is the Piano degli Investimenti, a document that requires not only solid business planning, but also formal appraisal of economic and financial sustainability.
This document must include:
- A detailed breakdown of revenues, costs, and margins
- Strategic investment objectives, including product expansion and market penetration plans
- A thorough risk analysis and return-on-investment forecast
- Consistency with the information provided in other technical and legal sections of the application
Given its complexity, the investment plan is not simply a business summary, but rather a document that must stand up to scrutiny by public authorities and market regulators. That’s why our clients rely on the expertise of DLA Piper’s tax and economic analysts, who work in close coordination with our legal team to ensure a credible, coherent and ADM-aligned support to clients both in drafting the investment plan and as part of its appraisal.
3. Drafting the Technical Report
The Relazione Tecnica is another critical component of the license application, composed of three main sections:
- Technical: Infrastructure design, platform architecture, cybersecurity, business continuity, and data protection
- Environmental: Sustainable operations, including efforts to minimize ecological impact and support ADM’s ESG priorities
- Human Resources: Organizational chart, roles and responsibilities, training policies, and compliance culture
Each section must be supported by specific competencies and certifications, and applicants are expected to demonstrate consistency across documents — particularly between what is promised in the avvalimento agreement and what is described in the technical report. The technical report will be evaluated by ADM that will allocate an amount of points for each document which are crucial to reach the minimum amount of points needed for the award of the Italian remote gambling license.
At DLA Piper, we work alongside clients to prepare and appraise the full set of documentation, coordinating between legal counsel, environmental engineers, HR advisors, and platform architects to produce a comprehensive and ADM-compliant Relazione Tecnica.
One Team, One Solution
The Italian tender for remote gambling licenses is a rare opportunity for operators to establish or expand their presence in a high-value, strictly regulated market. But success requires more than just compliance — it demands strategic insight, flawless execution, and a multidisciplinary approach.
At DLA Piper, we are uniquely positioned to offer an integrated, end-to-end solution:
- Public procurement and regulatory legal advice
- Tax structuring and economic analysis
- Technical drafting and ESG alignment
- Multi-jurisdictional support for international operators to better understand the nuances of their local regime and how to adapt them to Italian regulatory requirements.
With the tender deadline now imminent, there is no time to lose. Contact our team to ensure your license application is complete, compliant, and submitted on time.
On the topic, you can read the article “New Tender for Italian online gaming licenses Launched – Here are the updated FAQs!”.