New Italian Guidelines for Certification in Online Gambling: Key Changes and Open Questions

The final version of the Italian guidelines on certification for online gambling systems introduce a stricter and more comprehensive regulatory framework, setting new technical and procedural standards for platform compliance.

Published on 16 June 2025 by the Italian gambling regulator ADM (Agenzia delle Dogane e dei Monopoli), the guidelines redefine how testing labs must assess and certify systems used by licensed operators to which operators that will be awarded with new licenses will be subject.

Here are the most relevant changes—and the grey areas still awaiting clarification:

Key relevant changes

1. Broader Scope of Certification

The guidelines now cover the full lifecycle of the online gambling system, including front-end/back-end platforms, RNGs, account systems, and integrations. Every component involved in player interaction or data exchange must be certified.

2. Stronger Responsibilities for Testing Labs

Testing labs must:

• Keep logs, hashes, and source references;

• Inspect source code where necessary;

• Independently test modular components in a production-like setup; and

• Assess compliance of operators in relation to each requirement.

The latter change is the most relevant since the Italian gambling authority outsourced to testing labs the full compliance assessment process which will oblige them to considerably increase the amount of work they will have to perform.

3. Disaster Recovery Standards

It is provided that

• Data replication must occur within 120 seconds; and

• Disaster recovery sites must be geographically distinct but always within the EEA.

Certification requires verification of full disaster recovery processes.

For both the technical platform and the disaster recovery system it is allowed to use cloud platforms, but they need to be provided by an entity that is enrolled in the registry of the Italian Cybersecurity Agency (Agenzia per la Cybersicurezza Nazionale).

4. Real-Time Data Reporting

• Game transactions, bonuses, and outcomes must be transmitted in real time to ADM systems.

• Every step of the game flow must be traceable and certifiable.

5. Transition to New Licenses

A new section addresses how testing labs should manage:

• Migration of existing platforms to those run under the new licenses when the new technical requirements are in place;

• Temporary reuse of certified systems; and

• Risk-based evaluation approaches for transitional certification.

Grey Areas in the Italian Gambling Guidelines

Despite the improved structure, several unclear aspects of the certification process remain. These grey areas should be addressed to ensure consistent implementation:

1. Are open-network game and jackpot models shared between operators still allowed?

2. Are jackpots seeded with operator-funded amounts still compatible with ADM’s updated certification rules?

3. Is the offering of live casino games still permitted?

4. how shall the transition between different responsible gambling thresholds of for instance self exclusion be handled?

5. What technical methods must be applied to validate software integrity during certification?

What’s Next?

These final Italian guidelines for certification bring new burdensome obligations. Furthermore, the presence of operational ambiguities—especially on topics like jackpots, demo games, and data flows—means that further guidance from ADM is likely.

Operators, suppliers, and testing labs alike should begin preparing now for full technical compliance under the updated framework. Our team at DLA Piper is assisting clients with gap assessments, roadmap planning, and engagement with the regulator. Read more articles on gambling law matters HERE and if you want to have an overview of the gambling laws in different jurisdictions, you can read DLA Piper’s Gambling Laws of the World Guide.