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The new Italian online gambling license regime not only reshapes the market but also creates a unique opportunity for licensed operators to acquire, through an ADM-facilitated procedure, the player databases of competitors that did not apply for renewal and must cease operations by 12 November 2025.
Italian Online Gambling License and the Migration Opportunity
The reform of the gambling framework set in motion a complete overhaul of the system. Following the public tender launched in December 2024, ADM admitted 46 applications for 52 licenses.
For those who did not apply for an Italian online gambling license, the transitional extension of old licenses is rapidly approaching its final deadline. According to ADM’s Determination of 24 July 2025, operators under the old regime face the following obligations:
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By 5 September 2025: they must inform ADM whether they wish to continue operating until the final cut-off date.
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By 22 October 2025: they must block all new registrations and notify players of the termination of the license.
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By 17 November 2025: they must fully cease operations, close and liquidate all accounts, and regularize any suspended accounts.
This means that the migration of gaming accounts of player databases must occur before 12 November 2025. To facilitate this, ADM has established a simplified pathway for licensed operators to acquire these player databases, ensuring continuity for players and stability for the regulated market.
The Current M&A Rush
Not surprisingly, the weeks leading up to the November deadline are seeing intense M&A activity. Licensed operators are racing to negotiate the acquisition of player databases of those who will leave the market.
For some exiting operators, this represents the only way to monetize years of investment before shutting down. For active licensees, it is a once-in-a-decade consolidation opportunity. While the opportunity is clear, time is brutally short. There are legal, technical, and commercial complexities that require immediate attention:
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Strict Deadlines: The migration must occur before mid-November 2025 which means that deals need to be closed now. The structure of the deal and in particular of the consideration is not defined by ADM, there might be a fixed fee or a revenue share such as in case of an affiliation agreement;
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Regulatory Compliance: ADM approval and adherence to data protection rules (especially GDPR) may be burdensome. Not all the accounts will be automatically migrated to the buyer of the relevant database since the migration is subject to the players’ consent. As such, the sharing of players’ data will require considerable safeguards;
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Integration Costs: Technical compatibility and customer onboarding strategies need to be carefully planned. The migration might be easier between operators that use the platform from the same vendor, but there are no regulatory restrictions in this sense.
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Reputational Factors: Players may react differently to being migrated; transparent communication is essential. The collection of their consent might require push notifications and other practices that need to be implemented in a very short timeframe and have to deal with the additional complexity given by the Italian gambling advertising ban.
Operators that wait too long may find themselves locked out of the process.
What Operators Should Do Now
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Identify Targets: Quickly map which exiting operators hold valuable databases.
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Engage in Negotiations: Approach discussions now, as competition among license holders is fierce.
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Align with ADM Procedures: Ensure all filings and notifications are made correctly to avoid regulatory roadblocks.
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Plan Player Migration: Develop strategies for seamless account transfer, balancing technical execution with customer trust.
The Italian gambling sector has historically been difficult to penetrate due to high barriers to entry and strong incumbents. The combination of a new licensing framework, forced market exits, and ADM’s simplified acquisition procedure has created a rare market shake-up.
For operators holding an Italian online gambling license, the months between now and 12 November 2025 will be decisive. Those who act swiftly can dramatically increase their market presence; those who hesitate risk missing out on the largest player migration the Italian market has ever seen.
Conclusion
The introduction of the new Italian online gambling license has triggered one of the most significant reorganizations in the sector’s history. The simplified ADM mechanism for acquiring player databases of exiting operators is not only a regulatory novelty but a strategic goldmine—available for a limited time only.
The message is clear: move fast, or lose the chance.
On the same topic, you can read the article “New Tender for Italian online gaming licenses Launched – Here are the updated FAQs!“. Also, you can access DLA Piper’s Gambling Laws of the World guide HERE and other articles on gambling law matters HERE.