Share This Article
The Italian gambling authority has published the list of entities that have been admitted to stage 2 of the license application process, which involves multiple obligations and options, within a short timeframe.
The Timing of the Italian Gambling License Application Process
The Italian gambling authority has published a list of 46 entities that have completed stage 1 of the license application process and can now proceed to stage 2 of the procedure. The above means that.
- By August 6, 2025, operators shall submit to ADM a considerable amount of additional documents, including the payment of the EUR 4 million first instalment of the one-off license fee and the bank guarantee covering the liabilities arising from the operation of the license; while
- By August 31, 2025, they will be required to execute the new license agreement related to the operation of the Italian gambling license.
Also, unless ADM comes up with a different interpretation of the applicable terms, once operators that are currently active in the Italian gambling market execute the new license agreement, they will immediately start operating under the new license which means that they will have to pay also the additional EUR 3 million of the one-off license fee.
What About Operators that Did Not Apply for a New Gambling License?
Operators that are active in the Italian gambling market under a license that has been extended on a transitional basis up to September 17, 2025, and did not apply for a new license shall:
- By July 1, 2025, send ADM an updated list of dedicated bank accounts used to hold gaming account balances, only if they have changed from those already registered with ADM.
- Starting from July 8, 2025, and then every subsequent Tuesday, send to ADM the balance and movements of dedicated bank accounts and the balance of all non-dormant gaming accounts;
- By August 17, 2025, block new registrations and new gaming account openings. Notify players of the termination of the license (set for September 17, 2025) and send the notice of termination of gaming accounts, advising of liquidation within one month of the termination of the concession.
- By September 17, 2025, cease operations and settle the balance of gaming accounts, with an additional obligation to regularize suspended accounts within one month.
In parallel, within two months of the license termination, ADM will verify the correct fulfillment of all activities, including payments to the tax authorities. In the absence of outstanding payments, the bank guarantees will be returned; otherwise, ADM may enforce the guarantees and request further compensation.
An Opportunity in a Short Timeframe
In addition to the procedure set out above, ADM also published a bulletin circular setting out a new process to facilitate the migration of gaming accounts between
- Operators that did not apply for a new license and therefore will stop operating by September 17, 2025; and
- Operators who have applied for a new license will continue to operate.
This situation presents a unique opportunity, as the migration of gaming accounts would allow players to be automatically registered on the gambling platform of the acquiring operator without undergoing a new registration process, and with the possibility of also transferring the balance of gaming accounts. In the absence of such a migration, the accounts will be closed, and therefore, the asset will be lost by operators that will cease offering games in Italy.
In the above scenario, we frequently see that exiting operators become affiliates of operators that will continue their gambling offering, accruing a revenue share on the gaming activity generated by migrated players.
What happens for operators that are willing to enter the Italian gambling market?
Operators that are willing to enter the Italian gambling market and were late in apply for a new license cannot join the tender at this stage. Besides it is unlikely that a new tender is going to be launched any time soon since the licenses that will now be awarded last for 9 years.
The sole option for these operators is to acquire the license for an operator that joined the tender. However, the good news is that the new licensing regime provides a facilitated process to transfer licenses.
Feel free to contact me if you would like to discuss the above. On a similar topic, you can read the article “New Italian Guidelines for Certification in Online Gambling: Key Changes and Open Questions“.