Italy Gambling Top-up Shops Rules: What the Administrative Supreme Court Has Changed

The Italian Administrative Supreme Court, the Consiglio di Stato, has changed the regulatory framework for gambling top-up shops in Italy, known as Punti Vendita Ricariche or PVRs.

In its judgment No. 7220/2026, published on 30 September 2026, the Court annulled the general prohibition preventing PVRs from making computers and other internet-connected devices connecting to gambling sites available to customers. At the same time, it confirmed the €100 weekly limit for certain recharges and the prohibition on withdrawals from gaming accounts at PVRs.

The decision is therefore relevant for online gambling operators, concessionaires and the businesses forming part of their retail networks.

What are gambling top-up shops in Italy?

Punti Vendita Ricariche, or PVRs, are physical retail outlets such as tobacco shops, bars or newspaper shops connected to online gambling licensed operators. They allow customers to perform certain services relating to their online gambling accounts, including opening an account and making deposits to the gaming accounts.

PVRs have become an important connection between Italy’s online gambling market and its physical retail network, also in the light of the gambling advertising ban since they allow to create a personal connection between the operator and the relevant players. PVRs are gambling affiliates that can move a very large number of players from an operator to another and have become an essential component of the local strategy of several operators in the Italian gambling market.

The regulatory framework for PVRs was introduced by Article 13 of Legislative Decree 41/2024 and implemented by the Italian gambling authority (Agenzia delle Dogane e dei Monopoli, ADM) through its determination of 25 October 2024.

The latest judgment follows litigation brought by operators challenging several elements of the new PVR framework. I previously discussed one of the most relevant restrictions in Italy Gambling Top-Up Rules: Why Cash and Vouchers Now Hit a €100 Weekly Wall. The Administrative Supreme Court has now provided further clarification.

Internet points can also operate as PVRs

The most significant part of the judgment concerns internet points. ADM’s rules had prevented PVRs from making computers, tablets, totems and other internet-connected equipment available to customers where those devices could be used to access online gambling services.

This opportunity grants a major advantage to gambling operators since such devices can be used to make deposits, place bets, play casino games, and perform withdrawals. The reason why ADM prohibited their operation is that they would actually work in a manner similar to a betting shop, without holding a betting shop license.

The Consiglio di Stato annulled the prohibition. According to the Court, the general prohibition effectively excluded internet points from the possibility of operating as PVRs simply because they made internet-connected equipment available to their customers. The Court considered that restriction disproportionate in light of the regulatory objectives pursued by ADM.

This is particularly significant because the Court also considered the reasoning of the Constitutional Court in its earlier judgment concerning restrictions on internet-connected devices in gambling premises. The decision does not mean that internet points can freely provide gambling services without restrictions. ADM retains regulatory powers and could introduce more targeted restrictions, provided that they remain within the applicable legal framework and are proportionate to the objectives pursued.

For operators, however, the practical consequence is important: an internet point cannot be excluded per se from the PVR network merely because it makes internet-connected devices available to customers.

PVRs still cannot work as betting shops without a license since that would be in breach of criminal laws, but a greater level of flexibility is granted to their operation.

The €100 weekly limit remains

The Administrative Supreme Court reached a different conclusion concerning the €100 weekly limit on certain PVR recharges. The Court confirmed the restriction for cash and the other payment instruments covered by the relevant provision. It also clarified that the €100 ceiling does not constitute a universal limit on every possible method of funding an online gambling account.

This distinction matters for online gambling operators because the rule is linked to the method used to recharge the gaming account. The Court rejected the operators’ challenges concerning, among other things, the level of the limit, its economic impact and the possibility that the restriction could encourage customers to turn to illegal gambling.

The judgment also confirms that operators must use their systems to ensure that the weekly limit is respected, including where customers use different PVRs within the same network.  This scenario creates an important operational responsibility for operators because compliance with the €100 limit cannot be assessed solely at the level of an individual retail outlet.

Withdrawals remain prohibited

The judgment also confirms that customers cannot withdraw funds from their online gambling accounts through PVRs. The operators had challenged this restriction, but the Court rejected the argument that withdrawals should simply be treated as another ancillary service that PVRs could provide. The distinction between recharging an online gambling account and withdrawing funds therefore remains relevant under the current PVR framework.

For gambling licensed operators, this means that the latest judgment creates greater flexibility concerning the equipment that can be made available at PVRs, while maintaining important restrictions on the financial services that those outlets can perform.

What about operators that were under technical extension?

The judgment also addresses the transitional application of the PVR rules. The Administrative Supreme Court confirmed the position reached by the lower court (the TAR Lazio) concerning concessionaires operating under technical extensions.

ADM could not simply apply the new PVR regime and the related registration requirements to operators and their connected retailers before the conclusion of the tender procedure for the new gambling licenses. The new concessions were subsequently awarded and became operational, meaning that the PVR framework is now fully in operation.

This part of the judgment is particularly relevant when considering the relationship between regulatory changes and existing concession arrangements.

What does the judgment mean for gambling operators?

The decision gives operators a clearer picture of where the boundaries of the PVR regime currently lie:

1. Internet points cannot be excluded simply because they provide internet-connected equipment, this scenario grants a massive opportunity to operators that however need to make sure that PVRs do not operate as betting shops since this conduct might be challenged;
2. The €100 weekly limit remains applicable to the specified recharge methods, but the position of ADM is now more flexible and allows the usage of vouchers above the limit as covered in the article in the footer;
3. Withdrawals through PVRs remain prohibited, but PVRs might make available devices to process them.

For online gambling concessionaires, this means that the judgment should be considered not only from a regulatory perspective but also when reviewing the structure and operation of their retail networks and their strategy.  The technical implementation of the €100 limit, the controls applied across different PVRs and the services made available to customers all need to be assessed against the current framework. More broadly, the decision is another example of how quickly the Italian gambling regulatory framework is evolving. Rules governing the relationship between online gambling operators and physical retail outlets are increasingly affecting the technology, payment processes and commercial models used by concessionaires.

For operators active in Italy, the next question is therefore practical: how is your Italian strategy adjust to the new regulatory framework?

Related reading: Italy Gambling Top-Up Rules: Why Cash and Vouchers Now Hit a €100 Weekly Wall