Share This Article
Italy’s 2027 Budget Law is shaping up as the vehicle for the most significant changes to the land-based gambling sector since the reorganisation reform stalled.
According to industry reports, the government is considering measures on the duration of land-based concessions (AWP, VLT, betting and bingo), on the technical and tax parameters of gaming machines, and on instant lotteries, Lotto and SuperEnalotto. None of these measures has been formally approved. Their inclusion in the 2027 Budget Law still requires confirmation, and the text may change substantially during the parliamentary process. Even so, the direction of travel is clear enough for operators, manufacturers and investors to begin planning now, rather than reacting once the law is published in late December.
Uncertainty is now the defining feature of the Italian retail market.
1. Why the 2027 Budget Law has become the default route for gambling reform
The government intended to reorganise land-based gambling through a legislative decree under the fiscal delegation law. That plan collapsed this summer: after the Prime Minister’s office rejected the draft Land-based Gambling Reorganisation Decree, it was confirmed that the reform was no longer on the government’s legislative agenda for this year.
The draft decree had set out a complete new model. It provided for gaming machine lots of 4,000 AWPs and 900 VLTs with a starting bid of €25 million, retail betting licences in blocks of 25 at €60,000 each, 100-metre distance requirements from schools and hospitals, and an €80 million revenue-sharing allocation for the regions. The sticking points were the ones that have blocked every previous attempt:
- the geographical distribution of gambling venues between State and local authorities;
- minimum distances from sensitive locations;
- limits on operating hours.
With the current concessions due to expire on 31 December 2026, the 2027 Budget Law is the only realistic instrument left to secure business continuity and protect tax revenue.
2. Extension of land-based gambling concessions until 31 December 2029
The most likely measure is a three-year extension of land-based concessions, from 31 December 2026 to 31 December 2029. The extension would cover:
- AWP and VLT concessions;
- betting shops and betting corners;
- bingo halls.
A further extension is a highly plausible scenario. Stopping operations at expiry would expose operators to a market shutdown and the State to a substantial loss of revenue, and neither outcome is politically acceptable.
The open questions concern the conditions. In past rounds, extensions have typically come with a price for concessionaires, in the form of additional fees or revised obligations, and there is no reason to expect a free ride this time. The duration itself could also be shorter than three years if the government decides to relaunch the reform sooner.
From a legal standpoint, repeated extensions are not risk-free. The Court of Justice of the EU, in case C-517/20, already called the practice of extending concessions into question, and the industry association AGIC has warned that repeated extensions have left the retail market without long-term certainty for almost a decade, discouraging investment and slowing modernisation.
What this means for concession holders:
- Business plans and financing covenants tied to the 2026 expiry date should be reviewed against a 2029 scenario, and against a shorter one.
- The likely extension fee should be modelled now, so that it does not become a surprise cost in the 2027 accounts.
- Contracts with points of sale, platform providers and machine suppliers should be checked for termination clauses linked to the concession term.
- Any M&A transaction involving land-based assets will need valuation assumptions that reflect a short and uncertain residual concession life.
3. New AWP and VLT rules: payout, PREU and technical requirements
The second area of change concerns the technical and tax framework for gaming machines, with AWPs at the centre of the debate. The topic returned to the table at the ACADI Forum on 7 October 2026, where regulators and industry stakeholders discussed several proposals to support land-based gaming pending the broader reform.
The main proposals are the following.
- Next-generation AWPs. New machines with updated technology, enhanced monitoring systems and additional player protection features would be developed and tested.
- Higher payout rates. The percentage of stakes returned to players would be revised upwards to make land-based gaming more competitive against online and illegal offerings.
- Lower PREU. The Prelievo Erariale Unico (the single gaming tax on machines) would be reduced alongside the payout increase, to rebalance the economics of the sector.
- A new AWP category proposed by SAPAR. This machine would combine a 70% payout, a 20% PREU rate and a maximum prize of €200.
- Stronger player protection. Information messages and additional responsible gambling features would be introduced.
Mario Lollobrigida, Director of the Gaming Directorate at the Agenzia delle Dogane e dei Monopoli (ADM), confirmed that the regulator intends to put forward a technical proposal to raise payout rates while reducing PREU. When the regulator and the industry converge on the same mechanism, change becomes far more likely.
The technical specifications, the final tax and payout parameters and the implementation timetable remain open.
What this means for manufacturers and operators:
- Manufacturers should start scoping product development and type-approval workstreams for a new AWP category, since a regulatory window of this kind rewards those who are ready first.
- Operators should run sensitivity analyses on margins under different payout and PREU combinations, because a higher payout with a lower tax does not automatically produce the same net result for every business model.
- A replacement cycle for the installed base would raise questions on the allocation of costs between concessionaires, operators and venues, which are usually governed by contracts drafted for a very different framework.
- Enhanced monitoring features will involve player data processing, and GDPR compliance should be designed into the machines from the outset (see [link to gamingtechlaw.com article on privacy in gaming]).
4. Scratch cards: a possible €1 billion concession tender
The concession for national instant lotteries (Gratta e Vinci), currently held by Lotterie Nazionali, expires in September 2028. In anticipation, the Ministry of Economy and Finance could launch a new tender with an estimated starting value of approximately €1 billion.
Industry reports suggest that the government intends to keep the single-concessionaire model. There are no concrete signs of a move to a multi-concessionaire structure, which would have opened the market to new entrants.
What this means for potential bidders:
- Consortia and financing structures for a tender of this size take many months to assemble, and preparatory work should begin as soon as the tender terms emerge.
- Any challenge to the tender design (for instance on the choice of a single concessionaire, or on access requirements) is most effective at the publication stage, not after the award.
5. LAN gaming centres: extension or a stricter regime
LAN gaming centres, which provide video gaming and eSports facilities, have operated for years in a grey area over the classification of their equipment and whether it falls within the rules on amusement machines without cash prizes. The transitional regime for certain categories of these machines currently runs until 31 December 2026.
According to industry reports, the government is weighing two options:
- a further extension of the transitional arrangements;
- a specific and more stringent framework for LAN centres and their equipment.
The second option would impose new obligations, but it would also end a long period of legal uncertainty. In my experience, operators in this space often prefer clear rules, even demanding ones, to an indefinite transitional regime that makes investment decisions difficult to justify. The eSports angle is covered in more detail in [link to gamingtechlaw.com article on eSports regulation in Italy].
No official details on the content of a new framework have emerged so far.
6. Lotto and SuperEnalotto: an online levy and additional draws
Two further measures are reported to be under consideration.
- An additional levy on online Lotto. No information is available on its scope, its taxable base or who would bear the cost. The proposal is at a preliminary stage.
- An additional draw for Lotto and SuperEnalotto. The aim would be to increase turnover and tax revenue. Implementation would require specific regulatory measures on procedures and timing, and no revised draw schedule has been announced.
These measures fit a broader pattern: the gambling sector remains a reliable source of revenue whenever the Budget Law needs to find resources. Other proposals point the same way, such as Senator Paolo Marcheschi’s Bill 1902, which would introduce a 2% tax on all football bets, retail and online, from 1 January 2027.
7. Practical recommendations for gambling operators ahead of the 2027 Budget Law
The 2027 Budget Law will be presented in the coming weeks and approved by the end of December, leaving operators very little time between publication and entry into force. The following steps are advisable now.
- Map exposure. Identify every concession, contract and financing arrangement linked to the 31 December 2026 deadline.
- Model scenarios. Prepare financial projections for a 2029 extension, a shorter extension and the likely cost of an extension fee.
- Engage early. Trade associations and the parliamentary process offer real room to influence the final text, particularly on payout and PREU parameters, but only before amendments close.
- Prepare the product pipeline. Manufacturers and operators should be ready to move quickly once the technical specifications for next-generation AWPs are published.
- Monitor the tender calendar. The scratch card tender, and eventually the land-based tenders, will open opportunities that reward preparation.
The regulatory framework for AWP and VLT machines could change substantially within months, both on concessions and on the economics of each machine. Companies that treat the 2027 Budget Law as a planning exercise, rather than waiting for the final text, will be in a much stronger position to protect margins and identify opportunities.
Read additional gambling law related articles HERE and don’t miss DLA Piper’s Gambling Laws of the World.

