Gaming Law 2025 Comparisons

The legal gaming market is constantly growing in Italy. In 2024, the total gambling revenue was EUR157.45 billion, marking a 6.59% increase compared to the previous year. The gross gaming revenue (GGR) was EUR21.577 billion in 2024 – a 4.38% increase compared to the previous year. 2024 saw a slight decrease in tax revenues of 0.6% compared to 2023.

The data indicates a negative change for the AWP (amusement with prizes) and totalisator number games sectors, which saw a slight reduction in gaming volume. In the online betting sector and in the remote skill games sector (casino games, cash games, etc), however, there was a clear increase in the volume of gaming – with a corresponding increase in tax revenues (by 18.14% and 16.73% respectively).

Recent Changes

In 2024, a very important reform for the gaming and betting sector was approved, with Legislative Decree No 41/2024 containing “provisions regarding the reorganisation of the gaming sector starting with remote/online gaming” (passed under the broader tax reform framework of Delegation Law No 111/2023). Article 1 of Legislative Decree No 41/2024 states that “the provisions of this decree constitute the primary regulatory framework for the regulation of legal public gaming in Italy”. Legislative Decree No 41/2024 aims to reorganise the whole public gaming sector – particularly the online sector – by focusing on, among other things:

• the public tender for the online/remote public gaming concessions expiring on 31 December 2024 and, in the meantime, the extension of the old concessions until 12 November 2025 – ensuring service continuity pending new assignments (see 4.4 Availability of Licences);
• redefinition of concession fees for online gaming operators (see 4.8 Application Fees), as follows:
1. a “one-off fee” of EUR7 million for the concessionaires;
2. an “annual fee” of 3% of the net revenues of each concessionaire; and
3. an “annual fee” of 0.2% of the dealers’ net revenues for information and communication campaigns to combat gambling addiction;
• new rules for points of sale and recharge (PVR);
• greater player protection and measures to combat gambling addiction;
• adoption of advanced technological tools (such as AI) to monitor gaming activities and prevent illegal behaviour;
• more stringent requirements for obtaining authorisation from the Customs and Monopolies Agency (Agenzia delle Dogane e dei Monopoli, or ADM) (see 4.6 Application Requirements);
• a strong limitation on the use of cash (limited to EUR100 per week); and
• the reaffirmation of the protection of minors and the fight against pathological gambling problems including deposit limits, spending warnings, session duration notices, self-exclusion tools, and a general obligation to invest in information and awareness campaigns.

The State Budget Law of 2025 (Law No 207/2024) (the “2025 Budget Law”) contains, among other things, the following new provisions regarding the gaming and betting sector: 

• the extension until 31 December 2026 of all concessions originally expiring on 31 December 2024 ‒ for example, bingo, bets on sporting events (including horse race betting) and non-sporting events (including simulated events), and concessions for the construction and operation of telematic gaming management networks using entertainment machines pursuant to Article 110, paragraph 6 of the Consolidated Law on Public Security (Testo Unico delle Leggi di Pubblica Sicurezza, or TULPS) (AWP machines and video lottery terminals (VLTs));
• an exemption from the ban on transferring bingo hall premises during the concession extension period – referred to in Article 1, paragraph 636, letter c of Law No 147/2013 ‒ for concessionaires who are unable to maintain the availability of the premises owing to force majeure, proven economic hardship, or circumstances not attributable to the concessionaire;
• an annual fee of EUR94 million authorised for Pathological Gambling Addiction (Gioco d’Azzardo Patologico, or GAP) Fund.

Online gambling has been regulated in Italy by a series of laws since the late 1990s.

The Decree of the Ministry of Finance No 174/1998 laid down rules for the organisation and operation of totaliser betting and fixed-odds betting on sports competitions organised by the Italian National Olympic Committee (Comitato Olimpico Nazionale Italiano, or CONI), as well as opening up new electronic and telephone-based methods of placing bets.

With Law No 266/2005 (the “2006 Budget Law”), the ADM was entrusted with the task of regulating the online gaming sector; as a result, all sites that did not have the necessary permissions were banned.

Law Decree No 223/2006 (the “Bersani Decree”), converted into Law No 248/2006, was especially important for the legalisation of online betting. It created a regulatory framework that allowed operators to offer online sports betting in Italy, but only if they held a “licence” issued by the ADM.

Article 24 of Law No 88/2009 (the “Community Law 2008”) contains provisions regarding the operation and collection of online games. These provisions reiterate the principle that online games can only be offered by authorised dealers according to the procedures defined by the ADM. Law No 88/2009 (also known as the “Abruzzo Law”) legalised online poker and casino games.

The sector was reorganised more recently by Legislative Decree 41/2024 (see 1.1 Current Outlook and Recent Changes). The decree lists the types of online public gaming that are permitted, which are:

• fixed-odds betting and totaliser betting on sporting events (including horse racing);
• bingo;
• games of skill, including card games in tournament mode and in non-tournament mode, as well as fixed-odds games of chance;
• fixed-odds betting with direct interaction between players;
• national totaliser number games;
• fixed-odds number games;
• instant or deferred draw lotteries; and
• further games played in virtual or digital mode (including via the metaverse) that are established and regulated by regulation.

Online Betting

As previously mentioned, the Bersani Decree opened up the online gaming market by creating a regulatory framework that allowed operators to offer online sports betting in Italy, albeit only if they held a “licence/concession” issued by the ADM. The Bersani Decree introduced more detailed rules for sports betting and remote gaming – namely:

• mandatory state licensing for online offerings;
• technical controls on gaming systems; and
• mandatory transaction traceability.

The above-mentioned Legislative Decree No 41/2024, implementing Delegated Law No Law 111/2023, introduces a general reorganisation of digital betting and gaming with new rules (see 1.1 Current Outlook and Recent Changes).

Online Bingo

Online bingo was officially regulated by the Community Law 2008, which established the requirement for a “licence/concession” for operators wishing to offer bingo online. Subsequent ADM decrees have regulated various aspects of online bingo.

Online Casinos

Online casinos were also regulated for the first time in Italy by the Community Law 2008, which established that they could operate in Italy only on the basis of a concession issued by the ADM following a public tender. Subsequent decrees (in particular, the Ministerial Decree of 10 January 2011) established some specific rules to offer online casino games – namely:

• the requirement for ADM authorisation/concession;
• ADM controls on gaming systems; and
• licensing requirements for operators.

Lotteries

Article 24, paragraphs 11–26 of the Community Law 2008 also introduced the regulation of instant lotteries. Explicitly, paragraph 12 provided for the adoption of “specific provisions regarding the general gaming conditions, including for remote collection of deferred lotteries”.

Subsequently, Directorial Decree No 2011/17476/Giochi/LTT established a provision defining the technical characteristics for the collection of lottery bets through remote channels (internet, mobile phones, etc).

In Italy, there are three types of lotteries, which are distinguished according to the frequency of the awarding of prizes:

• instant lotteries (ie, “Scratch and Win”) – the prizes of which are paid immediately;
• regular draw lotteries – such as the Lotto game, which has a twice-weekly draw (on Wednesday and Saturday mornings), and its derivatives (SuperEnalotto, etc); and
• national lotteries (eg, the “New Year’s Lottery”) – the draws of which take place on an annual basis.

These are entrusted to single dealers authorised by the ADM or managed directly by the State.

Fantasy Sports

In Italy, there is no specific legislation for fantasy sports, which are regulated by the ADM. The regulatory framework is the same as that applicable to all online games/betting and includes the Bersani Decree (later converted into Law No 248/2006), which regulated remote games of skill.

Moreover, regulation of gaming in the fantasy sports sector varies depending on whether the game is classified as betting or as a game of skill, as follows.

• If the game is classified as a bet, an ADM licence/concession is required, along with compliance with AML regulations, player verification, age limits, etc.
• If the game is classified as a remote game of skill, it must be regulated according to the applicable ADM regulations and the key legal requirement is that skill prevails over randomness.

In both cases, the general rules set forth by current industry legislation apply: minimum age of 18 to participate, protection of minors, responsible gaming, and self-exclusion systems.

Social Gaming

The regulation of “social gaming” in Italy is not yet fully defined by specific dedicated laws and regulations. Instead, games played for fun without monetary prizes (often on apps or social networks) fall under the general principles of gaming and online gaming regulation.

Online Poker

With the Bersani Decree (converted into Law No 248/2006), remote games of skill with cash prizes were legalised, as previously mentioned. These include online poker, but only in tournament format (no cash games), with a limited draw and a predetermined prize pool.

The possibility of offering online poker in cash game mode was introduced by the Community Law 2008 ‒ which, as previously mentioned, authorises remote casino games – and by the related Autonomous Administration of State Monopolies (Amministrazione Autonoma dei Monopoli di Stato, or AAMS) (now the ADM) Decree of 10 January 2011 (“Regulations on Games of Skill and Remote Casino Games”), which officially introduced online “cash” poker (effective as of 18 July 2011) by establishing technical requirements for platforms and operators, including that:

• online platforms must use certified servers, anti-fraud controls, player identity verification, and direct connection to ADM systems; and
• only sites with the “.it” top-level domain and the “ADM logo” are authorised – therefore, all other sites (.com or foreign sites without a licence) are prohibited and blacklisted by the ADM, with access blocked in Italy and fines ranging from EUR20,000 to EUR50,000.

Online poker is also subject to the rules contained in Italian gambling legislation, particularly in Legislative Decree 231/2007 (AML regulations), Law 96/2018 (the “Dignity Decree”) and Legislative Decree 41/2024. These rules include:

• requirement for all cash flows to be traceable;
• prohibition of the use of cryptocurrencies or anonymous payment methods; 
• registration of players through provision of an identity document (KYC);
• minimum age of 18 for players;
• the option to exclude onself from gaming through the ADM’s national self-exclusion register (Registro Unico degli Autoesclusi, or RUA);
• daily and monthly deposit limits set by the user; and
• monitoring to prevent “pathological gambling”.

Electronic Sports

As yet, with regard to electronic sports (“esports”) competitions, Italy does not have a comprehensive law that recognises esports as a national sporting discipline (ie, under the aegis of CONI) with all the rights and obligations of traditional sports. Therefore, esports are subject to sector-specific regulations within some sporting bodies ‒ for example, the Italian Automobile Club (Automobile Club d’Italia, or ACI) published its “2023 ESports Sector Regulations”, which addresses matters such as memberships, registrations, and competition methods (online, onsite, blended) in the field of sim racing.

The Italian Esports Association (IEA) has a “Regulations” section expressing its commitment to promoting adequate regulation for the Italian esports ecosystem.

As regards esports betting, the ADM has considered video game competitions as “non-traditional” or “simulated” events in the context of betting since at least 2016.

The “Esports Legal Manifesto” by the Italian Esports Observatory (Italiano Esports Osservatorio, or OIES) highlighted many of the sector’s critical issues and proposed solutions in terms of definitions, reporting requirements, prize pool guarantees, and restrictions for minors.

The legal gaming market in Italy is structured into two segments:

• “public gaming” managed by the State through the ADM; and
• the activity of authorised private and corporate gaming houses and casinos (Sanremo, Campione d’Italia, Venice and Saint Vincent), as well as joint stock companies whose capital is held by the granting administrations (regions, provinces or municipalities).

The legal land-based games are:

• sports betting and horse race betting;
• poker;
• bingo;
• lotteries (Lotto, SuperEnalotto, national lotteries, Scratch and Win, etc); and
• AWP machines (under Article 110, paragraph 6a of TULPS), VLTs (under Article 110, paragraph 6b of TULPS) and amusement machines without cash prizes (Article 110, paragraph 7 of TULPS).

The main EU and Italian regulatory frameworks that govern land-based gambling in Italy are those that apply to the gaming and betting sector in general (see 3.1 Key Legislation).

Betting

Until 1998, the only legal bets in Italy were Totocalcio (an Italian football pool) bets and horse race bets, which were managed by the State through CONI and the Italian Horse Breeding Association (Unione Nazionale per l'Incremento delle Razze Equine, or UNIRE) respectively.

Legislative Decree No 504/1998, among other things:

• officially recognises sports betting as a legal activity under state control;
• grants the State – through the ADM – the power to issue concessions for the management of agencies;
• introduces taxation on betting (a flat tax); and
• establishes that bets can only be collected through authorised dealers.

From this moment on, licences for the collection of bets in physical locations were granted to private entities (agencies, betting shops, bookmakers). The first “betting agencies” or betting shops, electronically connected to the AAMS/ADM system, were also established.

Poker

Land-based poker is legal in Italy only if:

• it is organised according to public gaming regulations and under the supervision of the ADM and takes place in casinos with a valid ADM licence (ie, the casinos of Venice, Sanremo, Saint-Vincent, and Campione d’Italia);
• it is a sports poker tournament (nominal entry fee, non-cash prizes);
• it is played in clubs affiliated with sports federations or non-profit cultural associations; and
• it falls under the category of games of skill with no cash prizes.

All other forms (cash games or unauthorised tournaments) are considered illegal gambling and, as such, prohibited under Articles 718 to 722 of the Italian Criminal Code and Article 110 of TULPS.

Organising or participating in unauthorised gambling may result in:

• a penalty of up to six months in prison or a fine of up to EUR516 (Article 718 of the Italian Criminal Code);
• if the organisation is a stable or profit-making organisation, a penalty of up to three years in prison and confiscation of funds; or
• possible administrative closures and licence revocation.

Bingo

The game of bingo was introduced in Italy by Law No 133/1999, providing for the establishment of bingo halls. Bingo is also regulated by Ministerial Decrees No 29/2000, No 12/09/2000 and No 21/11/2000, which defined the centralised control of the game and its assignment under concessions.

Bingo concessions are granted by the ADM to bingo halls that meet all the safety standards and player privacy protection requirements. Bingo concessions last six years and can be renewed only once.

Casinos

In Italy, land-based casinos (Campione d’Italia, La Valleè, Sanremo, and Venice) operate under special derogations from the general ban on gambling set forth in Articles 718 to 723 of the Italian Criminal Code. These exceptions are authorised by special laws, such as Royal Decree No 3754/1936 for Sanremo and Royal Decree No 2448/1927 for Saint-Vincent).

General gambling regulations also apply to casinos, specifically:

• Articles 86, 88, 110, and 191 (Ministry of the Interior’s jurisdiction over gambling establishments) of TULPS;
• Legislative Decree No 231/2007 (AML legislation);
• Law No 266/2005 and Law No 88/2009 (prohibition of gambling for minors under 18 years of age).

Many operating rules (hours, internal regulations, limits, controls) are defined by the regions (Valle D’Aosta for Saint-Vincent) or municipalities (Sanremo and Venice).

Casinos do not pay the single withdrawal tax (prelievo erariale unico, orPREU) on gaming revenue (see 12.1 Tax Rate by Sector) as per “external” VLT/slot machine halls. However, they have a specific tax regime, comprising:

• entertainment tax (imposta sugli intrattenimenti, orISI), established by Presidential Decree No 640/1972);
• tax agreements with the ADM and the Ministry of Economy and Finance (MEF); and
• municipal and regional taxes.

Gaming Machines

Amusement machines are regulated by Article 110 of TULPS (and subsequent amendments). Paragraph 3 of Article 110 states that “the installation of the machines referred to in paragraphs 6 and 7 is permitted exclusively in commercial or public establishments or in areas open to the public, or in private clubs and associations authori[s]ed pursuant to Articles 86 or 88, or limited to the machines referred to in paragraph 7, in travel[l]ing entertainment activities authorised pursuant to Article 69, in compliance with the technical and administrative requirements in force”.

These devices are divided into:

• new slot/AWP machines (Article 110, paragraph 6a of TULPS and subsequent amendments);
• VLTs (Article 110, paragraph 6b of TULPS)
• amusement machines with no cash prizes (Article 110, paragraph 7 of TULPS).

For the installation of AWP machines, the following are necessary:

• permission/licence issued by the police (Article 86 of TULPS);
• connection to an operator or ADM dealer;
• a suitable location that complies with local regulations;
• compliance with regional and municipal regulations regarding distance metres (minimum distances from schools, churches, hospitals, etc), time limits, and restricted areas;
• subjective requirements of the owner (anti-mafia requirements, regular contributions/certificate of social security compliance (documento unico di regolarità contributiva, or DURC), and the absence of any criminal convictions);
• moral requirements of the owner (for a police licence); and
• compliance with the maximum number of AWP machines per location (ie, between two and four AWP machines in bars, a maximum of two in tobacconists, and a greater number – depending on local regulations – in gaming halls)

To install a VLT, it is necessary to:

• be connected to an ADM VLT licensee (Lottomatica, Sisal, Gamenet-Intralot,Snaitech, etc);
• have a police licence (Article 86 of TULPS);
• have premises certified by the ADM and compliant with local regulations;
• have a municipal business licence;
• demonstrate fulfilment of all subjective and anti-mafia requirements.

VLTs can only be present in:

• dedicated VLT halls (certified gaming halls);
• bingo halls; and
• betting shops/horse racing venues if authorised by the licensee.

In Italy, gambling is prohibited unless it is authorised by the State. In fact, Article 718 of the Italian Criminal Code punishes with imprisonment for no less than three months and a fine no less EUR260 “whoever, in a public place or place open to the public, or in private circles of any kind, holds gambling or facilitates it”.

Therefore, in Italy, a “State reserve” exists for the organisation of legal public gaming. In this regard, Article 1 of Legislative Decree No 496/1948 established that “the organisation and operation of games of skill, betting, and prediction contests, for which a reward of any kind is paid and for which participation requires the payment of a stake in money, are reserved to the State”. Article 2 of Legislative Decree No 496/1948 establishes that such activities “are entrusted to the Ministry of Finance, which may manage them either directly or through natural or legal persons who provide adequate guarantees of suitability”.

Consequently, given the flexible nature of the State’s reserve for gaming and betting pursuant to Legislative Decree No 496/1948, the Italian model for operating public gaming with cash prizes is based on:

• the concession issued by the ADM after a public tender (see 4. Licensing and Regulatory Framework); and
• the licence pursuant to Articles 86 and 88 of TULPS issued by the police headquarters or the mayor for the authorisation to open and manage the physical premises (halls, betting shops, bars, tobacconists, etc) in which the game is played (see 4.10 Personal Licensing).

The normative sources that regulate the legal public gaming in Italy are:

• EU Regulations and Directives;
• Articles 718 to 723 of the Italian Criminal Code;
• Articles 1933 to 1935 of the Italian Civil Code;
• Articles 86, 88 and 110 of TULPS;
• ordinary state laws:
• presidential and ministerial decrees;
• regional laws and municipal regulations; and
• ADM regulations and guidelines.

The Italian Civil Code distinguishes between:

• lawful betting (ie, poker, roulette, etc), for which there is no legal action for the payment of a gambling or betting debt, even if the gambling or betting is not prohibited, unless the debtor proves that they have suffered fraud or are incapable (Article 1933);
• protected betting, such as horse racing and sports betting (Article 1934) and authorised lotteries (Article 1935), for which there is legal action.

Articles 86 and 88 of TULPS contain rules regarding licences for gaming and betting. Article 110 of TULPS contains rules regarding licences for amusement machines (AWP machines/VLTs). For further details, please refer to 4.10 Personal Licensing.

Law No 401/1989 introduced measures to address illegal gambling and betting and to ensure fair play at sporting events.

Article 3, paragraph 230 of Law No 549/1995 (the “Financial Law 1996”) established that “the organi[s]ation and exercise of totali[s]er and fixed-odds bets reserved to CONI on sports competitions organi[s]ed or carried out under its control can be entrusted in concession to single operators or companies that offer adequate guarantees”. It also vested the MEF with the power to issue the relevant regulations/decrees.

As mentioned in 2.2 Land-Based Gambling, Legislative Decree No 504/1998 officially recognises sports betting as a legal activity under state control, grants the State ‒ through the ADM ‒ the power to issue concessions for the management of agencies, introduces taxation on betting (a flat tax), and establishes that bets can only be collected through authorised dealers.

With Legislative Decree No 300/1999, all responsibilities in the gaming and betting sector have been assigned to the ADM.

Law No 133/1999 (Article 16), Law No 311/2004 and the subsequent Ministerial Decree No 111/2006 govern the collection of totaliser and fixed-odds bets on sporting events (apart from horse racies) as well as on non-sporting events.

Ministerial Decree No 156/2001 attributed to the MEF the competence to authorise the licensee to collect bets by telephone or telematics (online).

Law No 266/2005 (the “Financial Law 2006”) gave the ADM the power to regulate the online gaming sector as well, with consequent prohibitions for unauthorised sites.

The Bersani Decree opened the horse race betting and sports betting market to all national and foreign operators meeting certain reliability requirements. Article 38, paragraph 1b of the Bersani Decree introduced “skill games” – defined as “remote games with cash winnings, in which the result depends, to a greater extent than on the random element, on the skill of the players” (ie, draughts, chess, bridge, poker, Texas Hold’em, etc) – and establishes that these games can only be played on online sites managed by concessionaires authorised by the ADM.

AML legislation was introduced by Legislative Decree No 231/2007 as amended and concerns all land-based and online gaming and betting operators.

The Community Law 2008 also includes provisions regarding the public gaming sector to align Italian legislation with EU legislation on gaming and betting, thus allowing the free flow of services within the EU. Specifically, the law provides that:

• gaming regulations (especially regarding legal gaming types, such as slot machines, betting, and online gaming) must be regulated by legislative decrees or specific regulations;
• gaming concessionaires (both land-based and online) must obtain a state licence for the operation of public gaming, issued by the ADM in accordance with established regulations;
• concessionaires are responsible not only for the management of the machines, but also for compliance with all tax and safety regulations;
• regulations on public gaming must include measures to prevent and combat gambling addiction – in this sense, concessionaires are obliged to inform players about the risks of pathological gambling and to ensure that gaming methods do not stimulate compulsive behaviour;
• network concessionaires are required to “monitor” and “verify” the correct functioning of AWP (new slot) machines and to ensure that the machines comply with the legal requirements set forth by national and EU legislation; and
• gaming operators must ensure that all gaming operations are clear and visible to the public, including clear information on the risks of gambling and the odds of winning.

Furthermore, additional protections are provided for online players, with particular attention to “misleading advertising practices” and the phenomenon of “problematic gambling”.

Law No 158/2012 (the “Balduzzi Decree”) contains the following rules regarding public gaming and betting.

• The problem of “pathological gambling” or “gambling disorder” is included among the significant public health issues, requiring prevention, treatment, and rehabilitation activities to be included in the essential levels of care (livelli essenziali di assistenza, or LEA).
• Operators of gaming halls, places where bets are taken or places where gaming machines with cash prizes are installed are required to display informational materials (in the halls or at the entrance) warning of the risks associated with gambling and indicating support services for those suffering from gambling addiction.
• A more restrictive regime is introduced for advertising related to games with cash prizes – for example:
1. advertising that aims to “glorify” gambling is prohibited; and
2. advertising must clearly indicate the probability of winning and, in many cases, must contain warnings regarding the risk of addiction.

Ministerial Decree No 47/2013 regulates remote betting at fixed odds with direct interaction between players (so-called betting exchange).

The “Dignity Decree” banned the advertising of gambling activities, except in certain cases (see 9. Advertising).

The Legislative Decree No 41/2024 contains “provisions regarding the reorganisation of the gaming sector starting from remote gaming” as part of the implementation of the general tax reform under Delegation Law No 111/2023 and aims to reorganise the legislation regarding public games, particularly online gaming (see 1.1 Current Outlook and Recent Changes).

Gambling is defined by Article 721 of the Italian Criminal Code as “those games in which the purpose of profit occurs and the win or loss is entirely or almost entirely random”. Gambling is different from games of skill, which are defined by the Bersani Decree as depending on the skill of the players rather than pure chance (see 3.1 Key Legislation).

“Land-based gambling” or “offline gaming” includes all the following gaming activities carried out on physical sites (casinos, betting shops, etc) considered legal by the Italian legislation: 

• machines with cash winnings (AWP machines and VLTs) (Article 110 of TULPS);
• lotteries (Lotto, SuperEnalotto, etc);
• scratch cards;
• horse race betting;
• sports betting;
• bingo; and
• casino games.

According to Italian legislation and EU Directive 98/34, online gaming is “a service involving a monetary stake in games dependent on luck, including lotteries and betting, provided remotely, by electronic means at the request of the individual recipient of the services”.

The main types of online legal gambling in Italy are classified by Legislative Decree No 41/2024 and listed in 2.1 Online Gambling.

In the Italian context, the key offences in the public gaming sector are all serious crimes or violations that affect the regularity, transparency, security and legality of gaming operations. They may also lead to exclusion or revocation of the concession, in addition to criminal and administrative liability.

The main legislative sources are:

• Articles 86, 88, and 110 of TULPS;
• Law No 401/1989 – criminal offences related to gaming and betting;
• Legislative Decree 231/2001 – corporate administrative liability;
• Legislative Decree 231/2007 – AML;
• the Balduzzi Decree – advertising and protection of minors;
• the Dignity Decree – ban on advertising of games with cash winnings; and
• ADM regulations and circulars – conduct punishable by suspension/revocation of the concession.

The main key offences and the corresponding sanctions are:

• unauthorised gaming/illegal operation of gaming or betting without concession and/or licence (Article 4 of Law 401/1989 and Article 110 of TULPS) – imprisonment for up to three years and a fine, revocation of the ADM concession, and administrative sanctions;
• computer fraud and system tampering/manipulation of devices, software or ADM telematic networks (Article 640-ter Criminal Code and Article 110 of TULPS) – imprisonment from six months to three years, as well as suspension or revocation of the licence;

• money laundering/self-laundering/use of gaming to transfer or clean illicit funds (Legislative Decree 231/2007 and Articles 648-bis and 648-ter of the Italian Criminal Code) – imprisonment from four to 12 years, as well as Financial Intelligence Unit (Unità di Informazione Finanziaria, or UIF) reporting obligation;

• aggravated fraud against the State/fraud in the collection or payment of winnings (Article 640-bis of the Italian Criminal Code) – imprisonment from one to six years, as well as revocation of the concession and disqualification from obtaining public concessions;
• Corruption and extortion/unlawful relations with public officials to obtain concessions (Articles 318 to 322 of the Italian Criminal Code) – imprisonment for up to ten years, as well as corporate liability under Legislative Decree 231/2001;
• criminal association for illegal gaming/Organisation of illegal networks outside the ADM system (Article 416 of the Italian Criminal Code) – imprisonment from three to seven years, as well as confiscation and permanent disqualification;
• usury/extortion related to gaming/illegal financing or coercive control of gaming activities (Articles 629 to 644 of the Italian Criminal Code) – imprisonment from three to ten years, as well as permanent disqualification;
• failure to verify identity/access by minors/failure to identify customers or allowing under-18 access (the Balduzzi Decree and Article 24 of Decree Law 98/2011) – fines from EUR5,000 to EUR20,000 and suspension of the activity;
• violation of AML obligations/failure to report, structuring or lack of transaction traceability (Legislative Decree 231/2007) – administrative sanctions up to EUR5 million, as well as suspension of the licence; and
• misleading advertising/non-compliant promotion/unlawful advertising of games (the Dignity Decree and Article 7 of the Balduzzi Decree, as well as the Italian Consumer Code and related regulations) – Italian Communications Authority (Autorità per le Garanzie nelle Comunicazioni, or “AGCOM”) sanctions and suspension of the concession.

The main penalties in cases of unlawful gambling are:

• operation of gambling and/or betting activities without a concession – imprisonment from six months to three years plus a fine of between EUR50,000 and EUR500,000 (Article 4 of Law 401/1989);
• operation with an expired concession – treated as “operation without concession” (Article 4 of Law 401/1989);
• AWP machines and/or VLTs not connected and/or not authorised – fine of up to EUR10,000 per machine plus seizure of the device (Article 110 of TULPS);

• collection of bets on behalf of a foreign bookmaker – same criminal penalties as operating gambling without a concession (Article 4, paragraph 4 of Law 401/1989);

• access by minors (ie, those under 18 years of age) to gaming/betting premises – administrative fine from EUR5,000 to EUR20,000 and closure of the gaming point for between ten and 30 days;
• non-compliant advertising of gambling/betting services – administrative sanction according to the parameters set out in the Dignity Decree;
• AML violations by gaming/betting operators – administrative sanctions and possible contractual penalties for concessionaires (Legislative Decree No 231/2007); and
• regional/local breaches (eg, opening hours, distance requirements for machines) – administrative sanction in the amount established by regional laws and/or municipal regulations, as well as possible suspension of the activity.

The regulatory authority was the AAMS. established in 1927, which had already acquired the national lotteries (in 1988) and the Lotto game and the instant lotteries (in 1994). The AAMS has been subsequently incorporated by Law No 135/2012 into the ADM, a public body with legal personality and wide financial, organisational and accounting autonomy.

The ADM has the following regulatory powers:

• issues licences for betting shops, bingo, slot machines/VLTs, and online games;
• authorises and monitors gaming concessionaires;
• manages tender procedures for new licences;
• conducts technical checks on gaming systems, payouts, software, and IT networks;
• issues circulars, technical regulations, and operational guidelines;
• combats illegal gambling, including by blocking unauthorised sites; and
• oversees tax collection and taxation.

In Italy, the entire public gaming system is based on:

• state monopoly;
• public concessions;
• central regulation entrusted to the State through the ADM; and
• strong technical, fiscal, and public order controls.

Gambling, in essence, is an activity reserved to the State, which can grant permission for it to private individuals through public concessions.

The public gaming concessions are divided into:

• mono-concessions – ie, Lotto, Superenalotto and lotteries; and
• multi-concessions – ie, horse race betting and sports betting, sports prediction competitions, bingo, devices (slots, VLTs), and online games.

Pursuant to TULPS, there are two types of licences, as follows.

• The licence pursuant to Article 86 of TULPS – issued by the police headquarters or the municipality – is the document that physically authorises a business (bar, tobacconist, etc) to host/install non-cash gaming machines (billiards, pinball machines, and video games (Article 110, paragraph 7 of TULPS)), new slot/AWP machines (Article 110, paragraph 6a of TULPS), VLTs (Article 110, paragraph 6b of TULPS), and other legal games without direct betting.
• The licence pursuant to Article 88 of TULPS (issued only by the police headquarters), on the other hand, is specific to those who collect sports bets, horse race bets, and virtual bets and for public games subject to state concessions from the ADM (eg, top-up and betting points of sale, corners, agencies).

There are no available public concessions at the moment.

The following concessions are currently envisaged.

• The concession for the automated Lotto and other fixed-odds number games, expiring on 30 November 2025, was awarded – following the public tender held at the beginning of 2025 ‒ to LottoItalia Srl (a company controlled by IGT) for a term of nine years starting from 1 December 2025 as per the determination of the ADM published on 15 July 2025.
• The concession for national totaliser number games (SuperEnalotto, SuperStar, and Vinci per la Vita (Win for Life)), complementary and optional games and related forms of remote participation – as well as any additional national totaliser-based numerical games – was awarded in July 2019, following a public tender, to Sisal SpA for a duration of nine years. However, owing to the COVID-19 pandemic emergency, this term commenced on 1 December 2021 and will therefore expire on 30 November 2030.
• Fifty-two online concessions were awarded in 2025, following the public tender held by the ADM pursuant to Article 6 of Legislative Decree No 41/2024, to 46 concessionaires for a duration of nine years starting from 13 November 2025.

• All the concessions that expired on 31 December 2024 ‒ bingo, betting on sporting events (including horse races and simulated events), and the development and operation of telematic gaming networks using amusement and entertainment machines (AWP machines and VLTs as per Article 110, paragraph 6 of TULPS) ‒ have been extended by two years according to 2025 Budget Law, meaning they will expire on 31 December 2026.

The duration of a public concession varies according to its type and is sometimes extended with specific regulatory measures, as follows – 

• remote (online) gaming – nine years;
• Lotto and other fixed-odds numerical games – nine years (non-renewable);
• national instant lotteries (Scratch and Win) – nine years (the previous concession was renewed for nine years, with an extension until 2028);
• bingo (halls) – six years (ADM agreement template);
• physical network betting – ninr years; and
• AWP machines/VLTs – to be defined in the new documents (a sector historically subject to a dedicated tender).

The ADM website contains a list of authorised remote gaming concessionaires.

The requirements for participating in the public tender for awarding the public gaming concession are published on the ADM website and are as follows.

• Legal and corporate requirements – the applicant company must:
1. be incorporated as a joint stock company (eg, SpA, Srl) with a registered office in an EU/European Economic Area (EEA) member state;
2. not be involved in any relevant criminal proceedings, nor have any convictions or disqualifications;
3. have a business purpose consistent with remote gaming activities; and
4. be up-to-date with tax and social security obligations.
• Economic and financial requirements ‒ the operator must demonstrate financial stability, including:
1. minimum share capital (often required to be at least EUR1.5 million, varying from call to call);
2. a surety bond (eg, EUR1.5 million or the amount established by the call);
3. minimum previous turnover requirement (typically several million euros in the gaming or digital sector); and
4. no insolvency proceedings or financial crisis.
• Technical requirements ‒ the operator must demonstrate:
1. a certified platform compliant with ADM standards;
2. a gaming system certified by authorised bodies (eg, Gaming Labs International (GLI), iTech Labs);
3. connection to the ADM national totalisator;
4. servers located in the EU and accessible to the ADM; and
5. features – betting traceability, log retention for up to ten years, anti-tampering and anti-fraud systems.
• Legal compliance and security – the operator must comply with:
1. AML regulations (Legislative Decree 231/2007);
2. the EU General Data Protection Regulations and personal data protection requirements; 
3. KYC procedures;
4. responsible gaming and self-exclusion systems (connection to the RUA); and
5. controls on minors and at-risk players.
• Organisational requirements ‒ the applicant company must demonstrate:
1. a registered office or permanent establishment in the EU/EEA;
2. qualified personnel (technical, administrative, compliance);
3. customer service (in Italian);
4. anti-problem-gambling structure (messages, limits, self-exclusions).
• Administrative and tax aspects – the operator must:
1. set up an Italian VAT number;
2. participate in ADM monitoring systems;
3. pay taxes, the PREU, and license fees; and
4. compliance with advertising regulations (the Dignity Decree and advertising ban).
• Participation in the public tender ‒ applicant companies are required to:
1. submit a technical and financial offer compliant with the specifications; 
2. pay the tender fee (eg, EUR2 million for the online tender scheduled for 2024); and
3. accept the ADM concession agreement.

The timeframe for obtaining a public concession from the ADM varies based on the type of game, the type of procedure (public tender or renewal), and the completeness of the application.

In the event of a new concession through a public tender announced by the State through a law and regulated by the ADM (eg, the public tender for the awarding of 52 online gaming licenses announced through Legislative Decree No 41/2024 and regulated by the ADM with subsequent directorial provisions), the timeframe is defined by specific phases. From the opening of the tender to the actual issuance of the concession, the process can last between and 12 months, as follows:

• publication of the ADM tender notice on its portal and in the Official Journal;
• submission of applications by interested operators within 60 to 90 days of the tender notice, including documents, deposits, application fees, and technical requirements;

• evaluation and investigation – approximately the next three to six months, during which the ADM verifies the subjective, technical, financial and moral requirements of the participants;

• award and signing of the concession agreement – the next one to three months, during which the ADM announces the award and signs the concession agreement with the successful bidders; and
• operational activation – the next one to two months, during which the operating systems, SOGEI (Società Generale d'Informatica SpA) interface, technical testing, and certifications must be configured.

In the case of a “renewal or extension” of an existing concession, the timeframe is three to six months if all requirements are met. During this time, the ADM may grant “technical extensions” for concessionaires already in operation pending a new tender (eg, extension of the 2023–24 betting concession). Renewal is not automatic – Legislative Decree 41/2024, for example, prohibits extensions exceeding nine years and requires a new tender every nine years.

In the case of a “takeover or transfer” (ie, if a party takes over from a concessionaire (eg, merger, sale of a business, change of ownership structure)), given that this is not a new concession but merely a “transfer/update”, the duration is two to four months depending on the complexity of the “requirements” verification required by the ADM.

The timeframe for obtaining a licence pursuant to Articles 86 and 88 of TULPS varies depending on the type of licence, the competent police headquarters, and the completeness of the documentation in compliance with the principles established by Law No 241/1990. These timeframes can be estimated as between 30 and 60 days from the date of application submission for obtaining a licence pursuant to Article 86 of TULPS from the municipality and/or one-stop shop (sportello unico per le attività produttive, or SUAP) and between 60 and 120 days for the issuance of a licence pursuant to Article 88 of TULPS by the Administrative, Social, and Immigration Division (DivisionePolizia Amministrativa, Sociale e dell'Immigrazione) (the “PAS Division”) of the police headquarters.

The cost for obtaining a public concession and/or a licence varies, based on the type of game to be offered

The fees of the various concessions ‒ up-to-date as of 2025 ‒ are as follows.

• Online gaming ‒ a one-time payment of EUR7,000,000 per concession is required (Article 6 of Legislative Decree No. 41/2024);

• Betting concessions (agencies and corners) ‒ according to the latest public tender of 2016‒18, an entry fee is required (EUR32,000 per shop and EUR18,000 per corner), as well as a bank guarantee (from EUR50,000 to EUR100,000 per point).

• For a bingo concession, the indicative tender cost ranges from EUR200,000 to EUR350,000 per hall (the concession lasts approximately nine years, depending on the tender), in addition to the guarantees required by the tender.
• For AWP machine/VLT concessions (network management) with national concessionaires (Lottomatica, Sisal, Snaitech, etc), the cost of the network right (based on the latest tender) is approximately EUR7,500 for each AWP right and up to EUR18,000 for each VLT right. Furthermore, concessionaires must have very high share capital (from EUR1 million to EUR5 million) and provide sureties amounting to hundreds of millions for the entire system, as well as network infrastructure, servers, and certifications.

• For lottery concessions (which are “monopolistic” concessions, obtainable only by large groups,) the estimated costs are more than EUR100 million for Superenalotto and more than EUR800 million for Gratta&Vinci (2010 tender).

The main annual costs of a concession, in addition to taxes (see 12. Tax), are as follows.

• For online concessions, in addition to the concession fee (EUR7 million), there is an annual fee equal to 3% of the net gaming margin.
• Costs related to top-up points (punti vendita ricarica, or PVRs) ‒ an annual registration fee of EUR100 per PVR is paid.

• For land-based betting ‒ per the 2025 Budget Law, the concession extension costs EUR9,500 per year for each main agency, whereas the cost is EUR5,700 per year for betting “corners” (smaller locations).

• SOGEI contribution ‒ this equates to 0.15% of the average revenue for connection to the ADM telematics network.

• “Responsible gaming” contribution ‒ this equates to 0.2%‒0.5% of the GGR as established in the ADM agreement for the prevention of gambling addiction.

To obtain a personal licence pursuant to Articles 86, 88 and 110 of TULPS, the following requirements must be met, which may vary slightly depending on the region and/or municipality.

• Subjective requirements ‒ the holder must:
1. be an adult;
2. be an Italian or EU citizen or be or a non-EU citizen with a valid residence permit;
3. enjoy full civil and political rights, not be interdicted, incapacitated or bankrupt, and have no convictions that prevent them from practising their profession;
4. demonstrate the absence of anti-mafia impediments (when required).
• Venue/structure requirements ‒ the venue must:
1. be intended for commercial/entertainment use (urban planning and building inspection);
2. comply with safety regulations (electrical system, escape routes, fire extinguishers, signage, etc);
3. hold a fire prevention certificate (segnalazione certificata di inizio attività, or SCIA) if larger than 200 square metres with a capacity of more than 100 people;
4. ensure that any amusement machines (including those with cash prizes) installed are connected by authorised dealers registered in the Register of Authorised Operators (Registro Informatico Elenco Soggetti, or REIS) of the ADM; and
5. verify minimum distances from “sensitive locations” (schools, churches, youth centers) if required by regional or municipal legislation.

The above-mentioned licence must be held by:

• directors and the board of directors;
• gaming room or platform managers;
• AML managers;
• IT systems managers;
• personnel supervisors; and
• personnel directly involved in gaming management.

The application must be submitted (in the case of a company) by the legal representative, by the individual/natural person who owns the sole proprietorship or by a specially designated delegate via proxy to the SUAP competent for the territory in which the activity takes place or the business is located. The application must contain the following documents:

• authorisation application;
• special power of attorney;
• declaration of possession of the prerequisites;
• declaration by the representative of lawful games;
• certification of stamp duty payment;
• certification of payment of charges and fees;
• identity documents of the interested parties;
• plan of the premises; and
• fire prevention certificate (SCIA).

Those public places, once the aforementioned licence has been obtained, enter into a connection contract with an authorised ADM licensee who supplies and manages the machines.

The fees for obtaining the aforementioned licence vary depending on the municipality, the local police headquarters, or the region. The fees are often dependent on the location, type of business, number of machines, and local requirements. By way of example, in the Municipality of Rome, the stamp duty starts at approximately EUR16.

Furthermore, there may be “additional costs” decided annually by the municipality, which vary depending on the type and size of the business.

Finally, for a betting licence pursuant to Article 88 of TULPS, minimum distances from “sensitive locations” and other checks must be respected. This means that the cost may also depend on these local requirements.

For simple affiliated points of sale, the cost is limited to administrative expenses and the contract with the dealer.

For the aforementioned licences, there are no fixed annual costs other than the costs for obtaining them and taxes/levies (see 12. Tax).

In the event of violations of the aforementioned licences and/or non-compliance of AWP machines and VLTs with current regulations, the following penalties are applicable pursuant to Article 110, paragraph 9 of TULPS:

• an administrative fine of EUR1,000 to EUR6,000 for each machine for anyone who manufactures or imports the aforementioned machines and devices (paragraphs 6 and 7 of Article 110) that do not comply with the characteristics and requirements indicated therein;
• an administrative fine of EUR500 to EUR3,000 for each machine for anyone who manufactures or imports the aforementioned machines and devices (paragraphs 6 and 7 of Article 110) without the authorisations required by current provisions;
• administrative fine of EUR4,000 for each device for use in public places or places open to the public or in clubs and associations of any kind of the aforementioned devices or mechanisms (paragraphs 6 and 7 of Article 110) not complying with the characteristics and requirements indicated therein;
• an administrative fine of EUR500 to EUR3,000 for each device for use in public places or places open to the public or in clubs and associations of devices and equipment referred to in paragraphs 6 or 7 of Article 110 for which the authorisations required by current provisions have not been issued;
• in cases of repeated violations, the ADM may not issue new authorisations for a period of five years;
• an administrative fine of EUR1,500 to EUR15,000 and/or EUR5,000 to EUR50,000 for each device for anyone within the national territory who distributes, installs, or permits the use in public places or places open to the public or in clubs and associations of devices referred to in Article 110 without the required authorisations.

In addition to the aforementioned fines, violations of Article 110 and Articles 86 to 88 of TULPS also entail additional penalties, such as:

• suspension and/or revocation of the licence;
• confiscation pursuant to Article 20, paragraph 4 of Law 689/1981 – the same order may order the destruction of the equipment and devices, in accordance with the procedures established therein;
• closure of the gaming hall/commercial premises;
• cancellation from the RIES by the ADM for betting centres operating without a licence pursuant to Article 88 of TULPS or without a state concession.

The requirements for issuing a land-based authorisation include the public concession issued by the ADM following the award of a public tender and the authorisation/licence pursuant to Article 86 or Article 88 of TULPS (see 4.10 Personal Licensing).

For AWP machines and VLTs (pursuant to Article 110, paragraph 6a and b and paragraph 7 of TULPS), a licence is also required for:

• production or importation activities;
• distribution and management activities;
• indirect activities and installation in commercial or public establishments, other than those already in possession of other aforementioned authorisations or referred to in Article 88; or
• installation in other premises open to the public or in private clubs.

For a B2C operator in the gaming sector in Italy (ie, a company offering games to the public, both online and land-based), the following are required:

• the ADM concession, which authorises the licensee (eg, Lottomatica, Sisal, Snaitech, Eurobet) to offer land-based and online games (casino, poker, bingo, remote slots), manage a network of betting shops, operate AWP machines/VLTs (if a network licensee), bingo and lotteries (for a few large operators) on behalf of the State; and
• the licences pursuant to Articles 86 and 88 of TULPS, which authorise physical points of sale to operate in Italy.

The requirements for obtaining an ADM concession following a public tender and/or a TULPS licence are the general requirements described in 4.6 Application Requirements and 4.10 Personal Licensing.

The duration of a concession varies depending on the type of licence (see 4.5 Duration of Licences).

The costs for an ADM concession and/or a TULPS licence are general (see 4.8 Application Fees, 4.9 Ongoing Annual Fees, and 4.10 Personal Licensing).

The annual costs for a B2C operator are as follows:

• gaming taxes (varies by category);
• annual ADM contribution; and
• SOGEI costs – audit and compliance (between EUR30,000 and EUR60,000).

The B2C operating models are as follows:

• operator with own licence – high investment, but total control;
• white label/skin – relies on an existing licensee (ADM or foreign);
• affiliate/pay-per-click (PPC) – does not require a licence if it does not offer gaming.

In Italy, there is no specific ADM licensing regime for software suppliers and B2B operators.

A B2B licence does not allow the public to offer games, but is used to provide technology platforms, payment systems, gaming software, random number generators (RNGs), management services, maintenance services, server housing, and technical support.

A supplier with ADM certification can:

• sell games to Italian concessionaires;
• operate within the regulated .it market;
• gain greater credibility across Europe;
• obtain contracts with major Italian operators; and
• expand within the sector by offering additional services.

A B2B supplier, on the other hand, cannot:

• offer gaming services directly to end users;
• manage players’ sensitive data unless specifically authorised;
• intervene in the final payout; and
• operate independently without being linked to a concessionaire.

The B2B “licensing” works in Italy in four operational models, as follows.

• Game suppliers (casino, skill, bingo, virtuals) – each game must be tested by an accredited laboratory, approved by the concessionaire, integrated with SOGEI and authorised for release on the .it market.
• Sportsbook suppliers (feeds and betting engines) – a sportsbook B2B supplier must provide certified data feeds, generate odds in accordance with ADM requirements, and transmit transactions in real time.
• Gaming (player account management, or PAM) platforms – PAM platforms must strictly comply with requirements relating to security, user management, bonus systems, wallet management, and anti-fraud systems. Often, the B2B platform is integrated as a “technical provider”.
• Additional modules ‒ these include responsible gaming/self-exclusion modules, automated AML systems, AML/KYC modules, and behavioural tracking systems.

The ADM formally communicates:

• the supplier’s name;
• the module or game used; and
• the outcome of the certification

The supplier’s system must connect to the ADM/SOGEI central systems.

Every transaction (bet, win, game state) must be recorded in real time.

The ADM carries out periodic checks, including:

• audits;
• functional tests;
• document checks;
• RNG integrity verification; and
• statistical and payout analyses.

In Italy, affiliates are NOT considered gaming operators, therefore:

• no ADM licence is required;
• no technical certification is required; and
• no individual authorisation is required.

However, affiliation in the gaming sector is permitted only if the affiliate promotes operators authorised by the ADM and complies with all rules on commercial communications.

Among the applicable regulations is the Dignity Decree (see 3.1 Key Legislation and 9. Advertising), which contains a total ban on direct or indirect advertising relating to gambling and betting. Therefore, an affiliate may not, for example:

• advertise .com or non-authorised sites;
• promote bonuses, offers or promo codes;
• carry out SEO/SEM (search engine marketing) activities aimed at promoting gaming;
• use banners, pop-ups or paid advertising;
• engage in influencer marketing;
• use social ads (Facebook/Instagram/Google);
• carry out indirect promotions (eg, disguised brand awareness); and
• insert tracked links redirecting to ADM operators.

The advertising ban applies to websites, blogs and information portals, social media, newspapers and magazines, TV/radio, billboards and outdoor advertising, email marketing, and SMS (short message service) marketing.

Despite the advertising ban, some “informational content” is permitted, provided that strict conditions are met, such as neutral information and/or regulatory information.

The sanctions for affiliates in the event of violation may be imposed by:

• AGCOM (administrative fine from EUR50,000 to EUR500,000 charged to the affiliate, immediate removal of the content, and – in serious cases – website blocking);
• the ADM (reports for participation in unauthorised gambling activity, in addition to potential criminal liability if the affiliate promotes illegal (.com) sites);
• the Financial Guard (Guardia di Finanza, or GdF) (domain seizure and – in the most serious cases – tax and criminal investigations).

White labels are permitted in Italy, but only if:

• they operate under an existing ADM licence;
• they do not independently collect bets;
• they do not manage gaming accounts, wallets, or payouts;
• they do not perform AML/KYC functions;
• they are declared by the licensee to the ADM;
• they use only ADM-certified software/games;
• they are integrated into the ADM/SOGEI systems through the licensee.

As a result, white labels can neither obtain their own licence nor, for example, open gaming accounts, manage sensitive player data, manage deposits, limits or payments, or transmit data directly to SOGEI.

Furthermore, the ADM prohibits any white label that resembles an independent B2C operator.

Italy applies strict technical, administrative and operational measures to protect players and block illegal gambling. These measures are enforced by the ADM and SOGEI, as follows.

• Blocking illegal websites – these measures entail:
1. an official blacklist of unauthorised domains updated daily;
2. domain name system (DNS) blocking – access is redirected to an ADM warning page;
3. IP (internet protocol) address and URL (uniform resource locator) blocking for mirrors, subdomains and disguised sites; and
4. monitoring of VPN (virtual private network)/proxy traffic and seizure of illegal servers.
• Payment protection – in order to protect players’ payments:
1. payment service providers (PSPs) cannot process payments to illegal operators (severe sanctions apply);
2. banks must block transactions, then report suspicious activity via a suspicious transaction report (STR) (segnalazione di operazioni sospette, or SOS);
3. all payments to ADM operators are fully traceable via SOGEI; and
4. strong restrictions apply to e-wallets, prepaid cards and vouchers to prevent anonymity.
• Consumer protection – these measures entail:
1. national self-exclusion system (RUA) – blocks access across all ADM operators;
2. mandatory KYC and identity verification;
3. player limits – deposits, sessions, self-imposed limits, cooling-off periods; and
4. behavioural monitoring to identify risky or problem gambling patterns.
• Enforcement actions – these take the form of:
1. domain and server seizures;
2. national blocking of illegal platforms;
3. international financial freezing of funds;
4. joint operations by the ADM and the GdF.

In Italy, responsible gaming represents one of the legality requirements set out by the ADM in the guidelines to which every dealer and operator is subject by law in order to obtain Gioco Italia 2.0 certification. (Italy’s “Gaming 2.0” certification framework is a new technical and licensing regime administered by the ADM, having been introduced under Legislative Decree 41/2024.)

All gaming platforms also adopt the “Service Charter for Remote Gaming” issued by the ADM. Its aim is to “ensur[e] a responsible gaming environment for players”.

There are seven types of responsible gaming areas directly linked to the iGaming sector, which are:

• protecting vulnerable players;
• preventing underage gambling;
• security measures against criminal activities;
• privacy policy;
• online payment protection;
• a safe online environment; and
• ethical and responsible marketing.

Gaming management tools (GMTs) are provided for and regulated by:

• the ADM Regulations on Remote Gaming, the ADM Technical Rules for Gaming Account Management, and the ADM/SOGEI Technical Protocols, as well as specific regulations for casinos, betting, poker, and bingo; and
• the following national laws (see 3. Legislative Framework):
1. the Balduzzi Decree;
2. the Dignity Decree;
3. 2020 and 2023 Budget Laws (“Strengthening Responsible Gaming”)
4. Article 110 of TULPS for land-based machines (AWP machines and VLTs); and
5. AML Guidelines (Legislative Decree 231/2007).

In Italy, GMTs are mandatory, certified, and centrally controlled by the ADM and SOGEI.

Operators must implement:

• gambling limits;
• national self-exclusion;
• strict KYC;
• behavioural controls;
• payment protection;
• anti-manipulation tools;
• auditing and reporting systems; and
• real-time monitoring.

Mandatory GMTs for all ADM (B2C) dealers are as follows.

• Mandatory limits – players must set limits before playing (deposit limit, session limits, spending limits, top-up limits, and cooling-off period/temporary exclusion).
• Mandatory identity verification (KYC) within 30 days of account opening ‒ failure to do so will result in account suspension and subsequent closure.
• National self-exclusion – the RUA is national and centralised, managed by the ADM/SOGEI, and applies to all dealers. A self-excluded player cannot open new accounts, access ADM sites, deposit, or play.
• Gaming behaviour monitoring tools ‒ these must be activated by dealers to analyse risk patterns, detect compulsive behaviour, monitor gaming frequency, and automatically alert players, etc.

• Mandatory communications and messages – regular responsible gaming messages must be communicated, including warnings about time spent, losses, and risk indicators.

AML legislation was introduced by Legislative Decree No 231/2007 and subsequent amendments, which transposed EU Directive 2005/60/EC and extended the obligations relating to customer due diligence, reporting of suspicious transactions, and data retention. The legislation has been progressively expanded to cover the entire gaming and betting sector.

Both for land-based gaming/betting and for the online sector, the above-mentioned AML legislation requires all operators to identify each customer who:

• make bets for an amount exceeding EUR2,000; and
• collects prizes exceeding EUR2,000.

For all gaming and betting operators who do not fulfil the obligations established by the aforementioned AML legislation, administrative fines range from EUR1,000 to EUR10,000.

The GdF, pursuant to Legislative Decree No 68/2001, exercises control over compliance with the aforementioned AML provisions.

In this regard, on 18 November 2024, the ADM issued specific AML Guidelines for gaming concessionaires. The AML Guidelines required operators to implement appropriate procedures and control systems within 30 days from publication. Further obligations and clarifications are provided in the guidelines issued by the UIF.

All operators who manage casinos or offer games and betting with cash winnings – whether through retail networks or online – are subject to AML regulations. The ADM has clarified that the entire supply chain (eg, outsourcing providers, sub-concessionaires, intermediaries) may also be involved in AML controls and subject to specific reporting obligations. Conversely, operators who offer only games without cash winnings – or offer prize contests that do not involve monetary collection – are not included, unless otherwise required by specific legislation.

The main obligations that gaming operators offering games with cash winnings must comply with are:

• customer identification and verification at the time of establishing the business relationship or carrying out a transaction – for example, collection of personal data, verification procedures, and identification of the beneficial owner in the case of legal persons;
• customer due diligence and risk profiling, particularly for significant transactions or high-risk customers;
• reporting of suspicious transactions to the UIF whenever there are elements reasonably suggesting that a transaction may be connected to money laundering or terrorist financing;
• record-keeping – documentation relating to customers, transactions and checks performed must be retained for the period required by law (eg, ten years) to demonstrate compliance;
• specific payment-related obligations, including limits on the use of cash and the traceability of financial transactions – cash use is restricted to prevent money laundering;
• transmission of data by concessionaires to the ADM – for example, in the event of termination of the contractual relationship or reporting by the supply chain; and
• staff training – operators must implement training programmes for employees involved in activities exposed to money-laundering risk.

Operators who fail to adequately implement AML procedures risk sanctions, suspension of operations, and revocation of the concession (ADM Guidelines).

Liability may fall both on the operator (the concessionaire company) and on its internal organisational structure if appropriate measures have not been adopted.

Before carrying out account-opening, top-up or payout operations above certain thresholds (eg, EUR1,000 for many operators), customer data must be collected. Thresholds may vary depending on the type of game, whether it is retail or online, and the associated risk (eg, online gaming accounts require enhanced verification).

STRs must be submitted through the ADM/online AML reporting system for the gaming sector.

Record-keeping and reporting obligations are also subject to inspection and verification by the ADM and the UIF.

Gambling advertising and sponsorship are prohibited in Italy pursuant to the Dignity Decree (see 9.3 Key Legal, Regulatory and Licensing Provisions).

The public bodies responsible for enforcing the ban on gaming advertising in Italy are:

• AGCOM, which monitors and sanctions prohibited advertising;
• the GdF, which investigates and represses illegal advertising involving economic and financial implications;
• the ADM, which can report violations and supervises concessionaires;
• the Postal Police Unit, which carries out digital controls (web, social media, influencers);
• the Judicial Authority, which intervenes if the advertising involves criminal offences; and
• the Ministry of Business and Made in Italy (Ministero delle imprese e del made in Italy, or “MIMIT”), which provides general regulatory support.

According to AGCOM resolutions (132/19/CONS, 23/20/CONS, 250/21/CONS, etc), advertising is any form of commercial communication ‒ even indirect or implicit ‒ aimed at promoting games with cash prizes or their use, even when it does not contain an explicit invitation to gamble.

Advertising in the gaming industry includes:

• direct communication (commercials, banners, videos, posters);
• indirect communication (brand exposure, logos, graphics, merchandising);
• covert communication (product placement, influencer marketing); and
• content that is not explicitly promotional but capable of encouraging gambling.

Therefore, even brand exposure ‒ if not merely neutral – can be considered advertising.

The total ban on advertising for gambling with cash prizes was established by Article 9 of the Dignity Decree. It applies to all media (TV, radio, print, web, social media, events, influencers) and covers all forms of advertising, even indirect.

Since 1 January  2019, sports sponsorships by gaming operators have also been prohibited.

The advertising ban referred to in 9.3 Key Legal, Regulatory and Licensing Provisions covers ‒ pursuant to Article 9 of the Dignity Decree and the AGCOM Guidelines – any form of commercial communication that might encourage gambling, promote an operator (including the ADM), foster brand awareness related to gambling, or communicate bonuses, offers, odds, or welcome bonuses.

The ban applies without exception to any time slot or media category. The ban includes all advertising channels, including TV, radio, print media, websites, blogs, news portals, social media, sports sponsorships, banners, pop-ups, keyword advertising, SEM/SEO for gambling, influencer marketing, podcasts, streaming, email marketing, SMS, and push notifications.

Only purely informative content is permitted, provided it is neutral, free of invitations to play, does not contain tracked links, and does not mention bonuses, odds or promotions. By way of example, information on ADM licences, explanations on legality and safe gaming, and industry news without commercial content are permitted.

Penalties amount to 20% of the value of the sponsorship or advertising, but to no less than EUR50,000. For violators (both the recipient of the advertising message and the owner of the means of communication concerned), an administrative fine of EUR100,000 to EUR500,000 is foreseen.

In general, warnings on the risk of addiction to gambling with cash winnings and on the related probability of winning must be reported (under penalty of an administrative fine of EUR50,000):

• on the slips (schedine);
• on AWP gaming machines – ie, those machines that are activated by introducing coins or electronic payment instruments;
• in rooms equipped with VLTs;
• at sales points for betting on sporting and non-sporting events; and
• on websites intended to offer games with cash prizes.

The disclosure requirements required of licensees/concessionaires by the ADM for acquisitions and change of control of gaming and gambling companies are:

• corporate information with the complete corporate structure;
• financial and accounting requirements – audited financial statements, minimum share capital, financial strength, cash flows to suppliers/operators, and periodic reporting of collections;
• technical and operational information – software certifications, RNG and payout, gaming servers and infrastructure, platform architecture, technical and security audits;
• AML/KYC information pursuant to Legislative Decree 231/2007 (see 8. Anti-Money Laundering (AML));
• contracts with third parties (B2B) to avoid uncontrolled outsourcing (see 6.2 B2B Licences (Suppliers, Software, Etc); and
• advertising and communication in compliance with the prohibitions under the Dignity Decree (see 9. Advertising).

In the gaming and betting sector, any change of corporate control triggers concerning the concessionaire ‒ such as changes in shares, governance changes, or mergers – require communication and approval from the ADM to ensure that control of the operator remains in the hands of suitable and transparent entities.

In the event of the changes mentioned in 10.2 Change of Corporate Control Triggers, the concessionaire must promptly notify the ADM of the event, providing:

• new corporate structure;
• identities of the new shareholders/directors;
• anti-mafia documentation; and
• updated financial requirements.

Subsequently, the ADM verifies (through a fit-and-proper test) that the new entities meet:

• integrity requirements;
• the requirement to demonstrate absence of criminal records;
• financial soundness requirements; and
• corporate transparency requirements.

The possible outcomes of the above-mentioned ADM test are:

• if approval is granted, the concession continues;
• if the ADM request additions, the concession is temporarily suspended pending the aforementioned additions; or
• refusal, with the consequent risk of the concession being revoked if the new inspection is not suitable.

In Italy, enforcement activities aimed at ensuring compliance with sector regulations are entrusted to the following bodies, each with its own specific tasks:

• the ADM (see 4.1 Regulatory Authority);
• the GdF, which:
1. conducts inspections of tax evasion, money laundering, and gambling fraud;
2. conducts audits of cash flows, dealer accounts, and irregular gaming machines;
3. combats illegal betting and unauthorised gambling establishments;
• the State Police, which is responsible for:
1. administrative inspections of premises and licences;
2. suppression of unauthorised gambling; and
3. collaboration in blocking illegal sites (via the Postal Police Unit).
• the Carabinieri (military police force), which is responsible for:
1. local inspections, inspections of gaming halls, and seizures; and
2. support for investigations into illegal networks;
• the MEF, which has a steering and supervisory role in the sector;
• the Ministry of the Interior, which supervises all aspects of public order and has the power to issue the licence required pursuant to Article 88 of TULPS to open gaming halls and betting shops (see 4.10 Personal Licensing);
• the UIF (Bank of Italy), which is responsible for enforcing AML regulations, in particular;
• municipalities and regions, which have territorial jurisdiction, particularly regarding gaming hall opening hours, minimum distances from sensitive locations (schools, hospitals, churches), commercial licences, and local administrative controls;
• AGCOM (in the online gaming sector), which is primarily responsible for overseeing compliance with the gambling advertising bans set forth in the Dignity Decree; and
• the Ministry of Health and Regional Health Services, which has a role related to player protection and the fight against pathological gambling and is responsible for co-ordinating the National GAP Plan, among other things.

The sanctions enforced by the competent authority are:

• administrative sanctions imposed by the ADM ‒ for example, for technical violations (non-compliance of gaming systems), irregularities at points of sale, failure to comply with the rules on the AWP/VLT network, breaches of concession agreements, and failure to communicate data or information to the ADM;
• regulatory sanctions imposed by the ADM (technical supervision, concessions), AGCOM (advertising ban), and the UIF/MEF (AML); and
• additional sanctions (including criminal sanctions), such as suspension of activity, closure of points of sale, suspension or revocation of concessions, and termination of branch contracts.

The main financial penalties are (see also 3.5 Key Offences and 3.6 Penalties for Unlawful Gambling):

• AGCOM penalties for violations of the Dignity Decree (advertising) – up to 20% of the value of the sponsorship or advertising contract/never less than EUR50,000 (also applicable to media, platforms, and influencers);
• ADM penalties for technical or administrative violations of concessions ‒ from EUR5,000 to more than EUR300,000 (depending on the violation), as well as contractual penalties for concessionaires’ non-compliance;
• penalties for violations of AWP/VLT rules pursuant to Article 110 of TULPS (see 3. Legislative Framework) ‒ for example, EUR10,000 for an irregular device, and between EUR50,000 andEUR200,000 for disconnected or tampered devices;
• tax penalties ‒ irregular payments may result in tax recoveries, late payments, interest, and GdF audits; and
• penalties for AML violations (Legislative Decree 231/2007 (see 8. Anti-Money Laundering (AML)) – from EUR2,000 to EUR1 million for serious AML violations, as well as heavy fines for failure to perform due diligence or failure to submit an SOS.

For violations of concession obligations, Article 4 of Law No 401/1989 (as subsequently amended) established penalties of imprisonment from three to six years and a fine from EUR20,000 to EUR50,000 for:

• anyone who unlawfully operates the organisation of the Lotto game or of betting or forecasting competitions that the law reserves to the State or to another authorised concessionaire;
• anyone who, in any manner, organises betting or forecasting competitions on sporting events managed by CONI, by entities dependent on CONI, or by UNIRE;
• anyone who organises, operates or remotely collects – without the required concession – any game established or regulated by the ADM;
• anyone who ‒ without a concession, authorisation or licence under Article 88 of TULPS ‒ carries out in Italy any activity aimed at accepting or collecting (or otherwise facilitating the acceptance or collection – including by telephone or telematic means – of) bets of any kind, accepted in Italy or abroad;
• anyone who collects or books Lotto plays, forecasting competitions or bets by telephone or telematic means without specific authorisation from the MEF and/or the ADM to use such means for said collection or booking; and
• “third parties who participate in or promote games or bets organised by entities without a concession (even merely as intermediaries)”.

Article 4 of Law No 401/1989 further imposes penalties of imprisonment from three months to one year and a fine from EUR500 to EUR5,000 for:

• anyone who unlawfully operates public betting on other competitions involving persons or animals and games of skill;
• anyone who sells on the national territory ‒ without ADM authorisation – tickets of lotteries or similar prize-drawing events issued by foreign states, as well as anyone who participates in such operations through the booking of plays and the crediting of related winnings and through promotion or advertising carried out by any means of dissemination;

• anyone who – although holding the required concession ‒ uses methods or technologies other than those provided for by law to organise, operate or remotely collect any game established or regulated by the ADM.

For network service providers, payment service providers, etc, who fail to comply with ADM orders to block access to or block accounts linked to entities without a concession, a fine of between EUR30,000 and EUR180,000 for each detected violation is imposed by Article 4 of Law No 401/1989.

For authorised concessionaires who violate contractual/conventional obligations, MEF Decree No 57/2025 provides for fixed-amount penalties (for serious violations preventing continuation of the concession, or based on days of delay, or within a minimum/maximum set by the concession agreement). A reduction of the penalty is available (up to 30% of the fixed amount in the least serious cases) if the breach is remedied promptly.

Regulation of the tax levy in the gaming sector provides for different methods and rates according to the various types of gaming.

Tax revenues from the sector are both non-tax-related and tax-related. In the first case, the tax levy coincides with the residual tax margin, which is obtained by subtracting the winnings paid to the players and the premium due to the gaming point manager from the total amount of the bets (collections). This levy only applies to the Lotto and to instant and deferred lotteries. The revenue generated by all other types of gaming is instead classified under tax revenue.

Main Tax Levies

PREU

The PREU is a single withdrawal tax on gaming revenue, which was established by Law No 88/2009 and applies to games with cash prizes and betting regulated by the State. The PREU is applied on the following games and bets:

• slot (AWP) machines and VLTs regulated under Article 110, paragraph 6 of TULPS ‒ the tax is applied to the total turnover (ie, the total amount wagered by players);
• sports betting ‒ the tax is calculated either on the amounts wagered or on the winnings paid out;
• casino games (both land-based and online) (eg, roulette, blackjack, poker) ‒ the tax is applied to wagers or to winnings;
• fixed-odds games (such as SuperEnalotto and other lottery games) and instant lotteries (eg, scratch cards) ‒ the tax is applied to the amount wagered;
• bingo (both in physical halls and online) ‒ the tax is applied to the total stakes collected;
• poker and card games (both traditional and online) ‒ the tax is applied to the prizes distributed to winners; and
• other skill-based games with cash winnings.

The PREU is calculated as a percentage of the amounts wagered or winnings distributed. The percentage varies depending on the type of game, but generally ranges from 10% to 20%, with different rates for each gaming category. By way of example:

• for “new slot” (AWP) machines, the rate is 19.25% of the wagered amount; and
• for VLTs, the rate is 6.25% of the wagered amount.

The taxable persons for PREU are:

• operators of slot machines and VLTs ‒ ie, those who manage the machine or the network of machines ‒ whether a physical venue (eg, bar, gaming hall, casino) or an online operator;
• betting concessionaires – for sports betting or other forms of betting, the taxable person is the concessionaire offering the betting service, whether online or through physical outlets;
• casino game operators ‒ both land-based (the entity that manages the casino and collects wagers) and online ‒ provided they are legally operating in Italy;
• bingo operators (ie, the manager of the bingo hall), both physical and online ‒ here too, the PREU is applied to the wagers placed by participants;  and
• remote gaming operators – meaning online gaming operators offering services such as online poker platforms, online casinos and instant games.

The taxable person must pay the PREU to the ADM in accordance with the methods and deadlines established by law.

Single tax

The single tax, established by Legislative Decree No 504/1998, applies to all forms of betting and prediction competitions operating on the national territory, regardless of the operator’s headquarters.

The 2019 Budget Law established differentiated tax rates based on the type of activity carried out, as follows:

• for remote skill games with cash prizes and online bingo, the tax rate is 25% on amounts not returned to the player according to the game rules; and
• for fixed-odds bets (excluding horse race betting), the tax rates are 20% for land-based gaming collections and 24% for online gaming collections and they are calculated based on the difference between the amounts wagered and the winnings actually paid to players (GGR).

The taxable base is:

• for betting pools, the amount paid by the participant for the game, net of fixed fees and compensation to the bettors; and
• for betting, the amount wagered for each bet.

The following are liable for this tax:

• those who manage betting and sports betting competitions – whether licensed or not – using any means (including electronic means) on their own behalf or on behalf of third parties located abroad (Article 3 of Legislative Decree No 504/1998); and
• owners of betting shops operating on behalf of bookmakers, even if they do not directly participate in the betting risk (Article 1, paragraph 66, letter b of Law 220/2010).

When the activity is carried out on behalf of third parties, both the principal and the person physically carrying out the activity are jointly liable for the tax and related penalties.

Winnings obtained at agencies authorised by the ADM do not incur any direct taxation for the player. The sums are paid in full without any withholding tax, given that the tax is borne exclusively by the business operators.

The 2025 Budget Law introduced a 0.5% tax on betting company revenues, specifically earmarked to finance the renovation of national football stadiums.

“Luck tax”

From 1 January 2012, there will be a levy ranging from 6% to 20% for winnings of more than EUR500 in almost all public games controlled by the ADM (8% in the Lotto, 20% in SuperEnalotto, 11% in10eLotto, between 15% and 25% in online casinos, etc).

ISI and VAT rate

The ISI and and the VAT rate (pursuant to Article 74 of the Presidential Decree No 633/1972) are applied for:

• casinos; and
• machines for legal gaming without winnings in money (Article 110, paragraph 7 of TULPS) (billiards, table football, etc).

The taxable base is equivalent to the average annual flat-rate taxable amount by category. The VAT rate is 8%.

Salvasport tax

This was introduced by Legislative Decree No 34/2020 (the “Relaunch Decree”, later converted into law), with bookmakers asked to pay 0.5% of the bets collected in a year.