regime were not published until August 2020 and it wasn’ t until July 2021 that the permanent licensed market launched.
HUNGARY
REGULATED GAMBLING PRODUCTS: Sports betting, horse race betting, poker, casino, bingo and lottery. OPERATOR TYPE: The state-owned operator Szerencsejáték Zrt has the exclusive right to offer lottery products, while concessions to operate online casino may only be granted to operators that already hold a Hungarian landbased concession. EEA-based gambling operators may apply for an online betting licence. STATUS: Amendments to Hungarian gambling law came into force on 1 October 2015 and allow only two land-based casinos to hold remote casino concessions. The regulator has since issued fines, a number of which have been challenged, against unlicensed operators that continue to target the market. In June of 2017, the ECJ determined that Hungary’ s gambling regime was incompatible with Article 56 TFEU. A subsequent ECJ decision in February 2018 ruled against the Hungarian requirement that online gambling operators are required to have a land-based licence in order to offer online gambling services to Hungarian citizens, thereby further strengthening arguments that the regime is incompatible with EU law. However, it should also be noted that, on 1 January 2023, further amendments to Hungary’ s gambling legislation entered into force so as to introduce a licensing regime that allows eligible EEA-based gambling operators the opportunity to apply for an online betting licence( although it is understood that applicants are required to establish a local branch in Hungary). On 1 July 2023, payment blocking provisions introduced by the amendments entered into force.
IRELAND
REGULATED GAMBLING PRODUCTS: Online betting regulated since August 2015. Online gaming is not specifically accounted for in Ireland’ s outdated legislation and as such is currently unregulated. OPERATOR TYPE: Private operators can apply for a betting licence. STATUS: On 23 October 2024 the President of Ireland signed the Gambling Regulation Act into law. Significantly, the Gambling Regulation Act reforms the way in which gambling is regulated in Ireland through the introduction of a comprehensive B2C and B2B licensing regime and the establishment of the Gambling Regulatory Authority of Ireland( GRAI). The legislation will be implemented in phases, with several provisions having commenced on 5 March 2025. On 5 May 2025, a public consultation on gambling licences( including with respect to application fees, duration and licence conditions) closed. It is anticipated that the GRAI will begin accepting licence applications from December 2025.
ITALY
REGULATED GAMBLING PRODUCTS: Sports betting, horse race betting, poker, casino, bingo and lottery. OPERATOR TYPE: Fully regulated market, although lotteries are the subject of a state monopoly. STATUS: Remote gambling licences are granted within specific application windows. The last tender process for applications closed on 19 March 2018 and licences granted following that tender process were set to expire in December 2022 before the licence term was extended to 31 December 2024 and then – on application to the regulator – certain licences were once again extended to the end of 2025. On 4 April 2024, the‘ Reorganisation
Decree’ was published in the Official Gazette, which sets out the framework for the grant of new licences before 31 December 2024( which are understood to carry a € 7 million fee and last for a period of nine years). The licence application window opened on 31 March 2025 and will close on 30 May 2025, and it is anticipated that the tender process will complete in September of 2025. AGCOM, the Italian communications regulator, has issued sanctions against operators and media companies for violation of the gambling advertising ban( introduced in 2018). Measures to combat unlicensed gambling, including payment blocking measures, entered into effect in October 2019.
LUXEMBOURG
REGULATED GAMBLING PRODUCTS: Lottery. OPERATOR TYPE: Monopoly. STATUS: The general prohibition on gambling appears sufficiently wide to cover all forms of online gambling.
MALTA
REGULATED GAMBLING PRODUCTS: Sports betting, horse race betting, poker, casino, bingo and lottery. OPERATOR TYPE: Private operators can apply for a local licence( except for lottery products). STATUS: In 2018, Malta approved a Gaming Act that replaced all pre-existing gaming legislation with a single piece of legislation, supplemented by secondary legislation. The Gaming Act, with directives and regulations, became effective on 1 August 2018. In June 2023, Malta approved amendments to the Gaming Act, which sets out that Malta will refuse to recognise and / or enforce foreign judgments against operators licensed in Malta that comply with their Maltese obligations.
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