European Gambling Regulation

European Gambling Regulation at a Glance

The overriding theme of European gambling regulation is the tension between increasingly tight player-protection requirements and the market reality of channelisation. Germany, the Netherlands, and – until recently – Sweden have each discovered that restricting the licensed channel aggressively does not eliminate gambling; it redirects it to unlicensed alternatives. The table below provides an orientation for practitioners new to the region.

TOPIC	SUMMARY
Total market size	European online gambling GGR estimated at EUR 35-40 billion in 2025; overall gambling (land and online) approaching EUR 100 billion
Regulatory model	No EU-wide gambling law; each country regulates independently
EU-level instruments	GDPR, AMLA/AMLR/AMLD6 (fully applying July 2027), TFEU free movement principles, Digital Services Act
Licensing approaches	Open multi-operator (UK, Sweden, Denmark, Netherlands, Spain, Italy); state monopoly (Finland until July 2027, Norway); mixed models (Germany, France)
Channelisation challenge	Germany below 40% for online slots; Netherlands below 50% by GGR for the first time since its 2021 launch
Dominant compliance themes	AML/CTF, responsible gambling and duty of care, advertising restrictions, payment blocking, player protection
Key 2025-2026 reforms	Finland ending monopoly (July 2027); Italy new concession system activated November 2025; Germany GlüStV review due December 2026; Sweden credit gambling ban; Netherlands channelisation crisis; UK Remote Gaming Duty increase to 40%
EU AML overhaul	AMLA operational July 2025; AMLR and AMLD6 fully apply July 2027, replacing national AML frameworks with a single EU rulebook

The EU Legal Framework: What Europe Does and Does Not Control

The most important thing to understand about European gambling regulation is what the EU does not do: it does not harmonise gambling law. The Treaty on the Functioning of the European Union (TFEU) recognises gambling as a matter of national policy, allowing member states to restrict gambling services from other member states on public interest grounds, provided those restrictions are non-discriminatory and proportionate. Landmark CJEU cases including Gambelli, Placanica, and Liga Portuguesa have shaped national licensing frameworks across the continent.

What the EU does provide is a set of horizontal legal instruments that gambling operators – like all other businesses – must comply with, and which are increasingly shaping how national frameworks are designed.

GDPR and gambling

The General Data Protection Regulation (GDPR) applies in full to gambling operators. Player data – identity verification records, betting history, self-exclusion status, financial transaction records – falls squarely within scope. Gambling operators typically hold some of the most sensitive categories of behavioural and financial data held by any consumer-facing business. Key obligations include a lawful basis for processing at each stage of the player journey; data retention and deletion policies; rights to access, portability, and erasure; data breach notification within 72 hours; and Data Protection Impact Assessments (DPIAs) for high-risk processing.

The EU AML Package – the biggest shift in European gambling compliance since 2015

Three interlocking instruments replace the five previous AML directives and represent the most significant restructuring of European AML law in two decades. The practical compliance deadline for gambling operators is July 10, 2027.

The Anti-Money Laundering Regulation (AMLR, Regulation 2024/1624) is a directly applicable EU regulation – meaning it will supersede national AML rules for gambling operators from July 10, 2027, without requiring national transposition. The same CDD rules, beneficial ownership thresholds, and suspicious transaction reporting requirements will apply from Malta to Finland.

The Sixth Anti-Money Laundering Directive (AMLD6, Directive 2024/1640) addresses national supervisory structures, FIU powers, and beneficial ownership registers. Member states must transpose it by July 10, 2027.

The Anti-Money Laundering Authority (AMLA) became operational on July 1, 2025, and is based in Frankfurt. AMLA will directly supervise up to 40 high-risk obliged entities once it assumes full supervisory powers in 2027. For gambling operators, the more immediate impact is indirect: AMLA is publishing 23 regulatory technical standards through 2026 that define how the AMLR applies in practice.

Key changes gambling operators should prepare for under the AMLR:

• Beneficial ownership identification threshold lowered from ‘more than 25%’ to ‘25% or more’ of shares or voting rights
• Harmonised CDD obligations across all EU member states – currently, thresholds and EDD triggers vary significantly between, for example, Germany and Malta
• Uniform suspicious transaction reporting requirements and timelines
• Senior management personal liability enabled where penalties are applicable for AML breaches – sanctions can fall on individuals, not just the operator entity
• Crypto-asset service providers (CASPs) brought fully within scope – important for operators accepting crypto payments

Compliance deadline.
AMLA became operational July 1, 2025. The AMLR and AMLD6 fully apply from July 10, 2027. AMLA is publishing 23 technical standards through 2026 that define how the rules apply in practice. Operators should treat July 2027 as the hard compliance deadline for AML programme alignment across all EU operations.

TFEU and the single market

Articles 56-62 TFEU govern the free movement of services. CJEU gambling case law has established that while member states can restrict cross-border gambling services for public interest reasons – public order, fraud prevention, problem gambling – those restrictions must be coherent and systematic. A state cannot simultaneously liberalise gambling domestically while citing public order as the reason to exclude foreign operators. This principle underpins every legal challenge to national licensing frameworks. It also explains why Finland’s monopoly, with a 50% channelisation rate, became legally and politically untenable.

The Digital Services Act

The Digital Services Act (DSA), fully in force since February 2024, applies to online gambling platforms as online intermediaries. Illegal content – gambling services operating without a licence in a given market – can be removed or blocked under DSA notice-and-action mechanisms. Very large online platforms and search engines face obligations around recommending or advertising unlicensed gambling. Several national gambling regulators, including the KSA in the Netherlands and the GGL in Germany, are actively exploring DSA tools to supplement their existing enforcement powers against unlicensed operators.

National Regulatory Frameworks: Three Models

European national gambling frameworks cluster into three broad models, each reflecting a different set of policy choices about competition, state interest, and player protection. Understanding which model a jurisdiction follows is the first step in any market entry or compliance analysis.

Model 1 – Open, multi-operator licensed markets. Multiple operators compete for licences subject to requirements covering financial integrity, technical certification, responsible gambling tools, and AML compliance. The most commercially significant model in Europe. Examples: UK, Sweden, Denmark, Malta, Spain, Italy, Netherlands, Romania, Czech Republic.

Model 2 – State monopoly or near-monopoly. A state-owned operator holds exclusive rights over some or all gambling verticals. Increasingly difficult to sustain legally as digital alternatives erode effective enforcement. Examples: Finland (until July 2027), Norway (Norsk Tipping). The Finnish reform is the most watched monopoly-to-competition transition in Europe since Sweden’s in 2019.

Model 3 – Mixed models. State monopoly retained for certain formats – typically lotteries and physical slot machines – while competitive licensing applies to sports betting and online casino. Examples: Germany, France, Sweden (Svenska Spel retains lottery monopoly; competitive licences for online casino and betting).

Regional regulatory overview

COUNTRY	REGULATOR	ONLINE MODEL	GGR TAX	KEY 2025-2026 DEVELOPMENT
UK	Gambling Commission	Open multi-operator	40% Remote Gaming Duty (from April 2026)	RGD increase to 40%; statutory levy from April 2025; slot stake limits in force
Germany	GGL	Mixed (competitive online; lottery monopoly)	5.3% per bet (sports); EUR 1 per slot hour	GlüStV 2021 evaluation due December 2026; IP blocking court ruling March 2025
Italy	ADM	Open multi-operator	25% GGR (online casino)	52 licences to 46 operators; EUR 7m fee; new concessions activated November 2025
France	ANJ	Open (sports, horse racing, poker only)	7.5% GGR (sports betting); 2% per hand (poker)	Online casino prohibition under review; advertising tightening
Spain	DGOJ	Open multi-operator	20% GGR	Mandatory risk-detection algorithm from 2026; strict advertising restrictions
Sweden	Spelinspektionen	Open multi-operator	22% GGR	Credit gambling ban from May 2026; Spelpaus API upgrade August 2026; Casino Cosmopol closed 2026
Netherlands	KSA	Open multi-operator	34.2% GGR (2025)	Channelisation below 50% by GGR; Remote Gambling Act reform underway; operator exits
Denmark	Spillemyndigheden	Open multi-operator	28% GGR	Mature market; online well above 50% of total gambling revenue
Malta	MGA	Open multi-operator (B2B and B2C)	5% on qualifying revenue	Major B2B/B2C licensing hub; ongoing enforcement of licensee conduct abroad
Finland	New supervisory agency	Monopoly until July 2027; multi-operator from July 2027	22% GGR (from 2027)	Applications open March 2026; 24 received; market launches July 1, 2027
Belgium	Gaming Commission	Open multi-operator (limited)	11% GGR	Near-blanket advertising ban progressing through legislature
Ireland	GRSA	Building licensing framework	TBD	Gambling Regulation Act 2024; licensing expected 2026-2027
Portugal	SRIJ	Open multi-operator	15-30% GGR (tiered)	Stable; competitive market well established
Czech Republic	Ministry of Finance	Open multi-operator	23% GGR	Added live dealer games 2024; operators may serve players outside Czech territory

Key Regulated Markets in Depth

Six markets drive the majority of European gambling law practice and operator investment. Each is at a distinct regulatory moment in 2026 and presents a different compliance and commercial risk profile for lawyers, operators, and investors.

United Kingdom

The United Kingdom is Europe’s largest gambling market and operates an entirely separate legal framework since Brexit. The Gambling Commission (UKGC), established under the Gambling Act 2005, is the primary regulator. The Act is undergoing its most significant overhaul since 2005, driven by the April 2023 White Paper and implemented through rolling statutory changes and LCCP updates.

Key 2025-2026 developments:

• Online slot stake limits: GBP 5 per spin for adults aged 25+ and GBP 2 for adults aged 18-24, in force from 2025; applies to online slots only
• Statutory levy: mandatory operator levy from April 6, 2025, replacing voluntary arrangements; funds research, education, and treatment for gambling harm
• Remote Gaming Duty: increased from 21% to 40% from April 1, 2026; the most significant tax change for UK operators since the point-of-consumption switch
• Financial risk checks: light-touch checks triggered at GBP 150 net deposits in a rolling 30-day period; frictionless enhanced assessments for higher spenders under development
• Point-of-consumption model: any operator serving UK consumers must hold a UKGC licence regardless of corporate location; 21% Remote Gaming Duty applied wherever the operator is incorporated
• UKGC enforcement: record GBP 60.9 million in regulatory settlements in 2024-2025; AML and social responsibility failures remain the dominant enforcement categories
• GamStop: all UKGC-licensed operators must participate in the national online self-exclusion scheme; single registration blocks access across the entire licensed market

Germany

Germany’s Interstate Treaty on Gambling (GlüStV 2021) introduced a unified federal framework in July 2021. Four years in, the licensed market is underperforming: channelisation for online slots sits below 40%, and unlicensed operators are estimated to offer 9.2 times more products than the legal market. A formal evaluation of the framework is required by December 31, 2026 – the most significant review since its inception.

The GGL (Gemeinsame Glucksspielbehorde der Lander) is Germany’s joint federal gambling authority, responsible for issuing licences and maintaining the LUGAS national deposit monitoring system.

Key issues:

• Product restrictions: EUR 1 maximum stake per spin on online slots; EUR 1,000 monthly deposit cap across all licensed operators tracked through LUGAS; no online casino table games; no live dealer games; no simultaneous multi-operator play
• IP blocking setback: a March 2025 Federal Administrative Court ruling (Case 8 C 3.24) held that the GGL has no valid legal basis for IP blocking under current statute – a significant enforcement limitation
• Second Amending Treaty: state interior ministers are fast-tracking a Second Amending Treaty ahead of the formal December 2026 review deadline, focused on restoring IP blocking powers
• 2026 review: the GGL is examining whether stake limits, deposit caps, and product restrictions can be reformed to improve channelisation; the review is widely expected to produce a verdict that the current framework has not achieved its channelisation goals
• Tax structure: 5.3% per bet for sports betting; EUR 1 per virtual slot game hour – a structure that penalises volume rather than revenue and adds compliance complexity

Italy

Italy completed the most significant structural reform of its online gambling licensing system in over a decade in November 2025. Legislative Decree No. 41/2024 replaced dozens of expiring concessions – previously priced at EUR 200,000 – with a consolidated system of 52 concessions awarded to 46 operators at EUR 7 million each, generating EUR 364 million in licensing revenue for the state.

Key features of Italy’s 2025 licensing reform:

• Concession fee: EUR 7 million one-time fee (EUR 4 million on award; EUR 3 million on launch), plus an ongoing annual fee of 3% of net revenues
• Incorporation requirement: operators must be incorporated in the EU or EEA; non-Italian entities must maintain a registered office in Italy for tax purposes
• ISO certification: ISO 9001 (quality management), ISO 26000 (social responsibility), and ISO 27001 (data security) are now embedded in concession requirements – the first time international management standards have been required in Italian gaming law
• Single-domain rule: one brand per concession; player database migration from exiting operators to new concessionaires was mandatory by November 2025
• Concession duration: nine-year concessions running to 2034
• Advertising: the 2018 Dignity Decree blanket ban on gambling advertising and sports sponsorship remains nominally in force; potential repeal via a new Sports Law is under active consideration – the sector’s most commercially significant open question

Netherlands

The Netherlands is the most instructive current case study in European gambling regulation – for the wrong reasons. The Remote Gambling Act (KOA) launched in October 2021. By 2025, channelisation had fallen below 50% by GGR for the first time – meaning more money is wagered with unlicensed operators than licensed ones. Rather than generating the additional EUR 200 million in annual tax revenue the government anticipated, the 2025 GGR tax increase resulted in a tax revenue shortfall.

The KSA (Kansspelautoriteit) is the Dutch gambling regulator. Its 2026 supervisory agenda, titled ‘putting the player first’, identifies five priorities: combating illegal gambling, protecting vulnerable groups, duty-of-care monitoring, advertising compliance, and AML under the new EU framework.

Key issues:

• Tax: GGR tax rose from 30.5% to 34.2% from January 2025; a potential further increase to 37.8% from January 2026 is under review – itself a signal of how poorly the tax-channelisation relationship has been managed
• Operator exits: several operators have left the market citing the combination of rising taxes and compliance costs as commercially unsustainable
• Ecosystem enforcement: KSA has shifted from case-by-case site blocking to disrupting the infrastructure of illegal gambling: near-elimination of paid search ads for illegal sites on Google since August 2025; domain takedowns via SIDN registry; B2B game supplier commitments to geoblock unlicensed platforms
• Duty-of-care fines: the KSA fined five licensed operators a combined EUR 8.6 million in 2025, largely for duty-of-care failures following dossier-style investigations into cases of extreme player losses
• Extended supervision: payment providers, hosting companies, social media platforms, and B2B game suppliers all face expanded KSA supervision in 2026 and beyond – a significant widening of the regulatory perimeter
• Legislative reform: the Remote Gambling Act is under active reform; the new coalition government has committed to repealing and replacing the KOA with a focus on tighter advertising restrictions and stronger player protection

Sweden

Sweden liberalised its gambling market in January 2019 under the Gambling Act (SFS 2018:1138), overseen by Spelinspektionen. The Swedish model – multi-operator licensing, Spelpaus national self-exclusion, 22% GGR tax, and active enforcement – is the Nordic region’s template and a relative channelisation success story. Online gambling represents well over half of total gambling revenue. 2026 marks a year of significant new compliance obligations for Swedish operators.

Key 2025-2026 developments:

• Credit gambling ban: from May 2026, all licensed operators are prohibited from processing payments funded through credit cards, overdrafts, personal loans, or buy-now-pay-later services – the first complete credit gambling ban by an EU/EEA jurisdiction
• Spelpaus upgrade: from August 2026, operators must connect to a redesigned Spelpaus API using regulator-issued Actor IDs and API Keys; self-exclusion verification becomes a real-time active compliance duty rather than a passive consumer safeguard; registrations now exceed 134,500 individuals
• Casino Cosmopol closures: all state-owned land-based casino venues closed in 2026, completing Sweden’s shift to a purely digital competitive casino market
• Jurisdictional loophole closed: the ‘directional criterion’ – which previously allowed some operators to avoid Swedish law by using non-Swedish language and currency – is being removed; the Gambling Act now covers any operator making services available to Swedish players regardless of language or currency
• B2B supplier liability: Spelinspektionen has issued fines and warnings to software suppliers whose games appeared on unlicensed platforms, following a January 2024 precedent-setting enforcement decision

Finland

Finland’s transition from state monopoly to licensed competition is the most significant structural change to a European gambling market since Sweden’s liberalisation in 2019 – and it is still in progress. Parliament passed a new Gambling Act in December 2025 ending Veikkaus’ monopoly on online betting and casino games. By 2026, Veikkaus estimated its own market share at just 51% – meaning roughly half of Finnish online gambling was already happening outside regulatory oversight.

Key facts:

• Market launch: July 1, 2027; B2C licence applications opened March 1, 2026; 24 applications received in the opening phase
• Products moving to competitive licensing: fixed-odds sports betting, online casino games, online slots, online bingo, pari-mutuel betting
• Products remaining under Veikkaus monopoly: lottery, scratch cards, physical slot machines, land-based casino
• GGR tax: 22%; annual supervision fee EUR 4,000-434,000 based on GGR volume
• Player protection requirements: mandatory national self-exclusion register (all operators must be connected); deposit limits set before first play; full identity verification
• B2B licensing: begins July 2027; from 2028, B2C operators must use only licensed B2B providers
• Market size: total estimated Finnish GGR EUR 1.9 billion in 2026 (H2 Gambling Capital); approximately 81% from online channels
• Enforcement gap: there is no comprehensive payment blocking mechanism for unlicensed operators under the new framework – a noted limitation that will test post-launch channelisation

Germany and the Netherlands: a shared warning.
Both markets demonstrate that if the licensed channel is materially less attractive than unlicensed alternatives – through restrictive product rules, high taxes, or both – players migrate to illegal platforms and the framework fails its own objectives. Germany’s sub-40% channelisation for online slots and the Netherlands’ fall below 50% by GGR are the two most-cited data points in the current European debate about whether tighter regulation is achieving its stated goals or undermining them.

Responsible Gambling and Player Protection Across Europe

Responsible gambling obligations have become the central compliance challenge in European licensed markets, displacing AML as the primary enforcement driver in the UK, Netherlands, and Sweden. The direction of travel is consistent: higher duty-of-care obligations, more personalised player monitoring, affordability and financial risk assessments, stricter advertising rules, and national self-exclusion systems. The specifics vary considerably by jurisdiction.

Duty of care and affordability

The concept of ‘duty of care’ – the legal obligation on an operator to take positive steps to protect a player from gambling harm, rather than simply responding when a player asks for help – is now the dominant compliance framework in the UK and Netherlands. In the UK, the Gambling Commission has pursued operators for failing to identify and intervene where customers showed signs of harm, even where those customers had not self-excluded. Financial risk assessments require operators to flag accounts where spending appears disproportionate to likely financial means.

In Germany, the affordability framework centres on the EUR 1,000 monthly deposit limit – but the definition of ‘affordability’ for allowing a limit increase is legally undefined, creating compliance uncertainty that the GGL is trying to resolve through the 2026 review. In the Netherlands, the KSA’s dossier-style investigations into extreme player losses and its EUR 8.6 million fine package in 2025 confirm that duty of care is an active enforcement priority, not a compliance checklist.

National self-exclusion systems

COUNTRY	SYSTEM	KEY FEATURE
UK	GamStop	National online scheme; all UKGC-licensed operators must be members; single registration blocks access across the licensed market
Sweden	Spelpaus.se	National register; real-time API integration mandatory for all operators from August 2026; 134,500+ active registrations
Netherlands	CRUKS	Central register; operators must check before onboarding and periodically thereafter
Germany	National exclusion database	Linked to LUGAS deposit monitoring system; cross-operator enforcement
Finland	National register (from 2027)	Mandatory national self-exclusion register; operators must be connected; deposit limits set before first play
Italy	ADM system	National register maintained by ADM; mandatory operator checking at onboarding

Advertising restrictions across Europe

Advertising is the most variable area of responsible gambling regulation in Europe. The range runs from near-total prohibition to managed liberalisation:

• Italy: the 2018 Dignity Decree imposes a blanket ban on all gambling advertising and sports sponsorship; potential reform under a new Sports Law remains commercially significant but unresolved
• Belgium: comprehensive advertising restrictions progressing toward near-blanket ban through the legislature
• Netherlands: untargeted advertising including sports sponsorship is prohibited; role models such as celebrities and influencers cannot promote gambling; KSA actively enforces cross-border cases
• Sweden: advertising must be ‘moderate’ and not target vulnerable groups; credit gambling ban from May 2026 extends the protective framework to payment methods
• UK: gambling-free kit sponsorship being phased into Premier League; enhanced age-gating for digital marketing; mixed-product bonus promotions prohibited
• Germany: advertising permitted for licensed products under GGL oversight; broadcast time restrictions apply; clear distinction between licensed and unlicensed product promotion
• Spain: advertising banned 1am-5am; no celebrity or sports-star endorsements; no bonus promotions targeting non-active customers

Safer gambling tools required across licensed markets

The following tools are required in most or all European licensed markets and represent the compliance baseline any operator should meet:

• Deposit limits (daily, weekly, monthly)
• Loss limits and cooling-off periods
• Session time limits and reality checks
• Self-exclusion (temporary and permanent), linked to national registers
• Age verification at account opening
• Prohibition on auto-play features (UK; under review in other jurisdictions)
• Prohibition on gambling with credit (now including Sweden from May 2026)

AML Compliance in European Gambling

AML compliance is a statutory requirement for gambling operators in every EU member state – gambling services have been ‘obliged entities’ under EU AML law since the Fourth AML Directive in 2015. The enforcement landscape is intensifying: the EU’s AML package represents the most significant restructuring of European AML law in two decades, and the AMLR applying directly from July 2027 will materially raise the compliance baseline in jurisdictions where standards have historically been lower.

Current obligations under AMLD4/5 (in force now)

All EU-licensed gambling operators must currently maintain:

• Registration as an obliged entity with their national AML supervisor
• A risk-based AML programme covering CDD, EDD for high-risk customers, ongoing monitoring, and suspicious activity/transaction reporting
• CDD applied at the EUR 2,000 transaction threshold for casino gambling (member states have discretion to lower this)
• Screening of customers against PEP and sanctions lists
• A designated Money Laundering Reporting Officer (MLRO)
• Regular staff AML training
• Record-keeping for at least five years

What changes under the AMLR from July 2027

The changes with the most immediate operational impact for gambling operators:

• Beneficial ownership threshold: lowered from ‘more than 25%’ to ‘25% or more’ of shares or voting rights; operators must update UBO identification processes and internal records accordingly
• Harmonised CDD: the same customer due diligence rules will apply across all EU member states; operators running multi-market compliance programmes need to model the uplift required in lower-standard jurisdictions
• Uniform STR format and timelines: consistent suspicious transaction reporting obligations across member states replace the current national variation
• Personal liability: national supervisors enabled to impose sanctions on individual senior management and compliance officers responsible for AML breaches, not just the operator entity
• Crypto in scope: gambling operators accepting crypto must ensure their payment processors are compliant CASPs

National AML enforcement priorities in 2025-2026

The UK Gambling Commission remains the most active gambling AML enforcer in Europe. AML-related regulatory settlements have totalled hundreds of millions of pounds over five years, and AML and social responsibility remain the two dominant enforcement categories. The statutory levy from April 2025 is partly designed to cross-subsidise AML research and enforcement capacity.

In the Netherlands, the KSA expanded AML supervision in 2026 to cover payment providers and B2B suppliers, not just licensed operators. Italy embedded AML compliance directly into the new concession terms – failure to meet AML standards can trigger termination of a nine-year concession. Germany’s GGL shares AML oversight with BaFin and Lander-level supervisors under the federal Anti-Money Laundering Act (Geldwaschegesetz).

Licensing and Market Entry Considerations

For operators, B2B suppliers, and investors considering or expanding European gambling operations in 2026, the licensing landscape presents more variation than at any recent period. Three markets in particular offer well-defined entry windows; three established markets are in active regulatory review with uncertain trajectories; and the EU’s AML overhaul is raising the compliance baseline for every jurisdiction simultaneously.

Malta as a pan-European licensing hub

Malta’s Gaming Authority (MGA) operates a well-established B2B and B2C licensing regime within the EU single market. An MGA B2C licence does not authorise operation in any specific national market – operators serving UK, Swedish, Italian, German, or Dutch players need local licences in each jurisdiction. However, the MGA provides a credible base that many national regulators treat as evidence of regulatory standing during their own application processes.

Annual MGA fees: EUR 25,000 per year for B2C Gaming Service Licences; EUR 10,000 for B2B Critical Gaming Supply Licences. Qualifying revenue from Malta-based players is taxed at 5%; players in other EU jurisdictions are taxed under local rules. There is no passporting of an MGA licence across European markets.

The absence of EU-wide harmonisation creates a specific and increasingly litigated tension between Malta and several other member states, most significantly Germany and Austria. Both countries operate gambling frameworks that prohibit or severely restrict the online casino and slot products that MGA-licensed operators have historically offered to their residents. Malta’s position, grounded in Article 56 TFEU and the freedom to provide services, is that a product legally licensed in Malta can be offered across the EU without further national authorisation. Germany and Austria contest this position, maintaining that their domestic prohibitions take precedence and that contracts concluded in breach of those prohibitions are null and void — entitling players to recover losses as if the gambling contract had never existed.

A cottage industry of player claims law firms, predominantly in Germany and Austria, has grown around this dispute. German and Austrian civil courts have issued numerous judgments ordering MGA-licensed operators to repay player losses incurred before Germany’s 2021 licensing framework and in breach of Austria’s monopoly regime. In 2023, Malta passed the controversial Article 56A of the Gaming Act (“Bill 55”), which directs Maltese courts to refuse recognition and enforcement of foreign judgments where those judgments contradict the legality of gaming services provided under an MGA licence. Germany and the European Commission challenged this measure as incompatible with EU mutual recognition principles, and the Commission opened an examination of the law’s compatibility with EU law. The MGA has not required its licensed operators to comply with foreign loss-recovery judgments, leaving enforcement dependent on whether claimants can execute awards against Maltese assets.

The dispute has been substantially resolved in favour of the claimant states by two landmark CJEU rulings in 2026. In January 2026, the court confirmed that players may pursue personal liability claims against company directors under the law of their home country. In April 2026, the court issued a binding preliminary ruling in Case C-440/23 (the Lottoland case), confirming that EU law does not preclude member states from prohibiting online gambling services licensed elsewhere in the EU, that contracts concluded in breach of those prohibitions are void, and that players are entitled to file civil claims to recover losses. The court also held that Germany’s subsequent legalisation of online gambling in 2021 did not retroactively validate prior unlicensed operations. With thousands of pending claims now able to proceed and legal experts estimating potential refunds in the billions of euros across Germany alone, the Maltese Bill 55 shield — while still formally in place — is now required to be read in light of the CJEU’s interpretation. Operators with historical grey-market exposure in Germany, Austria, or the Netherlands should treat this as an active legal risk requiring immediate assessment.

Finland: the most time-sensitive opportunity in European gambling law

Finland is a first-mover play in an affluent, digitally native market with an estimated total GGR of EUR 1.9 billion in 2026 and no established competitive entrenchment among private operators. The compliance preparation window is 2026; the market launches July 1, 2027. Assembling the required AML framework, technical certification, and local representative arrangements typically takes six to nine months, which means operators targeting a Day 1 launch position need to be acting now.

B2C licence applications are open under the new Gambling Act. B2B licensing begins July 2027. From 2028, B2C operators will be required to use only licensed B2B providers. The 22% GGR tax sits at the higher end of Northern European markets. Note that there is no comprehensive payment blocking mechanism for unlicensed operators post-launch – this will test the framework’s channelisation effectiveness.

Italy: entry through M&A only

Italy’s 2025 tender process is complete. The nine-year concession window runs to 2034. Operators who did not participate can now only enter the Italian market through acquisition of, or partnership with, an existing concessionaire. The EUR 7 million entry fee and the consolidation to 52 licences has created an active secondary market in Italian gambling M&A. Due diligence must assess AML programme adequacy under the new concession framework – ADM can terminate concessions for AML failures.

Ireland: the English-language opportunity

The Gambling Regulatory Authority of Ireland (GRSA) is building out its regulatory capacity under the Gambling Regulation Act 2024. Ireland is an English-language market with strong cultural alignment to sports betting. The framework, once fully operational, is expected to be broadly similar in structure to the UK model. Operators should begin pre-engagement with the GRSA process in 2026 to position for the licensing phase expected in 2026-2027.

Germany: enter with realistic expectations

No B2C licence in Germany should be pursued without understanding the structural competitive disadvantage of operating only the licensed product set. The EUR 1 stake limit, the EUR 1,000 deposit cap, and the prohibition on live dealer games mean the licensed market is materially less competitive than unlicensed alternatives. The 2026 GlüStV evaluation may produce reform – but operators entering Germany should model entry economics under both the current framework and a potential reformed version, and should not assume reform will arrive quickly or comprehensively.

No passporting.
There is no European gambling licence that authorises operation across multiple jurisdictions. An operator serving players in the UK, Germany, Italy, Sweden, and the Netherlands simultaneously holds five entirely separate licences under five separate regulatory frameworks, each with its own compliance obligations, audit requirements, enforcement priorities, and reform trajectory.

The Reform Wave: Key Developments Across Europe

European gambling regulation in 2025 and 2026 is in its most active reform period in a decade. The tracker below covers the most significant current and recent developments.

COUNTRY	DEVELOPMENT	DIRECTION	STATUS (MID-2026)
Finland	New Gambling Act; monopoly ends July 2027	Liberalisation	24 B2C applications received; market launches July 1, 2027
Germany	GlüStV 2021 formal evaluation due December 2026	Review	Outcome will determine whether product restrictions and deposit caps are reformed
Germany	Second Amending Treaty to restore IP blocking powers	Tightening (enforcement)	Draft endorsed by Interior Ministers; federal states initiating legislative process
Italy	New concession system activated November 2025	Consolidation	52 licences to 46 operators; nine-year framework; EUR 364m in licensing revenue
Italy	Potential repeal of 2018 Dignity Decree advertising ban	Potential liberalisation	New Sports Law pending; uncertain timeline; commercially significant for operators
Netherlands	Remote Gambling Act (KOA) replacement	Tightening	New coalition government; reform focused on advertising restrictions and player protection
Netherlands	GGR tax potential increase to 37.8%	Tax increase risk	Announced for 2026; implementation under review amid worsening channelisation data
Sweden	Complete credit gambling ban	Tightening	In force from May 2026; first complete credit gambling ban by an EU/EEA jurisdiction
Sweden	All Casino Cosmopol venues closed	Market structure	Completed 2026; digital-only competitive casino market now fully established
UK	Remote Gaming Duty increase to 40%	Tax increase	In force April 1, 2026; most significant tax change for UK operators since point-of-consumption switch
UK	Online slot stake limits and statutory levy	Tightening	Stake limits in force from 2025; statutory levy from April 2025
Ireland	GRSA building regulatory capacity	Formalisation	Gambling Regulation Act 2024; licensing phase expected 2026-2027
Belgium	Near-blanket advertising ban	Tightening	Progressing through legislature; expected to be among Europe’s most restrictive regimes
EU-wide	AMLA operational; AMLR/AMLD6 apply July 2027	Harmonisation	23 technical standards being published through 2026; compliance deadline July 2027
EU-wide	DSA enforcement expanding to gambling context	Tightening	Regulators exploring DSA tools against unlicensed operators and illegal gambling advertising

Frequently Asked Questions

Is there a single European gambling licence?

No. There is no pan-European gambling licence and no EU-wide gambling regulator. Each country in Europe sets its own licensing requirements, taxes, and permitted products. A licence in one country does not authorise operation in another. Operators serving players across multiple European markets must hold a separate local licence in each jurisdiction where they are targeting players.

What is the EU’s role in gambling regulation?

The EU does not harmonise gambling law. However, EU-wide instruments apply to gambling operators: GDPR (data protection), the EU AML package including AMLA, the AMLR, and AMLD6 applying fully from July 2027, the Digital Services Act, and TFEU free movement principles. The Court of Justice of the EU defines when national restrictions on cross-border gambling services are legally valid under EU law.

What is AMLA and why does it matter for gambling operators?

AMLA (the Anti-Money Laundering Authority) became operational in Frankfurt on July 1, 2025. Together with the Anti-Money Laundering Regulation (AMLR) and AMLD6, it replaces the previous EU AML directives with a single directly applicable rulebook from July 10, 2027. For gambling operators, this means the same customer due diligence rules, beneficial ownership thresholds, and suspicious transaction reporting requirements will apply across every EU member state, replacing the current variation between national AML regimes.

Is online gambling legal in Germany?

Yes. Online sports betting, virtual slot games, and online poker are legal under federal licences issued by the GGL under the Interstate Treaty on Gambling (GlüStV 2021). Online casino table games and live dealer games remain prohibited. The market is heavily restricted: a EUR 1 maximum stake per spin on online slots and a EUR 1,000 monthly deposit cap apply across all licensed operators. The GlüStV 2021 formal evaluation is due by December 31, 2026 and may lead to reforms of these restrictions.

How does Germany’s Interstate Treaty on Gambling work?

The GlüStV 2021 is a treaty between Germany’s 16 federal states, creating a unified national gambling framework for the first time. It is implemented by state-level legislation in each Land and overseen by the GGL (Gemeinsame Glucksspielbehorde der Lander), the joint federal authority that issues licences and enforces the framework. Licensed products include online sports betting, virtual slots, and poker. A formal evaluation of the treaty’s performance is due by December 31, 2026.

What happened in Italy’s gambling licence reform?

Italy activated a new online gambling concession system in November 2025. The ADM awarded 52 concessions to 46 operators after a competitive tender, each priced at EUR 7 million and running to 2034. This replaced the old EUR 200,000 concession model. Operators must now be incorporated in the EU or EEA, meet ISO certification standards, and operate under a single domain per licence. The tender generated EUR 364 million in licensing revenue for the Italian state.

When does Finland open its gambling market to competition?

Finland’s licensed gambling market opens on July 1, 2027, following the December 2025 passage of a new Gambling Act ending Veikkaus’ monopoly on online betting and casino games. B2C licence applications opened March 1, 2026 and received 24 applications in the opening phase. The market will be subject to a 22% GGR tax and strict responsible gambling requirements. Veikkaus retains exclusivity over lotteries, scratch cards, and physical gaming machines.

What is channelisation and why does it matter in European gambling law?

Channelisation is the share of gambling activity that takes place with licensed rather than unlicensed operators. It is the central metric for evaluating whether a national gambling framework is working in practice. Germany’s online slot market has fallen below 40% channelisation; the Netherlands fell below 50% by GGR for the first time in 2025. Both show that if the licensed market is significantly less attractive than unlicensed alternatives, players migrate to illegal platforms and the framework fails its own objectives.

What are the responsible gambling requirements across Europe?

Responsible gambling requirements vary by jurisdiction but typically include mandatory deposit limits, loss limits, session time limits, age verification at account opening, national self-exclusion registers, and prohibition on advertising to vulnerable groups. Duty-of-care obligations requiring operators to monitor player behaviour and intervene proactively are increasingly enforced in the UK, Netherlands, and Sweden. Sweden became the first EU jurisdiction to impose a complete ban on gambling with credit, effective May 2026.

What is Malta’s role in European gambling licensing?

Malta’s Gaming Authority (MGA) operates a well-established B2B and B2C licensing regime within the EU. An MGA licence does not authorise operation in any specific national market – operators serving UK, Swedish, Italian, Dutch, or German players need separate local licences. However, the MGA provides a credible base licence recognised by many national regulators as evidence of regulatory standing. Annual B2C fees are EUR 25,000; B2B critical gaming supply licences cost EUR 10,000 annually.

What is the Netherlands’ channelisation problem?

The Dutch licensed online gambling market opened in October 2021 but by 2025 channelisation had fallen below 50% by GGR for the first time – meaning more money is now wagered with unlicensed operators than licensed ones. Rising GGR taxes (34.2% in 2025, with a potential further increase proposed), strict advertising restrictions, and duty-of-care obligations have made the licensed market commercially unattractive compared to offshore alternatives. Several operators have already exited the market.

About IMGL

The International Masters of Gaming Law (IMGL) is a global, non-profit association of the world’s leading gaming lawyers, regulators, and industry experts. For specialist advice on any of the jurisdictions covered in this guide, use the IMGL Member Directory to find a qualified gaming lawyer in your region.