DENMARK Law and Practice Contributed by: Nina Henningsen, Mazanti-Andersen
3. Legislative Framework 3.1 Key Legislation
DGA. A new and updated certification programme for online betting, land-based betting and online casinos was implemented in 2023, and a new and updated certification programme entered into force on 1 Janu- ary 2025. The provision of gambling in Denmark is subject to the Anti-Money Laundering Act (the “AML Act”) and gen- eral rules on marketing in the Danish Marketing Prac- tices Act, which supplement the marketing provisions in the Gambling Act. Furthermore, financial regulation is relevant in relation to the supply of payment ser- vices, e-money, etc, as well as regulation on consum- er protection in relation to information requirements about players, which can be applicable. Additionally, there are rules on the players’ right to withdraw from a transaction. Finally, licensed games are subject to the Danish Gambling Duties Act. All of the relevant products are permitted according to Danish Law, conditional upon specific requirements. However, it is important to note that commercial lot- The Danish Gambling Act applies to all games offered to the Danish market. A “game” is defined as any activity that falls within one of the following categories: • lotteries, where the chance of winning is solely based on chance; • combination games, where the chance of winning is based on a combination of chance and skill; and • betting (ie, where the chance of winning is depend- ent on the outcome of an event). The Danish Gambling Act applies to all games, regard- less of whether or not payment of a stake is required to participate. However, the Gambling Act only requires a licence for games that are subject to payment of a stake. Activities where the betting concerns the result of an event or game where there is no element of chance, such as participation in sports events or competitions based on knowledge (with no drawing of lots), do not fall within the Danish Gambling Act. teries are run as a monopoly. 3.2 Definition of Gambling
The primary legislation for gambling activities in Den- mark is the Gambling Act supplemented by a series of specific executive orders: • Executive Order No 727 of 9 June 2017 on partial exemption from the Anti-Money Laundering Act for certain games (as amended by Executive Order No 1285 of 27 November 2017 and Executive Order No 465 of 12 May 2025); • Executive Order No 72 of 29 January 2018 on the special contribution to the sport of horse racing; • Executive Order No 1274 of 29 November 2019 on online casinos (as amended by Executive Order No 1010 of 25 May 2021, Executive Order No 19 of 10 January 2022, Executive Order No 720 of 24 May 2022 and Executive Order No 682 of 11 June 2025); • Executive Order No 1276 of 29 November 2019 on online betting (as amended by Executive Order No 1009 of 25 May 2021, Executive Order No 721 of 24 May 2022 and Executive Order No 684 of 11 June 2025); • Executive Order No 1288 of 29 November 2019 on non-profit lotteries (as amended by Executive Order No 1438 of 6 December 2024); • Executive Order No 1289 of 29 November 2019 on gaming machines in arcades and restaurants; • Executive Order No 1290 of 29 November 2019 on land-based casinos (as amended by Executive Order No 1442 of 5 December 2024); • Executive Order No 657 of 26 May 2023 on report- ing etc, to the Anti-Money Laundering Secretariat; • Executive Order No 658 of 30 May 2023 on notifi- cation and publication of information about domes- tic politically exposed persons (PEPs); • Executive Order No 873 of 21 June 2023 on duty payment to the Gaming Authority; • Executive Order No 1140 of 28 August 2023 on land-based betting (as amended by Executive Order No 686 of 11 June 2025); and • Executive Order No 43 of 17 January 2025 on the prevention and combating of match-fixing. Licensed games in Denmark must also be certified in accordance with the certification programme of the
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