Gaming Law 2025

DENMARK Law and Practice Contributed by: Nina Henningsen, Mazanti-Andersen

Land-Based Gambling The process when applying for a land-based casino licence and a licence to set up gaming machines is similar to the one described above, supplemented by the executive orders on land-based casinos and gaming machines in arcades and restaurants. Accord- ingly, there are, for example, requirements for persons working within a land-based casino. At the time of writing (November 2025), there are sev- en land-based casino licences in Denmark. For now, it is not possible to apply for new land-based casino licences. It will only be possible to apply for a licence when one of the current licences becomes available or if the DGA allows new applications. 4.7 Application Timing As stated in 4.6 Application Requirements , it normally takes between three and six months from the submis- sion of an application to the DGA issuing a licence. 4.8 Application Fees The application fee is DKK327,500 for a betting licence or an online casino licence; however, if the party applies for a combined betting and online casino licence, the fee is DKK458,500 (2025 prices). The application fee for a B2B game supplier licence is DKK64,500 (2025 price). For applicants with a GGR of less than DKK1 million, a “revenue-restricted” licence may be issued, and the fee is DKK65,500 per licence (2025 price). 4.9 Ongoing Annual Fees Online gambling operators have to pay an annual fee for holding a licence. The fee is based on their GGR. Additionally, the licence holders have to pay gambling duty based on their GGR (see 12.1 Tax Rate by Sec- tor ). For B2B game suppliers, the annual fee is DKK43,000. Since 1 January 2025, gaming machines have been subject to an annual fee based on the licensee’s GGR for the previous year, which must be paid by the end of January of the current year. If the realised GGR either exceeds or is lower than the basis for the fee

EU/EEA or have an appointed representative in Den- mark. Furthermore, the members of the board and the direc- tors must meet the requirements for physical persons mentioned above. When appointing a representative, the representative must be approved by the DGA and, in order to obtain this approval, the representative must meet require- ments similar to those imposed on physical persons mentioned above. If these minimum requirements are met, the applicant must further prove that it will be able to provide online gambling in a sound financial and professional man- ner. The assessment is made by the DGA based on a large number of financial and technical documents, which the applicant is required to submit. The requirements for a revenue-restricted licence are less comprehen- sive. The DGA may either choose to grant a full licence, grant a conditional licence or reject the application. Applicants failing to submit sufficient documentation or failing to live up to the requirements set forth by the DGA will normally be given a chance to take remedial action by providing the missing information before the application is rejected. The DGA will consider the overall picture, and if it finds that the necessary requirements are met, it will issue a licence. From the submission of an application to the DGA, the issuing of a licence normally takes between three and six months. The application requirements for a game supplier (B2B) are overall very similar to the requirements as described above. The key difference is that only legal entities can apply for a licence as a game supplier. See 6.2 B2B Licences (Suppliers, Software, Etc) for additional information. As a rule, there is no refund of the application fee, which will be forfeited if the application is rejected. If the applicant applies again, a new fee must be paid.

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