ITALY Law and Practice Contributed by: Stefano Sbordoni, Sbordoni & Partners
graph 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). 4.4 Availability of Licences 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 Novem- ber 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, fol- lowing 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 (includ- ing 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. 4.5 Duration of Licences 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 dedi- cated tender). The ADM website contains a list of authorised remote gaming concessionaires. 4.6 Application Requirements The requirements for participating in the public tender for awarding the public gaming concession are pub- lished on the ADM website and are as follows. • Legal and corporate requirements – the applicant company must: (a) be incorporated as a joint stock company (eg, SpA, Srl) with a registered office in an EU/Euro- pean Economic Area (EEA) member state; (b) not be involved in any relevant criminal pro- ceedings, nor have any convictions or disquali- fications; (c) have a business purpose consistent with re- mote gaming activities; and (d) be up-to-date with tax and social security obligations. • Economic and financial requirements ‒ the operator must demonstrate financial stability, including: (a) minimum share capital (often required to be at least EUR1.5 million, varying from call to call); (b) a surety bond (eg, EUR1.5 million or the amount established by the call); (c) minimum previous turnover requirement (typically several million euros in the gaming or
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