ITALY Law and Practice Contributed by: Stefano Sbordoni, Sbordoni & Partners
business, change of ownership structure)), given that this is not a new concession but merely a “transfer/ update”, the duration is two to four months depending on the complexity of the “requirements” verification required by the ADM. The timeframe for obtaining a licence pursuant to Arti- cles 86 and 88 of TULPS varies depending on the type of licence, the competent police headquarters, and the completeness of the documentation in compliance with the principles established by Law No 241/1990. These timeframes can be estimated as between 30 and 60 days from the date of application submission for obtaining a licence pursuant to Article 86 of TULPS from the municipality and/or one-stop shop ( sportello unico per le attività produttive , or SUAP) and between 60 and 120 days for the issuance of a licence pursuant to Article 88 of TULPS by the Administrative, Social, and Immigration Division ( DivisionePolizia Amministra- tiva, Sociale e dell’Immigrazione ) (the “PAS Division”) of the police headquarters. 4.8 Application Fees The cost for obtaining a public concession and/or a licence varies, based on the type of game to be offered The fees of the various concessions ‒ up-to-date as of 2025 ‒ are as follows. • Online gaming ‒ a one-time payment of EUR7,000,000 per concession is required (Article 6 of Legislative Decree No. 41/2024); • Betting concessions (agencies and corners) ‒ according to the latest public tender of 2016‒18, an entry fee is required (EUR32,000 per shop and EUR18,000 per corner), as well as a bank guaran- tee (from EUR50,000 to EUR100,000 per point). • For a bingo concession, the indicative tender cost ranges from EUR200,000 to EUR350,000 per hall (the concession lasts approximately nine years, depending on the tender), in addition to the guar- antees required by the tender. • For AWP machine/VLT concessions (network management) with national concessionaires (Lottomatica, Sisal, Snaitech, etc), the cost of the network right (based on the latest tender) is approximately EUR7,500 for each AWP right and
up to EUR18,000 for each VLT right. Furthermore, concessionaires must have very high share capital (from EUR1 million to EUR5 million) and provide sureties amounting to hundreds of millions for the entire system, as well as network infrastructure, servers, and certifications. • For lottery concessions (which are “monopolistic” concessions, obtainable only by large groups,) the estimated costs are more than EUR100 million for Superenalotto and more than EUR800 million for Gratta&Vinci (2010 tender). 4.9 Ongoing Annual Fees The main annual costs of a concession, in addition to taxes (see 12. Tax ), are as follows. • For online concessions, in addition to the conces- sion fee (EUR7 million), there is an annual fee equal to 3% of the net gaming margin. • Costs related to top-up points ( punti vendita ricari- ca , or PVRs) ‒ an annual registration fee of EUR100 per PVR is paid. • For land-based betting ‒ per the 2025 Budget Law, the concession extension costs EUR9,500 per year for each main agency, whereas the cost is EUR5,700 per year for betting “corners” (smaller locations). • SOGEI contribution ‒ this equates to 0.15% of the average revenue for connection to the ADM telem- atics network. • “Responsible gaming” contribution ‒ this equates to 0.2%‒0.5% of the GGR as established in the ADM agreement for the prevention of gambling addiction. 4.10 Personal Licensing To obtain a personal licence pursuant to Articles 86, 88 and 110 of TULPS, the following requirements must be met, which may vary slightly depending on the region and/or municipality. • Subjective requirements ‒ the holder must: (a) be an adult; (b) be an Italian or EU citizen or be or a non-EU citizen with a valid residence permit; (c) enjoy full civil and political rights, not be inter- dicted, incapacitated or bankrupt, and have no convictions that prevent them from practising
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