BELGIUM Law and Practice Contributed by: Pieter Paepe and Christoph de Preter, EDSON
reform. In its judgment of 23 October 2025, the court dismissed the actions as unfounded. The Act of 7 May 2024 introduced a new Article 54/1 to the Gaming Act, requiring all land-based gaming licence holders to verify the identity of anyone enter- ing their gaming areas or participating in gaming activities. This obligation applies to casinos, gaming arcades, betting shops (including mobile outlets), and race tracks offering bets. Operators must also consult the Excluded Persons Information System (EPIS) as part of this process. The expanded identity verification and EPIS consultation requirements entered into force on 1 May 2025, except for F2 licence holders operat- ing mobile betting shops or outside type IV gaming establishments, for whom the rules will apply from 1 May 2026. The Act of 7 May 2024 also introduces a specific iden- tification requirement for newspaper shops permitted to offer sports betting as an ancillary activity (holders of an F2 licence). This identification must be conduct- ed through an “appropriate IT system” that can verify the player’s age and check if the individual is listed in the EPIS. The IT system will require certification. This identification obligation will take effect on 1 May 2026. To combat the unlicensed black market, it has been possible since 1 June 2024 to request that the presi- dent of the Enterprise Court in Brussels issue a cease- and-desist order against infringing companies as well as against intermediaries (such as ISPs). These pro- ceedings may be initiated ex parte. This mechanism has been used to obtain orders against websites offer- ing unlicensed games of chance in Belgium, requiring ISPs and companies such as Meta, Google, and Apple to implement technical measures preventing access to these websites, remove them from search results, and take other necessary actions to restrict their avail- ability. In its 2025 coalition agreement, the Belgian federal government reaffirmed its commitment to modernis- ing gambling regulation. The government emphasised its objective of establishing a transparent and stable regulatory framework that provides legal certainty to the gambling industry. It also announced plans to update the Gaming Act to reflect the emergence of
new forms of gambling. Under the reform, the Minister of Economic Affairs will become the government’s sole representative within the Gaming Commission and will take further steps to strengthen the fight against ille- gal gambling, both online and offline. These measures aim to ensure a level playing field across the indus- try and to enhance consumer protection. In addition, local authorities will be granted a stronger role in the licensing process for gambling establishments within their jurisdictions, including the power to designate specific zones where such venues may be located. Offering online games of chance and betting requires a licence. There are three categories of online gaming licences: • an A+ licence for online casino games; • a B+ licence for online arcade (dice) games; and • an F1+ licence for online betting. As a general rule, the Gaming Act stipulates that an online licence holder (A+, B+ or F1+) can only oper- ate games of chance “of the same nature” as those offered offline. An F1+ licence holder can offer online betting and an A+ licence holder has the right to com- mercialise online casino games. The National Lottery holds the monopoly on offering online lotteries. 2.2 Land-Based Gambling Offering land-based games of chance and betting requires a licence. There are five categories of land- 2. Jurisdictional Overview 2.1 Online Gambling based gaming licences: • an A licence for casinos; • a B licence for gaming arcades; • a C licence for bars; • an F1 licence for organising betting; and • an F1P licence for organising betting on horse races. Holders of an A, B or C licence can offer explicitly enu- merated games of chance and F1 licensees can com- mercialise all (sports) betting. But betting on horse
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