Gaming Law 2025

BELGIUM Law and Practice Contributed by: Pieter Paepe and Christoph de Preter, EDSON

• licence A – a class I gaming establishment (casi- nos); • licence A+ – an online casino; • licence B – a class II gaming establishment (gam- ing arcades); • licence B+ – an online gaming arcade; • licence C – a class III gaming establishment (bars); • licence D – exercising a professional activity within class I, II or IV gaming establishments; • licence E – sale, rental, supply, making available, import, export, manufacture, maintenance, repara- tion and equipment of games of chance; • licence F1 – a class IV gaming establishment (organisers of betting); • licence F1+ – offering online betting; • licence F1P – allows the F1 licence holder to organise betting on horse races (only an F1 licence holder can obtain an F1P licence); and • licence F2 – licence to take on bets on behalf of an F1 licence holder. 4.4 Availability of Licences The following licences are readily available: • licence A – there are nine available licences and, as of October 2025, nine active licences; • licence A+ – there are nine available licences (avail- able for A licence holders only) and, as of October 2025, nine active licences; • licence B – there are 180 available licences and, as of October 2025, 175 active licences; • licence B+ – there are 180 available licences (avail- able for B licence holders only) and, as of October 2025, 51 active licences; • licence C – the number of licences is not limited and, as of October 2025, there are 4,037 active licences; • licence D – the number of licences is unlimited and the number of active licences is unknown; • licence E – the number of licences is unlimited and, as of October 2025, there are 169 active licences; • licence F1 – there are currently 30 available licenc- es and, as of October 2025, 30 active licences; • licence F1+ – there are currently 30 available licences (available for F1 licence holders only) and, as of October 2025, 22 active licences; • licence F1P – unknown; and

• licence F2 – there are 600 fixed and 60 mobile licences available and, as of October 2025, there are 397 active licences for betting shops and 26 for bookmakers. 4.5 Duration of Licences The duration of the available licences is as follows: • licence A – a renewable period of 15 years; • licence A+ – the same as an A licence; • licence B – a renewable period of nine years; • licence B+ – the same as a B licence; • licence C – a renewable period of five years; • licence D – unspecified in the Gaming Act; • licence E – a renewable period of ten years; • licence F1 – a renewable period of nine years; • licence F1+ – the same as an F1; • licence F1P – the same as an F1; and • licence F2 – a renewable period of three years. 4.6 Application Requirements The application requirements vary for each type of licence. All applications should be filed with the Gam- ing Commission. Only EU citizens and EU/European Economic Area (EEA)-registered companies can apply for an A, B, E, F1 or F1P licence. In general, a licence applicant must submit fiscal and financial information, as well as demonstrate that it and its directors do not have a criminal history. There are solvency criteria to be satis- fied and must be demonstrated by a Belgian certified auditor or accountant. A legal person must include additional information about its directors and share- holders, together with supporting evidence. Failure to meet any conditions set out in the application form or to submit the requested information will result in the application being denied. For online games of chance (licences A+, B+ and F1+), two Royal Decrees of 21 June 2011 are noteworthy. The first Royal Decree lists the quality requirements to be met by an applicant for an online licence. The applicant must: • have a solvency ratio of 40%; • provide a plan that guarantees the security of all payments between the operator and the player;

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