Italy Sets New Traceability Rules for Online Gaming

Italy’s Customs and Monopolies Agency (ADM) has published a resolution governing deposits, withdrawals and electronic wallets for licensed remote gaming operators. The measures focus on tracking financial movements and verifying that payment methods belong to the players using them.

Published on October 22, 2026, the resolution follows attention from top-up point-of-sale businesses (PVRs) over account funding rules, including the weekly €100 limit for cash top-ups. It establishes requirements for payment instruments, transaction records and player funds.

Under Article 1, concessionaires must use payment methods that allow deposits and withdrawals to be traced. Operators must also hold player funds in dedicated bank or postal accounts registered in the company’s name and notify ADM of those accounts and the methods used to transfer money and winnings.

Eligible Payments Must Identify Both Parties

Article 2 covers non-cash instruments offered by Italian or EU payment service providers. Bank transfers, direct debits, payment cards and prepaid cards can fund gaming accounts if they comply with applicable authorisation, banking and anti-money laundering requirements.

The instruments must identify the person making a payment and its recipient, while recording the transaction date, amount and purpose. Under the resolution’s conditions, these methods are exempt from the limitations referenced in Article 13, paragraph 5, of Legislative Decree No. 41 of 2024.

Article 3 addresses alternative payment instruments. The purchaser must be identified and match the gaming account owner, whose account must undergo anti-money laundering checks. Each device must fund only its owner’s account and prevent transfers to third parties or transaction changes.

Only the identified owner may recharge the device using a PIN, voucher or another uniquely linked method. Issuers must certify compliance through a report prepared by a qualified third party with banking or anti-money laundering expertise. Dealers must check the requirements before submitting the report to ADM.

The Agency forwards documentation to the Guardia di Finanza and Bank of Italy for review. If an instrument fails the conditions, ADM can suspend its operation and apply contractual penalties, alongside any applicable anti-money laundering sanctions. Existing compliant instruments may remain in use until March 31, 2027, provided operators submit the certified report by that deadline.

Deposits and Withdrawals Require Separate Records

Article 4 requires operators to record every gaming account top-up made through PVRs, including cash deposits. Records may be entered at the dealership or sales point before transmission under the concession’s technical rules. Separate categories must distinguish standard payment methods, alternative instruments and cash, helping authorities monitor the weekly cash limit.

Article 5 requires withdrawals to go to a traceable payment account or instrument registered to the player. Operators must verify ownership through payment providers or by requesting documents. If the details fail verification, payment cannot proceed until the player supplies an eligible alternative.

Withdrawals through PVRs or other gaming outlets are prohibited, including outlets within the same physical network linked to the operator.

E-Wallets Must Remain Accountable

Article 6 allows operators to use electronic wallets managed by authorised, supervised intermediaries, provided they notify ADM in advance. Operators must also identify the bank holding player funds and specify the contact responsible for confirming their availability.