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Interactive Guide to Online Gambling Regulation in Europe

Editors: David Zeffman
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An interactive guide to the regulation of online gambling
Austria
Is online gambling permitted? Yes
Licence available for
BettingYes
SportsYes
Skill GamesNo
Card GamesNo
CasinoNo
LotteryNo
ArcadeNo
Can online operators licensed in other EU Member States offer their online services?No
Can online operators licensed in other EU Member States advertise their online services?No

Notes
Online lotteries and casino type games are part of the federal lottery monopoly, Austrian Lotteries, and may not be undertaken by private operators. Online sports betting is however regulated at a provincial level and is subject to a local licence.
Contacts
Johannes Juranek Gabriela Staber
Partner Counsel
T +43 1 40443 2450 T +43 1 40443 4850
E johannes.juranek@cms-rrh.com E gabriela.staber@cms-rrh.com

Although this resource may provide information concerning potential legal issues, it is not a substitute for legal advice from a qualified legal professional. This resource is not created nor designed to address the unique facts or circumstances that may arise in any specific instance. You should not rely on this content as a source of legal advice.
Belgium
Is online gambling permitted? Yes
Licence available for
BettingYes
SportsYes
Skill GamesNo
Card GamesYes
CasinoYes
LotteryNo
ArcadeYes
Can online operators licensed in other EU Member States offer their online services?No
Can online operators licensed in other EU Member States advertise their online services?No

Notes
Online licences are only available to operators holding land-based licences. There are three types of licence: A+ (online casino games), B+ (online arcade games) and F1+ (online betting).
Contacts
Tom HeremansAlexis Laes
Managing PartnerAvocat
T +32 2 74369 73T +32 2 674 85 77
E tom.heremans@cms-db.comE alexis.Laes@cms-db.com

Although this resource may provide information concerning potential legal issues, it is not a substitute for legal advice from a qualified legal professional. This resource is not created nor designed to address the unique facts or circumstances that may arise in any specific instance. You should not rely on this content as a source of legal advice.
Bulgaria
Is online gambling permitted? Yes
Licence available for
BettingYes
SportsYes
Skill GamesYes
Card GamesYes
CasinoYes
LotteryYes*
ArcadeYes
Can online operators licensed in other EU Member States offer their online services?No
Can online operators licensed in other EU Member States advertise their online services?No

Notes
Bulgarian gambling legislation provides for unlicensed websites to be blocked. To date over 6,000 such websites have been blocked although no other enforcement action has been taken against unlicensed operators.
* Instant lottery games are not regulated.
Contacts
Veliko SavovNevena Radlova
Senior AssociateSenior Associate
T +359 2 923 4856T +359 2 923 4866
E veliko.savov@cms-cmno.comE nevena.radlova@cms-cmno.com

Although this resource may provide information concerning potential legal issues, it is not a substitute for legal advice from a qualified legal professional. This resource is not created nor designed to address the unique facts or circumstances that may arise in any specific instance. You should not rely on this content as a source of legal advice.
Cyprus
Is online gambling permitted? Yes
Licence available for
BettingIn progress
SportsIn progress
Skill GamesNo
Card GamesNo
CasinoNo
LotteryNo
ArcadeNo
Can online operators licensed in other EU Member States offer their online services?Yes
Can online operators licensed in other EU Member States advertise their online services?No

Notes
Remote betting licences are not yet available, although the National Betting Authority has confirmed that it is in the process of preparing secondary legislation to commence the process for issuing licences. Until the new regulatory regime is in place, operators holding a licence from another EU Member State (which is compatible with Cypriot legislation) are permitted to operate in Cyprus.
Although this resource may provide information concerning potential legal issues, it is not a substitute for legal advice from a qualified legal professional. This resource is not created nor designed to address the unique facts or circumstances that may arise in any specific instance. You should not rely on this content as a source of legal advice.
Czech Republic
Is online gambling permitted? Yes
Licence available for
BettingYes
SportsYes
Skill GamesNo
Card GamesYes
CasinoNo
LotteryNo
ArcadeNo
Can online operators licensed in other EU Member States offer their online services?No
Can online operators licensed in other EU Member States advertise their online services?No

Notes
Online gambling is currently only partially regulated in the Czech Republic. To date only domestic operators have obtained licences to operate websites offering sports betting and card games to customers in the Czech Republic.
Reform of the regulatory regime is underway. Current proposals would allow for EEA-based operators to obtain licences to offer online gambling services in the Czech Republic.
Contacts
Tomas Matejovsky
Partner
T +420 2 96798 852
E tomas.matejovsky@cms-cmno.com

Although this resource may provide information concerning potential legal issues, it is not a substitute for legal advice from a qualified legal professional. This resource is not created nor designed to address the unique facts or circumstances that may arise in any specific instance. You should not rely on this content as a source of legal advice.
Denmark
Is online gambling permitted? Yes
Licence available for
BettingYes*
SportsYes
Skill GamesNo
Card GamesYes**
CasinoYes
LotteryNo
ArcadeNo
Can online operators licensed in other EU Member States offer their online services?No
Can online operators licensed in other EU Member States advertise their online services?No

Notes
Remote gambling companies can offer online casino games, online poker and online betting under a licence. Online lotteries, bingo, scratch cards, keno and betting on horseracing and dog racing remain within Danske Spil’s monopoly.

* except horse and dog betting
** Poker
Although this resource may provide information concerning potential legal issues, it is not a substitute for legal advice from a qualified legal professional. This resource is not created nor designed to address the unique facts or circumstances that may arise in any specific instance. You should not rely on this content as a source of legal advice.
Estonia
Is online gambling permitted? Yes
Licence available for
BettingYes
SportsYes
Skill GamesYes
Card GamesYes
CasinoYes
LotteryNo
ArcadeYes
Can online operators licensed in other EU Member States offer their online services?No
Can online operators licensed in other EU Member States advertise their online services?No

Notes
As online gambling is not considered to be a separate type of gambling, the categories of gambling permitted via land-based facilities can be offered online as well. Lotteries are still however only available under the state monopoly.
Although this resource may provide information concerning potential legal issues, it is not a substitute for legal advice from a qualified legal professional. This resource is not created nor designed to address the unique facts or circumstances that may arise in any specific instance. You should not rely on this content as a source of legal advice.
Finland
Is online gambling permitted? Yes
Licence available for
BettingNo
SportsNo
Skill GamesNo
Card GamesNo
CasinoNo
LotteryNo
ArcadeNo
Can online operators licensed in other EU Member States offer their online services?No
Can online operators licensed in other EU Member States advertise their online services?No

Notes
Only the State owned monopolies (Oy Veikkaus Ab, RAY and Fintoto Oy) have been authorised. The provision of online services is interpreted under Finish law as another distribution channel rather than a distinct service in its own right.
Although this resource may provide information concerning potential legal issues, it is not a substitute for legal advice from a qualified legal professional. This resource is not created nor designed to address the unique facts or circumstances that may arise in any specific instance. You should not rely on this content as a source of legal advice.
France
Is online gambling permitted? Yes
Licence available for
BettingYes
SportsYes
Skill GamesYes*
Card GamesYes*
CasinoNo
LotteryNo
ArcadeNo
Can online operators licensed in other EU Member States offer their online services?No
Can online operators licensed in other EU Member States advertise their online services?No

Notes
Three types of online gambling are licensed in France:

  • Horserace betting;
  • Sports betting; and
  • “Club games” (defined as “pooled games based on chance and skill, in which a player, after the intervention of chance, decides, upon observing the behaviours of other players, on a strategy that is likely to modify his/her expected winnings” - to date online poker is the only game authorised (both in cash games and tournaments).


Casino games were excluded from the partial liberalisation of online gambling in France.

*Poker
Contacts
Although this resource may provide information concerning potential legal issues, it is not a substitute for legal advice from a qualified legal professional. This resource is not created nor designed to address the unique facts or circumstances that may arise in any specific instance. You should not rely on this content as a source of legal advice.
Germany
Is online gambling permitted? It depends…4
Licence available for
BettingNo1
SportsYes*
Skill GamesNo2
Card GamesNo**
CasinoNo***
LotteryYes*
ArcadeNo
Can online operators licensed in other EU Member States offer their online services?No3
Can online operators licensed in other EU Member States advertise their online services?No3

  • except for sports and horse racing
  • no license necessary, not considered as gambling
  • except sports betting
  • …on the type of gambling


* Lottery and online betting for sports and horse racing can be permitted if the legal conditions are fulfilled.

** It is controversial whether poker must be classified as a card game (gambling) or as a skill game. In 2014 the Federal Administrative Court (BVerwG 8 C 26/12) considered poker as a form of gambling as long as participants pay the gaming amounts.
In 2015 the Administrative Court of Karlsruhe (3 K 3872/13) followed the Federal Administrative Court’s assessment and, moreover, decided that poker (Hold’em) must be classified as gambling, because of different elements of uncertainty, which aren´t predictable for the players.

Skat is mostly seen as a skill game, whereas skat tournaments with various players are considered as a subset of gambling.

*** Although some licences were already issued for a period of five years in Schleswig-Holstein under a separate Gambling Act, which is no longer in force.
Notes
The regulatory landscape for online gambling in Germany currently remains uncertain. Although online gambling is subject to regulation at an individual state level, the Interstate Treaty on Gambling (ITG) was enacted to ensure unified rules throughout the 16 German states.

The second ITG in its current version, effective as of July 2012, determines a general prohibition of online gambling but with the exception that permission for lottery, horse racing and sports betting can be given. The requirements for a permission are listed in the ITG.
All other forms of online gambling are still completely prohibited.

Before joining the ITG in 2013, the state of Schleswig-Holstein had its own Gambling Act allowing online lottery, sports and horse betting as well as online casino. It issued more than 50 licences under this Act, of which 23 were for online casino, 7 of it also included the license for online poker, and 25 for sports betting). These licences still remain valid until their stipulated expiry date.

For the sector of sports betting, the ITG states that twenty concessions (as a special form of permission) shall be acquired to applicants for a period of seven years.

Due to various pending disputes and a decision of the Higher Administrative Court of Hesse of 16th October 2015, which has confirmed several defects in the sports betting licensing process as contrary to fundamental rights and EU law, no licences have been issued to applicants yet.

Furthermore the CJEU decided on 4th February 2016 (C-336/14- Ince) that private economic operators, who offer sports betting without the obligatory concession cannot be punished, because of the unclear legal situation.

On 16th March 2017 the 16 German states agreed to a reform of the ITG and a revision of the concession process to become effective on 1st January 2018. However, with the state elections in Schleswig-Holstein in May 2017 bringing a so called Jamaica coalition into power it has already become clear that the reform agreed in March will not become effective.

Furthermore the Higher Administrative Court in North Rhine-Westphalia has ruled that the interim permissions provided for in the reform of the ITG are contrary to EU law with the result that the law cannot be enforced upon operators irrespective of whether they hold such an interim permission or not.

Updated 22nd June 2017


Contacts
Benjamin Schirmer Nantje Johnston
Counsel Counsel
T +49 30 20360 1519 T +49 40 37630 310
E benjamin.schirmer@cms-hs.com E nantje.johnston@cms-hs.com

Sebastian Cording
Partner
T +49 40 37630 325
E sebastian.cording@cms-hs.com

Although this resource may provide information concerning potential legal issues, it is not a substitute for legal advice from a qualified legal professional. This resource is not created nor designed to address the unique facts or circumstances that may arise in any specific instance. You should not rely on this content as a source of legal advice.
Greece
Is online gambling permitted? Yes
Licence available for
BettingIn progress
SportsIn progress
Skill GamesIn progress
Card GamesIn progress
CasinoIn progress
LotteryIn progress
ArcadeIn progress
Can online operators licensed in other EU Member States offer their online services?No
Can online operators licensed in other EU Member States advertise their online services?No

Notes
Currently local licences for both betting and gaming are only available to the monopoly operator (OPAP) and 24 offshore companies listed on the “white list” who have been granted provisional permits on the basis of their agreement to become subject to a retrospective tax regime.
Although this resource may provide information concerning potential legal issues, it is not a substitute for legal advice from a qualified legal professional. This resource is not created nor designed to address the unique facts or circumstances that may arise in any specific instance. You should not rely on this content as a source of legal advice.
Hungary
Is online gambling permitted? Yes
Licence available for
BettingNo
SportsNo
Skill GamesNo
Card GamesYes
CasinoYes
LotteryNo
ArcadeNo
Can online operators licensed in other EU Member States offer their online services?No
Can online operators licensed in other EU Member States advertise their online services?No

Notes
The last amendment to Hungarian Gambling Act which came into force on 1 October 2015 set new regulation on online gambling. The regime provide that:

  • only the state monopoly operator Szerencsejáték Zrt. has the right to offer online sports betting;
  • only the state monopoly operator Nemzeti Lóversenyfogadást-szervezőKft. has the right to offer online horse race betting; and
  • online casino games (including card games) may be operated only by concessionaires authorized to operate casinos in the territory of Hungary, by offering the online casino games through the same concession company established for organizing the land-based casino games.

It is to be noted that the Hungarian gambling authority has the right to order Hungarian ISPs to block access to those websites on which unlicensed online gambling is offered.
Contacts
Eszter Csapo Marton Domokos
Senior Associate Counsel 
T +36 1 483 4855 T +36 1 48348 24
E eszter.csapo@cms-cmno.com E marton.domokos@cms-cmno.com

Although this resource may provide information concerning potential legal issues, it is not a substitute for legal advice from a qualified legal professional. This resource is not created nor designed to address the unique facts or circumstances that may arise in any specific instance. You should not rely on this content as a source of legal advice.
Ireland
Is online gambling permitted? Yes
Licence available for
BettingYes
SportsYes
Skill GamesNo
Card GamesNo
CasinoNo
LotteryNo
ArcadeNo
Can online operators licensed in other EU Member States offer their online services?Yes*
Can online operators licensed in other EU Member States advertise their online services?Yes*

Notes
The Irish law on betting was amended in April 2015 by the Betting (Amendment) Act 2015. This introduced a new licensing system for remote bookmakers and betting intermediaries who accept, or facilitate, bets from Irish customers. Enforcement action is likely to be taken against any unlicensed operator that continues to accept bets from Irish customers after 1 August 2015.

* While remote bookmakers and intermediaries will require a valid Irish licence in order to accept or facilitate bets from Irish customers by remote means, there is currently no licensing regime in respect of the provision of online gaming services by remote operators to customers in Ireland. Until such a regime is introduced, there is no restriction on an operator from outside of Ireland continuing to offer online gaming services to customers in Ireland, even if offered from a platform offering licensed bookmaking or betting intermediary services.
Although this resource may provide information concerning potential legal issues, it is not a substitute for legal advice from a qualified legal professional. This resource is not created nor designed to address the unique facts or circumstances that may arise in any specific instance. You should not rely on this content as a source of legal advice.
Italy
Is online gambling permitted? Yes
Licence available for
BettingYes
SportsYes
Skill GamesYes
Card GamesYes
CasinoYes
LotteryYes
ArcadeNo
Can online operators licensed in other EU Member States offer their online services?No1
Can online operators licensed in other EU Member States advertise their online services?No2

Notes
  • Operators licensed in other EU Member States to offer online gambling services must obtain a concession to offer such services in Italy.

  • Comment under 1) above also applies to activities ancillary to gambling such as advertising.

Contacts
Italo de Feo
Partner
T +39 06 4781 51
E italo.defeo@cms-aacs.com

Although this resource may provide information concerning potential legal issues, it is not a substitute for legal advice from a qualified legal professional. This resource is not created nor designed to address the unique facts or circumstances that may arise in any specific instance. You should not rely on this content as a source of legal advice.
Latvia
Is online gambling permitted? Yes
Licence available for
BettingYes
SportsYes
Skill GamesNo
Card GamesYes
CasinoYes
LotteryNo
ArcadeYes
Can online operators licensed in other EU Member States offer their online services?No
Can online operators licensed in other EU Member States advertise their online services?No

Notes
There are currently only six licensed operators in Latvia, in addition to the state-owned operator Latvijas Loto, which is the only operator allowed to offer lottery, keno and bingo games.
Although this resource may provide information concerning potential legal issues, it is not a substitute for legal advice from a qualified legal professional. This resource is not created nor designed to address the unique facts or circumstances that may arise in any specific instance. You should not rely on this content as a source of legal advice.
Lithuania
Is online gambling permitted? Yes*
Licence available for
BettingNo
SportsNo
Skill GamesNo
Card GamesNo
CasinoNo
LotteryYes*
ArcadeNo
Can online operators licensed in other EU Member States offer their online services?No
Can online operators licensed in other EU Member States advertise their online services?Uncertain

Notes
*Online lottery licences are available for locally established operators.

On 1 January 2016, new legislation will come into force which will regulate online gambling in Lithuania for the first time. Under the new regime, operators based in the EEA will be able to apply for a licence to provide online gambling services to customers in Lithuania. However, there are requirements for operators to also have land-based operations in Lithuania.
Although this resource may provide information concerning potential legal issues, it is not a substitute for legal advice from a qualified legal professional. This resource is not created nor designed to address the unique facts or circumstances that may arise in any specific instance. You should not rely on this content as a source of legal advice.
Luxembourg
Is online gambling permitted? Yes
Licence available for
BettingNo
SportsNo
Skill GamesNo
Card GamesNo
CasinoNo
LotteryNo
ArcadeNo
Can online operators licensed in other EU Member States offer their online services?No
Can online operators licensed in other EU Member States advertise their online services?No

Notes
Only the local monopoly operator, the Loterie Nationale, is licensed to provide online gambling services in Luxembourg.
Although this resource may provide information concerning potential legal issues, it is not a substitute for legal advice from a qualified legal professional. This resource is not created nor designed to address the unique facts or circumstances that may arise in any specific instance. You should not rely on this content as a source of legal advice.
Malta
Is online gambling permitted? Yes
Licence available for
BettingYes
SportsYes
Skill GamesNo
Card GamesNo
CasinoYes
LotteryNo
ArcadeYes
Can online operators licensed in other EU Member States offer their online services?Yes
Can online operators licensed in other EU Member States advertise their online services?Yes

Although this resource may provide information concerning potential legal issues, it is not a substitute for legal advice from a qualified legal professional. This resource is not created nor designed to address the unique facts or circumstances that may arise in any specific instance. You should not rely on this content as a source of legal advice.
The Netherlands
Is online gambling permitted? No1
Licence available for
BettingNo
SportsNo
Skill GamesNo
Card GamesNo
CasinoNo
LotteryNo
ArcadeNo
Can online operators licensed in other EU Member States offer their online services?No
Can online operators licensed in other EU Member States advertise their online services?No

Notes
  • Only local monopoly operators are licensed to provide online gambling services in the Netherlands. However, there are plans to introduce a local licensing regime in due course. An updated draft of the latest draft law to regulate online gambling was notified to the European Commission on 5 March 2014. However, due to political issues, the process to begin issuing licences has been delayed and is not expected to commence before mid-2016 at the earliest.

Contacts
Annemieke HazelhoffTim Wilms
AssociateAdvocaat
T +32 26 5004 55T +31 20 3016 398
E annemieke.hazelhoff@cms-dsb.comE tim.wilms@cms-dsb.com

Although this resource may provide information concerning potential legal issues, it is not a substitute for legal advice from a qualified legal professional. This resource is not created nor designed to address the unique facts or circumstances that may arise in any specific instance. You should not rely on this content as a source of legal advice.
Norway
Is online gambling permitted? No1
Licence available for
BettingNo
SportsNo
Skill GamesNo
Card GamesNo
CasinoNo
LotteryYes2
ArcadeNo
Can online operators licensed in other EU Member States offer their online services?N/a
Can online operators licensed in other EU Member States advertise their online services?N/a

Notes
  • Only the locally licensed government entity is permitted to provide online gambling services in Norway; the Norwegian regime is a de facto state monopoly.

  • Notwithstanding the foregoing, private entities can obtain a local licence in respect of certain lotteries but only if they promote humanitarian or socially beneficial causes.


The Norwegian legislature and the Norwegian government agreed in Spring 2017 to maintain the state monopoly.
Although this resource may provide information concerning potential legal issues, it is not a substitute for legal advice from a qualified legal professional. This resource is not created nor designed to address the unique facts or circumstances that may arise in any specific instance. You should not rely on this content as a source of legal advice.
Poland
Is online gambling permitted? Yes
Licence available for
BettingYes
SportsYes
Skill GamesNo
Card GamesNo
CasinoNo
LotteryNo
ArcadeNo
Can online operators licensed in other EU Member States offer their online services?No
Can online operators licensed in other EU Member States advertise their online services?No

Notes
Online gambling is prohibited with the exception of formally approved mutual betting, defined as betting for cash winnings that are determined by guessing (i) the results of a sports competition or (ii) the occurrence of different events.
Contacts
Iain BattyMaciej Olejnik
PartnerSenior Associate
T +48 22 520 5528T +48 22 520 8380
E iain.batty@cms-cmno.comE maciej.olejnik@cms-cmno.com

Although this resource may provide information concerning potential legal issues, it is not a substitute for legal advice from a qualified legal professional. This resource is not created nor designed to address the unique facts or circumstances that may arise in any specific instance. You should not rely on this content as a source of legal advice.
Portugal
Is online gambling permitted? Yes1
Licence available for
BettingYes
SportsYes2
Skill GamesYes3
Card GamesYes
CasinoYes
LotteryNo4
ArcadeNo
Can online operators licensed in other EU Member States offer their online services?No
Can online operators licensed in other EU Member States advertise their online services?No

Notes
  • Only state-owned actors and locally licensed operators are permitted to provide online gambling services in Portugal.


  • Fixed-odds sports betting is permitted but pari-mutuel sports betting is reserved to the state monopoly.


  • Fixed-odds sports betting is permitted but pari-mutuel sports betting is reserved to the state monopoly.


  • Lottery is reserved to the state monopoly.

Contacts
Antonio MenezesJose Arnaut
AssociateManaging Partner
T +351 210 95 81 07T +351 210 958 100
E antonio.menezes@cms-rpa.comE joseluis.arnaut@cms-rpa.com

Goncalo Tavares
Partner
T +351 210 95 81 65
E goncalo.tavares@cms-rpa.com

Although this resource may provide information concerning potential legal issues, it is not a substitute for legal advice from a qualified legal professional. This resource is not created nor designed to address the unique facts or circumstances that may arise in any specific instance. You should not rely on this content as a source of legal advice.
Romania
Is online gambling permitted? Yes
Licence1 available for
BettingYes
SportsNo1
Skill GamesNo2
Card GamesYes
CasinoYes
LotteryYes3
ArcadeNo4
Can online operators licensed in other EU Member States offer their online services?No5
Can online operators licensed in other EU Member States advertise their online services?No6

Notes
  • Amusement or sporting games where players are required to demonstrate knowledge and skill and which are not based predominantly on chance do not constitute gambling and are not subject to licensing and authorisation. However, subject to the specifics of the game, sports games may fall under the general legal definition of “gambling”or within the category of a specific type of gambling activity regulated under the law and for which obtaining a licence and/or authorisation is required (e.g. betting).

  • Games of an entertainment nature which are operated via any kind of machine and which do not involve winning based on random elements, but are intended to test the participant’s strength, intelligence or dexterity, do not constitute gambling and are not subject to licensing and authorisation. However, subject to the specifics of the game, skill games may fall under the general legal definition of “gambling”for which obtaining a licence and/or authorisation is required.


  • Organising lottery games requires a specific type of licence to be obtained and is an activity subject to the monopoly of the Romanian state.


  • Comments under 2) above also apply here.

  • Operators licensed in other EU Member States to offer online gambling services must obtain a licence and/or authorisation to offer such services in Romania. Simplified requirements for obtaining a licence may apply to operators already licensed in other Member States.

  • Comments under 5) above also apply to activities ancillary to gambling such as advertising.

  • Under the regulatory regime applicable in Romania as of 2016, new licensing and authorisation requirements apply to traditional and online gambling activities, as well as to activities ancillary to gambling such as lease, distribution and maintenance activities in relation to gambling. Depending on the type of activity concerned, specific types of licences and/or authorisations need to be obtained.

Contacts
Ana-Maria Nistor Laura Capata
Senior Associate Associate
T +40 21 4073 872 T +40 21 407 3825
E ana-maria.nistor@cms-cmno.com E Ioana.capata@cms-cmno.com

Although this resource may provide information concerning potential legal issues, it is not a substitute for legal advice from a qualified legal professional. This resource is not created nor designed to address the unique facts or circumstances that may arise in any specific instance. You should not rely on this content as a source of legal advice.
Russia
Is online gambling permitted? Yes
Licence available for
BettingYes
SportsYes
Skill GamesNo
Card GamesNo
CasinoNo
LotteryNo1
ArcadeNo
Can online operators licensed in other EU Member States offer their online services?N/a
Can online operators licensed in other EU Member States advertise their online services?N/a

Notes
Online gambling in Russia is restricted to ‘interactive’ online bets through the state-run payment processing provider (TsUPIS); such online betting is subject to the operator holding a valid local licence. Online casinos and online slot machines are prohibited in all cases.

  • Lotteries may be organised as international lotteries (based on international treaties) or by the national state lottery.

Contacts
Hayk Safaryan
Partner
T +7 495 786 30 59
E hayk.safaryan@cmslegal.ru

Although this resource may provide information concerning potential legal issues, it is not a substitute for legal advice from a qualified legal professional. This resource is not created nor designed to address the unique facts or circumstances that may arise in any specific instance. You should not rely on this content as a source of legal advice.
Slovakia
Is online gambling permitted? Yes
Licence available for
BettingNo
SportsYes
Skill GamesNo
Card GamesNo
CasinoNo
LotteryNo
ArcadeNo
Can online operators licensed in other EU Member States offer their online services?No
Can online operators licensed in other EU Member States advertise their online services?Yes

Notes
Only the local monopoly operator (Tipos) is licensed to provide online gambling services in Slovakia. As a result of a legal loophole, local land-based operators are allowed to offer sports-betting online services without this being considered an online gambling operation.
Contacts
Martina Novysedlakova
Associate
T +421 296 798 742
E martina.novysedlakova@cms-cmno.com

Although this resource may provide information concerning potential legal issues, it is not a substitute for legal advice from a qualified legal professional. This resource is not created nor designed to address the unique facts or circumstances that may arise in any specific instance. You should not rely on this content as a source of legal advice.
Slovenia
Is online gambling permitted? Yes
Licence available for
BettingNo
SportsNo
Skill GamesNo
Card GamesNo
CasinoNo
LotteryNo
ArcadeNo
Can online operators licensed in other EU Member States offer their online services?No
Can online operators licensed in other EU Member States advertise their online services?No

Notes
Online gambling in Slovenia must be operated by land-based operators that already have a concession for a casino or existing classic lottery games. As a result of this requirement, the only entities eligible to apply for an online licence are Slovenia’s two lottery operators as well as the casino concessionaires. Criminal sanctions of up to three years’ imprisonment (or eight years where substantial sums are involved) apply in respect of any person who either organises, participates or assists with organising online games of chance.
Contacts
Aleš Lunder
Partner
T +386 1 62052 10
E ales.lunder@cms-rrh.com

Although this resource may provide information concerning potential legal issues, it is not a substitute for legal advice from a qualified legal professional. This resource is not created nor designed to address the unique facts or circumstances that may arise in any specific instance. You should not rely on this content as a source of legal advice.
Spain
Is online gambling permitted? Yes
Licence available for
BettingYes
SportsYes
Skill GamesYes
Card GamesYes
CasinoYes
LotteryYes*
ArcadeNo
Can online operators licensed in other EU Member States offer their online services?No
Can online operators licensed in other EU Member States advertise their online services?No

Notes
Regulated online gambling comprises:

  • lotteries;
  • betting (on sports, horseracing, fixed odds betting, live betting on certain events) and exchange betting;
  • raffles;
  • contests;
  • slots; and
  • other games (this category includes poker, roulette, baccarat, bingo and black jack amongst others).


Any kind of gambling not expressly regulated will remain prohibited.

Some Spanish regions have also issued their own online gambling regulations under which operators will require a specific local licence (compatible with and independent of the national licence). This is the case of Castile-Leon, Valencia, Murcia, Navarre, the Basque Country and Madrid.

* Only the local monopoly operators, SELAE and ONCE, are licensed to provide lottery gambling services in Spain.
Contacts
Blanca Escribano Marcos García-Gasco
Partner Associate
T +34 91 4519 287T +34 91 4519 305
E blanca.escribano@cms-asl.comE marcos.garcia‑gasco@cms‑asl.com

Although this resource may provide information concerning potential legal issues, it is not a substitute for legal advice from a qualified legal professional. This resource is not created nor designed to address the unique facts or circumstances that may arise in any specific instance. You should not rely on this content as a source of legal advice.
Sweden
Is online gambling permitted? No1
Licence available for
BettingNo
SportsNo
Skill GamesNo
Card GamesNo
CasinoNo
LotteryNo
ArcadeNo
Can online operators licensed in other EU Member States offer their online services?No
Can online operators licensed in other EU Member States advertise their online services?No

Notes
  • Only locally licensed government entities and non-profit organisations are permitted to provide online gambling services in Sweden; the Swedish regime is a de facto state monopoly.


In light of recent arguments that the Swedish regime is not compliant with EU law, the Swedish government has appointed a committee tasked with drafting a new gambling regime based on a licensing system. The committee’s proposals were published in March 2017 but will be subject to legislative scrutiny before any new regulations can be enacted in the future.
Although this resource may provide information concerning potential legal issues, it is not a substitute for legal advice from a qualified legal professional. This resource is not created nor designed to address the unique facts or circumstances that may arise in any specific instance. You should not rely on this content as a source of legal advice.
Switzerland
Is online gambling permitted? No1
Licence available for
BettingNo1
SportsNo1
Skill GamesIt depends2
Card GamesNo3
CasinoNo3
LotteryNo1
ArcadeNo3
Can online operators licensed in other EU Member States offer their online services?N/a4
Can online operators licensed in other EU Member States advertise their online services?N/a4

Notes
  • Under the current regulatory regime, online gambling is generally not permitted but online lottery and betting is technically permitted for operators with the relevant licence. However, the lottery and betting market is dominated by two local, licensed operators. Licences for other operators are available in theory but in practice Switzerland is a de facto monopoly.

  • Skill games are subject to cantonal law. In several cantons, skill games are not permitted.


  • Under the current regulatory regime, online gambling is generally not permitted however draft legislation in relation to online gambling was submitted to Parliament in October 2015. One of the main expected changes will be that the new law will allow online casino games subject to licence. The new law is expected to come into force in 2019.


  • Offering illegal online gambling is a criminal offence in Switzerland. Prohibited activities also include offering online gambling via foreign domains and prize pay-outs to winners in Switzerland from abroad.

Contacts
Robert Briner Caroline Gaul
Partner Senior Associate
T +41 44 285 13 37 T +41 44 285 11 11
E robert.briner@cms-vep.com E caroline.gaul@cms-vep.com

Although this resource may provide information concerning potential legal issues, it is not a substitute for legal advice from a qualified legal professional. This resource is not created nor designed to address the unique facts or circumstances that may arise in any specific instance. You should not rely on this content as a source of legal advice.
United Kingdom
Is online gambling permitted? Yes
Licence available for
BettingYes
SportsYes
Skill GamesYes*
Card GamesYes
CasinoYes
LotteryYes
ArcadeYes
Can online operators licensed in other EU Member States offer their online services?No**
Can online operators licensed in other EU Member States advertise their online services?Yes***

Notes
* if element of chance included.

** Under the Gambling (Licensing and Advertising) Act 2014, from 1 October 2014 all operators providing gambling services to customers located in Great Britain need to hold a licence obtained from the Gambling Commission.

*** Operators without licences issued by the Gambling Commission can advertise within Great Britain, provided that they have effective measures in place to prevent people accessing their facilities from within Great Britain.
Contacts
David ZeffmanStephen Hignett
PartnerPartner
T +44 20 7067 3198T +44 20 7067 3397
E david.zeffman@cms-cmno.comE robert.stephen@cms-cmno.com

Alasdair SteeleDan Tench
PartnerPartner
T +44 20 7524 6422T +44 20 7067 3518
E alasdair.steele@cms-cmno.comE dan.tench@cms-cmno.com

Robert Willis
Partner
T +44 20 7067 3398
E robert.willis@cms-cmno.com

Although this resource may provide information concerning potential legal issues, it is not a substitute for legal advice from a qualified legal professional. This resource is not created nor designed to address the unique facts or circumstances that may arise in any specific instance. You should not rely on this content as a source of legal advice.
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