Comparison with the UK and the EU

1) Briefly about the main thing

Ireland has historically shared betting and "games/lotteries" regimes and has long lacked a full national framework for online casinos. With the launch of GRAI, a unified licensing and supervision system is being built for all verticals.

Great Britain (UK) has been living according to the mature UKGC model for many years: uniform rules for online/offline, strict responsibility of operators and an emphasis on protecting vulnerable players.

The EU is not a single regulator, but a "mosaic" of national regimes: from liberal (for example, Malta, Denmark, Sweden) to strict with strict restrictions on advertising and products (Spain, Italy, Germany, the Netherlands).

2) Licensing: system outlines

Ireland: transition from a historical "two-track" to a single regulator (GRAI) and a single ladder of licenses for B2C/B2B. Private casino clubs and offshore online are becoming a thing of the past as the national license launches.

UK: centralised UKGC model and mandatory compliance with LCCP (licence terms and codes of practice) for all channels and products, plus industry advertising codes CAP/BCAP.

EU: each country itself. The pattern "national license + local technical requirements" (SE, DK, NL) is widespread, less often - restrictive modes for product/advertising (DE, ES, IT).

3) Taxes and fiscal logic

Ireland: for bets - excise tax on turnover (stake-based); for exchanges - share from commissions; for the rest - VAT/corporate taxes according to general rules. With the transition to GRAI, the fiscal framework is expected to align vertically.

UK: more often a guideline for GGR taxation (by vertical) + special modes.

EU: the GGR approach dominates, however, rates and pool rates may have separate excise taxes; ranges vary widely across countries.

Practical conclusion: the Irish "rate tax" is more sensitive to low-margin markets than the UK/EC GGR models. It is important for operators to take this into account in live and in-play.

4) Advertising and Marketing

Ireland: goes to a single code under GRAI: "watershed" in time, more stringent targeting requirements, protection of minors, transparent bonuses.

UK: mature system: CAP/BCAP, youth appeal restriction, protection of the vulnerable, liability of affiliates, strengthened rules for influencers and online venues.

• Spain - tight time windows and restrictions on sponsorship;
• Italy - a de facto ban on widespread gambling advertising;
• Netherlands - strong restrictions on untargeted advertising and sponsorships.

5) Payments, KYC/AML and "affordability"

Ireland: national ban on credit cards and "credit" financing of the game, strengthening KYC/AML, launching a national register of self-exclusion; course on digital-first supervision.

UK: developed risk-based KYC/AML practice, "game availability" (affordability) with in-depth checks of the source of funds for risk segments; everywhere - self-exclusion tools (GAMSTOP).

EU: AML common framework on EU law + national additions. Notable examples of self-exclusion registries are: ROFUS (Denmark), CRUKS (Netherlands), OASIS (Germany). Many countries ban credit cards and impose deposit/loss limits.

6) Product restrictions and live/slots

Ireland: historically liberal-by-product due to "half-hearted" framework; as GRAI launches - alignment with Britain/EU: RNG/RTP certification, live stream control, behavioral "soft-stops."

UK: tightening UX restrictions for slots (rate limits, slowing down dangerous mechanics), clear requirements for transparency of chances and bonuses, strict rules for design that can attract young people.

• Germany - conservative product design (spin speeds, deposit limits, strict vertical segregation);
• Sweden/Denmark - flexible model, but with accurate RG tools and bonus restrictions;
• The Netherlands - a strong emphasis on onboarding control and "no vulnerable" advertising.

7) Enforcement and blocking

Ireland: transition to proactive enforcement: warnings, prescriptions, blocking of unlicensed sites, cooperation with payment and media platforms.

UK: high level of public cases: fines, revocation and suspension of licenses, individual liability of managers.

EU: from "hard" (NL, DE) with locks and millions of fines - to "soft" (some markets) with an emphasis on prevention.

8) Summary table: where differences are more critical

9) What it means in practice

• In Ireland, it is profitable to build a "British" compliance level right away: then the transition to GRAI will be painless.
• When planning EU expansion, prepare a "compliance matrix" by market: taxes (GGR vs stake), advertising, payments, self-exclusion, product limits.
• Unify vendor audits (games, PSP, KYC) and "passport" RG/AML processes - this makes scaling easier.

• In Ireland and UK - strict responsibility for creative/targeting; in the EU, the rules differ, but there is only one trend: less aggressive advertising, more point-to-point informing of adult audiences.
• Building trust is more important than a "click": transparent bonus conditions, correct disclaimers, links to RG tools.

• Ireland is actually synchronized with the "Northern European" model: a single regulator, digital supervision, credit card bans, nat. self-exclusion, strong B2B responsibility.
• The difference from the UK is the fiscal logic of rates (stake-based) and the pace of implementation of new rules; from the EU - less fragmentation within the country and focus on the "best practices" of UK/Scandinavia.

10) The bottom line

Ireland is quickly catching up with "big" Europe and Britain, building a transparent, technological and unified system under GRAI. UK remains the benchmark for mature compliance and consumer protection, and the EU is a field of diverse but increasingly similar rules. As the Irish licence launches, the differences will narrow: brands that already live compliance-by-design today will benefit, with honest UX, understandable payouts and strong responsible gambling tools.