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Major laws: TULPS and 2011 reforms

The Italian gambling regulatory system is based on the historical but constantly updated TULPS framework (Testo Unico delle Leggi di Pubblica Sicurezza, 1931) and a number of industry innovations, among which the 2011 reforms were a key turn. Below is a practical "map" for understanding who can do what in the market.


1) What is TULPS and why it matters

TULPS is a single text of public safety laws (1931), which to this day sets the basis for admission to gambling. Two of his articles are particularly important to the industry:
  • Art. 88: requires a concession/license/permit for any bidding or collection activity (including remote channels). Without such a concession, work in Italy is prohibited.
  • Art. 110: describes the mode for devices and devices for the game, including "new slots" and VLT, and determines where and under what conditions they can be installed/operated.

These basic norms are explicitly used by the regulator (now ADM, formerly AAMS) and the courts, and also underlie sanctions against unlicensed activity.


2) Until 2011: foundation for the online segment

By the 2010s, Italy had already formed separate by-laws for distance games. In January 2011, the Ministry of Economy approved a decree that systematized online skill-games, fixed-odds games, and card games organized outside the tournament format (GAD). This gave a "legal road" to online verticals under the control of AAMS/ADM.


3) 2011: a year of tightening and tipping order

In 2011, two "framework" decree laws were issued that influenced the sector: Decree-Law No. 98 of 6 July 2011 (then Law No. 111/2011):
  • Confirmed the strict ban on the participation of minors (18 −) in public games with cash winnings;
  • Increased fines and provided for suspension/withdrawal of activities in case of repeated violations;
  • Expanded distant canal control tools and footholds for AAMS/ADM surveillance.
Decree-Law No. 201 of December 6, 2011 ("Salva Italia"):
  • part of the budget consolidation package, where gaming was considered as a regulated source of fisk;
  • consolidated measures to streamline concessions, fees and combat the illegal segment, as well as harmonize tax and administrative procedures.

Together, these steps "closed" gray areas: minors, opaque bonus practices, weak control of offline points and unauthorized remote offers.


4) How TULPS and 2011 reforms work together (in practice)

Operators need two supports:

1. Concession/license (Article 88 TULPS) - the right to accept bets/gambling;

2. Compliance with the product format (Article 110 TULPS and profile certificates) - where, how and what devices/channels are permissible.

Online verticals (skill, fixed-odds, cards outside the tournament) are valid under directory decree 10. 01. 2011 + ADM regulatory rules (RNG/live certification, reporting, limits).

Compliance circuit after 2011 includes: verification of age 18 +, KYC/AML for remote channels, sanctions up to closing the point/revoking the concession in case of repeated violations.


5) What is considered a violation (in general terms)

Acceptance of rates without a concession Art. 88 (including "online via phone/Internet") - subject to prosecution and administrative and criminal measures.

Operation of prohibited/non-conforming devices or their installation outside the permitted places is a violation of Art. 110.


6) What players and businesses should prepare for in 2025-2030

Licensing and concessions remain the core of the model; The European Commission and the MEF periodically agree on updates to the terms and conditions for online concessions (contribution amounts, term, technical standards).

The trend to strengthen RG/AML will continue: age control, advertising transparency and the fight against gray channels are a priority for ADM. (The context is the EU green book on online gambling and further initiatives.)


7) Short checklist

To the operator

1. Check that your activity is covered by the concession under Art. 88.

2. For offline - check the correspondence of the site and types of devices of Art. 110.

3. For online - follow decree 10. 01. 2011 (skill/fixed-odds/cards), ADM technical certification and reporting.

4. RG/AML: age 18 +, KYC, limits, transparent bonuses; readiness for checks.

To the player

1. Only play with ADM concessionaires.

2. Check age restrictions and transparency of rules/payments.

3. Online games - only on sites with an Italian license (Article 88); offline devices - only in permitted places (Article 110).


Bottom line: The Italian model is based on TULPS as a "skeleton" (licenses under Article 88, device mode under Article 110) and on the reforms of 2011, which tightened online, tightened 18 + and sanctions and strengthened the fiscal and compliance contour. As a result, Italy received a mature "white" market, where the legal status of the operator and visible instruments of responsibility are not an effect, but a condition of the game.

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