Regulation of gambling in France, Italy and Spain
1) France - Autorité Nationale des Jeux (ANJ)
Mode profile.
ANJ is a regulator with a focus on protecting vulnerable groups and marketing discipline. Historically strict promo framework, content sensitivity, high bar RG/KYC/AML.
Licensing and verticals.
Division by verticals (bets, poker, casino content - with reservations by assortment), mandatory RNG/RTP and technical control certifications.
Responsible Gaming (RG).
Central registers of self-exclusion, deposit/time limits, "reality checks," strict moderation of offers and interfaces, prohibition of manipulative patterns.
KYC/AML.
Identity/address identification, POP/sanctions, Source of Funds/Wealth triggers for large deposits, transaction monitoring, suspicious transaction reporting.
Advertising and affiliates.
Coordination of approaches, limitations of creatives and sponsorships, age/behavioral filters, responsibility for partner traffic.
Taxes and payments.
Focus on GGR logic with industry coefficients; working only with licensed PSPs, strict verification of sources of funds.
Pros/risks.
High market confidence, predictable oversight.
Rigid framework of promo and content, increased price of compliance.
2) Italy - Agenzia delle Dogane e dei Monopoli (ADM)
Mode profile.
ADM - "procedural regulator": consistent but detailed rules. Strong advertising discipline and phased assumption of functionality.
Licensing and verticals.
Issuing licenses in batches/windows; poker, casino, bets - by vertical, mandatory technical certification, local integration of reporting.
Responsible Gaming.
Mandatory limits and self-exclusion, risk warnings, interface control (game speed, auto game), bonus mechanics control.
KYC/AML.
Deep due diligence of clients and beneficiaries, SoF/SoW by events, monitoring transactions, storing logs within specified deadlines.
Advertising and affiliates.
Historically, one of the most low-key advertising policies in the EU; strict control of affiliates, prohibition of misleading messages.
Taxes and payments.
GGR taxes with industry rates, license fees; focus on "white" providers and payment/deposit reporting.
Pros/risks.
Mature market and high license value.
Bureaucracy, slow approval of changes, strict marketing.
3) Испания — Dirección General de Ordenación del Juego (DGOJ)
Mode profile.
DGOJ - about the "social mandate" and transparency: hard age filters, restrictions on advertising messages, carefully rationed bonuses.
Licensing and verticals.
Licenses by vertical; mandatory certification of content and technical infrastructure, reporting and activity monitoring.
Responsible Gaming.
Centralized self-exclusion mechanisms, limits, prohibition of "dark" patterns, mandatory reality checks and risk communication.
KYC/AML.
Full KYC before admission, sanction/PEP screening, SoF/SoW triggers, transaction risk scoring, SAR/STR procedures.
Advertising and affiliates.
Time/channel restrictions, strict copyright (prohibition of promises of "earnings"), responsibility for affiliates and transparency of partnerships.
Taxes and payments.
Tax logic for GGR, mandatory "white" PSP, control of returns and risk scoring.
Pros/risks.
Large Hispanic market, stable oversight practices.
Discreet promo frames, requirements for deep localization of UX/copyright.
4) Comparison of modes (the essence is 8 parameters)
1. RG hardness: France/Spain - high; Italy is high with an emphasis on procedural discipline.
2. KYC/AML depth: in all three - risk-based with SoF/SoW; France and Italy are more likely to require extended documentation for large deposits.
3. Advertising/affiliates: Italy and France are the strictest; Spain is strict with an emphasis on tonality and targeting.
4. Content certification: equal importance for everyone; control of releases and logging is mandatory.
5. Payments/crypto: white providers only; crypto - allowed in the format of VASP partners with hard AML (in reality - conservatively).
6. Tax base: GGR with industry rates and licensing fees; local vertical differences.
7. Enforcement: in all jurisdictions - active sanctions for marketing and RG/AML; Italy stands out for the duration of the negotiations.
8. Sewerage (retention of players in the "white" sector): high with correct advertising and convenient payment networks; tax/promo inflection reduces sewerage.
5) What it means for product and marketing
Product.
Mandatory limits and self-exclusion, reality checks, transparent RTP/probabilities, prohibition of "almost winning as a victory," control of autoplay and pace.
Immutable logs, release management, independent validation of builds, audit of B2B providers.
Marketing.
Age/behavioral filters, no promises of "income," clear delivery of bonuses (vager, limits, deadlines).
Strict verification of affiliates, a library of approved creatives, a ban on cloaking and "dark" patterns.
Operations and reporting.
SAR/STR procedures, reports on GGR/verticals, regulator access to logs, audit plan and personnel training.
6) Checklist for operator before entering FR/IT/ES
1. Legal structure and fit & proper: transparent beneficiaries, compliance/MLRO/RG officer roles.
2. Policies: KYC/AML (PEP/sanctions, SoF/SoW), RG (limits, self-exclusion, triggers), marketing/affiliates, incidents, change management.
3. Technique: RNG/RTP certification, logs (immutable), SIEM, encryption, DR/BCP plans and exercises.
4. Payments: white PSP, SCA/3DS, anti-fraud, limits, crypto policy via VASP (if applicable).
5. Localization: language, copyright, age filters, advertising hours/channels, UX patterns without manipulation.
6. Reporting: GGR by verticals, behavioral risk monitoring, ADR/Ombudsman, response time to complaints.
7. B2B partners: due diligence of studios/aggregators, change agreements, release logs.
7) Checklist for the player (how to recognize a legal operator)
The site contains an up-to-date license (ANJ/ADM/DGOJ) and regulator contacts.
There is self-exclusion and limits: they are included in 1-2 clicks.
Bonuses are transparent: the vager is visible, maximum bets/terms.
Official payments: known PSPs, encryption, intelligible withdrawal deadlines.
Public RTP/RNG certificates and content provider information.
Clear KYC process and verification/payment deadlines.
8) Trends 2025
Tightening marketing: unification of prohibitions on "quick earnings," restriction of influencers/streamers without audience verification.
RG behavioral triggers: automatic pauses/checks when "race to lose," night game, deposit spikes.
Cooperation of regulators: joint "black lists" of domains/payments, exchange of data on illegal immigrants.
Crypto under control: allowed via VASP with Travel Rule and SoF/SoW; without it, a block.
Ethics of UX: prohibition of dark patterns, honest defaults, labels "animation ≠ influence on the outcome."
9) Withdrawal
France, Italy and Spain agree on the main thing: player protection and money purity are primary, and marketing and content are under strict discipline. The difference is in the degree of rigor of advertising, the speed of approvals and the detailing of procedures. For the operator, this means: success on FR/IT/ES is not only to "get paper," but to embed RG/KYC/AML standards, technical certification and ethical UX in the DNA of the product. This way you get access to payment hubs, sustainable LTV and audience confidence - what regulation is for.