Online Gaming: ADM Sets Phased Deadlines for Italy’s New Concessionaire System
The ADM (Italian Customs and State Monopolies Agency) has revised the implementation schedule for the entry into force of the new ‘Concessionaire System’, amending the previous deadline of 13th November 2026 and introducing a phased approach that spreads the verification, certification and technical compliance activities over time.
This decision stems from the need to manage a particularly complex transformation process in a more orderly and gradual manner, one which simultaneously involves concessionaires, Service Provider Concessionaires (CFS), Verification Bodies (ODV) and technology suppliers.
The revised compliance schedule, in particular, addresses the need to ensure that each phase of the process can be completed with the necessary technical verifications before proceeding to the next. The aim is to ensure that, by the time the new system goes live, the infrastructure is fully verified, reliable and compliant with the new technical requirements.
In a sector where the correct functioning of systems directly affectsthe proper conduct of gambling operations , the security of operations and the protection of players, the quality and reliability of the certification process are therefore of paramount importance.
The restructuring is therefore not merely a postponement of the final deadline, but rather a reorganisation of the adaptation process: activities are distributed according to a precise technical sequence, taking into account the interdependencies between the various parties and the checks required to ensure the new system is fully operational.
The new ‘Licensee System’, as outlined in the Technical Rules,is not limited to a single technological platform . The process of transformation and structural adaptation involves all the technical components of the system and their correct functioning and interaction: gaming systems, platforms, communication protocols, gaming accounts and other components.
In addition to these technical activities, there are the compliance checks, certifications and technical-functional tests required to ensure the system is fully operational.
Thus, the complexity of the adaptation process is compounded by the numerous interdependencies between concessionaires, Service Provider Concessionaires (CFS), Audit Bodies (ODV), providers and software houses – that is, between all the key players in the supply chain.
This complexity stems precisely from the fact that the activities of the various parties are interlinked.
The phased approach allows the supply chain to spread the verification, certification and compliance activities over an extended period, with a defined sequence of requirements, enabling concessionaires to plan their compliance activities according to a precise sequence, whilst paying particular attention to interim deadlines and coordination with their technology suppliers and the ODVs.
To understand the new revised implementation process, it is useful to clarify the roles of the main parties involved alongside the licence holders.
Service Provider Licence Holders (CFSs) are licence holders who can make one or more gaming systems or technological platforms available to other licence holders, on which remote games are managed.
The new Technical Regulations provide for the possibility for a concessionaire to use gaming systems via a CFS rather than developing and managing the entire infrastructure in-house.
However, when a licence holder uses gaming systems made available by a CFS, the completion of their own certification process also depends on the availability of the systems and components that must be verified and certified beforehand.
This means that if the CFS’s system has not yet been verified or certified, the licence holders using it cannot independently complete their entire system certification process.
Audit Bodies (OdV) are independent bodies operating under agreements with the ADM that carry out technical compliance checks on the concessionaire’s system, ensuring that the system correctly implements the functionalities and protocols set out in the technical rules and specifications required by the ADM. As part of the process, they verify that the concessionaire’s system and its components comply with the applicable technical rules and specifications.
The schedule adopted by the ADM on 7th October sets out four milestones: 13th November 2026, 13th January 2027 and 12th February 2027, with progressive obligations for CFSs and concessionaires. The new system is scheduled to go live on 15 February 2027.
13 November 2026: CFS Systems and Components
13th November 2026: by this date, the requirements relating to the systems and components made available by the CFSs must be met. Therefore 13th November no longer represents the final go-live deadline; instead, it marks the first technical prerequisite that must be met before the next stage of the supply chain can proceed.
From an operational perspective, by this date, the results of the compliance checks on applications from CFSs supplying gaming systems to other concessionaires must be uploaded, and the components required to populate the ‘library’ must be certified.
13 January 2027: Concessionaire Compliance Checks
13th January 2027: deadline for uploading the results of the compliance checks on applications from concessionaires intending to use gaming systems supplied by CFSs.
The sequence of these two dates follows a precise logic: first, the components and systems supplied by the CFS must be certified and made available; subsequently, the concessionaires using them can complete their own verification process.
12 February 2027: Technical and Functional Verification
12th February 2027: completion of technical and functional verification activities.
The revised schedule provides a phased framework for all parties involved: concessionaires, CFSs and ODVs – and enables them to move beyond the ‘single deadline’ approach and to spread out activities according to their actual technical sequence.
The aim of the roadmap drawn up by the ADM is to ensure that the new system is implemented with the necessary guarantees of reliability, security and protection for all parties involved and, first and foremost, for players.
This is a separate stage from the compliance assessment and serves to verify that the system operates correctly in the configuration intended for theoperation under the concession . It marks the conclusion of the overall process of adapting to the new technical rules, i.e. bringing the platforms into line with the new technical requirements.
15 February 2027: New System Goes Live
15th February 2027: marks the operational transition to the new remote gambling framework, following the completion of the technical activities, verifications and certifications required by the new technical regulations.
