ADM sets conditions for dedicated gambling payment instruments in Italy

Italy's Customs and Monopolies Agency (ADM) issued directoral determination No. 675265/RU on 22 October 2026, setting the conditions for the use of traceable payment instruments in remote gambling. The measure covers top-ups, withdrawals and the movement of sums, according to the analysis of the determination described in the report. Article 3 of the determination sets conditions for limited-spend instruments dedicated to topping up gambling accounts.

Under Article 2, the determination covers services and instruments offered by payment service providers established in Italy or in the European Union that can uniquely identify payer and payee and record the date, amount and reason for the transaction. Bank transfers, direct debits, payment cards and prepaid cards fall within this article. Article 3 sets a separate route for limited-spend instruments referred to in legislative decree 11/2010, notified to the Bank of Italy as set out in the determination and subject to further requirements.

An instrument qualifies as dedicated where the payment serves exclusively to top up the gambling account of the instrument's holder. The determination also requires identification of the buyer, correspondence between the buyer and the holder of the account subject to due diligence, the unmodifiability of the operation and the non-transferability of the payment to third parties. The funding of the instrument must also be traceable to the identified holder, through a PIN, voucher or other means uniquely associated with the instrument. The use of an application, code or voucher, considered on its own, does not demonstrate that all the requirements are met.

For Article 3 instruments, issuers attest the requirements under their own responsibility through a report certified by a third party expert in anti-money laundering and/or banking matters. The document must describe the instrument's technical characteristics and be submitted to ADM through one or more concessionaires interested in using it. Before submission, the concessionaire verifies that the requirements are met on the basis of the attestations in the report. Submission of the report allows use of the certified instrument under Article 3, paragraph 3. ADM sends the documentation to the Guardia di Finanza and the Bank of Italy, indicating the reference concessionaire, for checks within their respective competences; this step is distinct from the notification to the Bank of Italy required for the category of instruments cited in the determination.

Compliance checks continue while the instrument is in use. The concessionaire must verify that the attested characteristics and requirements persist, while ADM checks the use of certified instruments, including through checks in the field. For instruments already in use and compliant with the requirements, the determination provides a transitional period until 31 March 2027, by which interested concessionaires must submit the certified report. From the following day, those instruments can no longer continue on the basis of the transitional provision alone. Checks may also be carried out earlier. Where the absence of requirements or the untruthfulness of the report is established, ADM promptly informs the Bank of Italy, suspends the instrument's operation and applies the conventional penalties to the concessionaire; anti-money laundering sanctions remain in place where their conditions are met.

Salvo Vullo, chief executive of Kogem, which supports concessionaires in coordinating technical, administrative and regulatory obligations, said the first task is to understand how the measure translates into the processes actually used. He said the full top-up path must be known: who issues the instrument, how it is purchased and funded, what checks are carried out on the holder and how the payment reaches the gambling account. Vullo said the introduction of an instrument requires oversight that continues over time, with software updates, procedural changes and new integrations assessed for their effects on the requirements and checks.

The report says the concessionaire must coordinate issuers, technology suppliers and the commercial network. For retail top-up points (PVR), it highlights instructions on identification methods, permitted instruments and the circumstances in which to interrupt an operation and contact the concessionaire, with staff training described as an essential part of applying the measure. The determination also addresses the €100 weekly limit on cash top-ups at PVRs: for instruments under Articles 2 and 3, exclusion from the limit applies under the conditions set by the determination and in compliance with other applicable obligations and limits. For dedicated instruments, that possibility is accompanied by specific requirements, certification and continuing checks.