ADM sets traceable payment rules for online gaming account top-ups

Italy's ADM set conditions for the use of traceable payment instruments to top up online gaming accounts in director's determination 675265/RU of 22 October 2026, signed by central director Mario Lollobrigida. The measure addresses payment instruments and alternative systems, including vouchers, used for top-ups at Punti vendita ricariche (PVR), according to the determination.

Article 2 of the determination covers services and instruments offered by payment service providers in Italy or established in the European Union that allow the payer and payee to be identified uniquely, recording the date, amount and reason for the transaction. The instruments expressly listed are bank transfers, direct debits, payment cards and prepaid cards. Where the authorisations required by law are in place and banking and anti-money-laundering rules are observed, these instruments are not subject to the restriction in the third sentence of Article 13, paragraph 5, of legislative decree 41/2024 on instruments already indicated by the account holder to the concessionaire and previously validated.

Article 3 allows instruments falling under Article 2, letter m), points 1 and 2, of legislative decree 11/2010, notified to the Bank of Italy, to be used for top-ups if six requirements are met. The purchaser of the instrument must be identified and must be the holder of the gaming account subject to anti-money-laundering checks; the payment may be used only to top up the holder's own gaming account; the operation must be unmodifiable; the instrument may be reloaded only by its identified holder through a PIN, voucher or other method uniquely associated with the instrument; the payment must not be transferable to third parties; and the holder of the instrument must be identifiable. The determination states that vouchers may be used within systems meeting these requirements, and that admissibility depends on the characteristics of the instrument, its link to the holder and its ability to ensure traceability.

Issuers of alternative instruments must attest compliance through a report asseverated by a third party expert in banking and/or anti-money-laundering matters, describing the instrument's technical characteristics and submitted to ADM through one or more interested concessionaires. Before transmission, the concessionaire must verify, on the basis of the attestations in the report, that the required characteristics exist. Submission of the report allows the concessionaire to use the instrument without the restriction on prior indication and validation under Article 13, paragraph 5, of legislative decree 41/2024, and the concessionaire must verify that the requirements continue to be met over time. ADM will send the reports to the Guardia di Finanza and the Bank of Italy, indicating the reference concessionaire, to allow checks. If the requirements are found to be absent or the report untrue, ADM will promptly inform the Bank of Italy, suspend the instrument's operation and apply contractual penalties against the concessionaire, without prejudice to anti-money-laundering sanctions.

Alternative payment instruments already used by concessionaires that meet the Article 3 requirements may continue to be used until 31 March 2027, and interested concessionaires must submit the asseverated report to ADM by that date. New payment instruments may still be introduced after 31 March 2027 under the procedure set out in the determination. ADM also plans checks in the field to verify concessionaires' use of asseverated instruments.

Article 4 requires top-ups made through regulated payment instruments, alternative instruments and cash at PVRs to be recorded directly in the concessionaire's accounts or in the PVR's accounts, then transmitted under the concession's technical rules; the recording also supports monitoring of the weekly limit for cash top-ups. Accounting records for regulated instruments must be kept separate from those for alternative instruments and cash payments. Article 5 requires the account holder to indicate a payment account or suitable payment instrument, necessarily in the holder's own name, to receive sums from the concessionaire, and the concessionaire must verify before crediting that the instrument belongs to the account holder, including through checks with payment service providers or by obtaining documentation. If the instrument is not in the player's name or does not meet the requirements, the concessionaire may not credit the sum and must ask the person to indicate a suitable instrument. Withdrawals through payments at PVRs or other gaming points of sale, including physical-network outlets belonging to the same concessionaire, are expressly prohibited.

Article 6 allows concessionaires to use one or more electronic wallets managed by authorised and supervised intermediaries to move sums held in dedicated bank or postal accounts and to pay winnings, subject to prior notification to ADM indicating the depositary or treasury bank where players' sums are physically held and which guarantees them. Concessionaires remain obliged to use dedicated bank or postal accounts in the concessionaire company's name for custody and management of funds on gaming accounts.