Background

On 4 March 2025, the Minister for Justice signed the first Commencement Order under the Gambling Regulation Act 2024 (the “Act”). This Order primarily focused on the formal establishment of the Gambling Regulatory Authority of Ireland (“GRAI”), which will serve as the single, independent body responsible for regulating and licensing gambling activities in Ireland.

In the five months since its establishment, the GRAI has undertaken a phased rollout of its regulatory functions, with an initial focus on licensing. The staged approach is intended to facilitate a smooth transition into operational capacity and reflects the graduated enactment of the Act.

Transition to the New Licensing Regime

Licences issued under the old gambling legislation (i.e., licences renewed by 30 June 2025 and first-time applications for licences made prior to the launch of the new licensing regime) will continue to be governed by that legislation until those licences expire on 30 June 2026. Entities that currently hold licences under the old gambling legislation will need to engage with the GRAI well in advance of the expiry of their licence, to ensure they are in a position to hold a licence under the new licensing regime from 1 July 2026.

The new licence categories will be implemented on a phased basis and include:

1. Business to Consumer Gambling Licences:For operators offering online or in-person gaming, betting, or commercial lottery products, irrespective of their physical presence in Ireland. The GRAI intends to set this licence duration to three years, which will be kept under review.
2. Business to Business Gambling Licences:This is a significant new requirement for businesses that provide ‘gambling related services’ to other businesses. Previously, this type of licence was not required.
3. Licences for a Charitable and Philanthropic Purpose: The authorising of games and lotteries for fundraising and not-for-profit purposes.

The GRAI’s current plan is to open Business to Consumer betting licence applications in December 2025 to include in-person and remote licensing. This will be followed by the introduction of remote gaming licence applications by the end of the first quarter of 2026, and the remaining licensing applications by the end of 2027. The GRAI has indicated that it is unlikely to process charity licence applications in 2025.

Application Process

As outlined in the GRAI’s recently published guidance (available here), the new application process will include a three-stage vetting process involving corporate, financial, and technical checks on applicants. To facilitate appropriate due diligence, the GRAI requires an increased amount of supporting documentation as part of the application. The supporting documentation includes the following policies:

1. Anti-Money Laundering / Counterterrorism Financing;
2. Know Your Customer;
3. Responsible Gambling;
4. Risk Management;
5. Whistleblower Policy; and
6. Business Continuity Plans.

The GRAI has advised that the application process may take several months to complete, as all documentation provided will be thoroughly reviewed. Applicants will need to ensure that the required policy documentation is fit for purpose in advance of the application process, to ensure timely renewal.

Key Measures of the Act

The Act represents a significant reform of gambling laws in Ireland and provides a comprehensive framework for the regulation of all types of gambling in Ireland. Key features of the Act include:

1. Social Impact Fund: A Social Impact Fund is established under the Act, requiring annual contributions from commercial gambling licence holders (excluding charitable organisations). This fund will finance initiatives to support those affected by gambling harm and will be managed by the GRAI.
2. Advertising: The Act grants the GRAI significant powers to regulate gambling advertising. A watershed prohibition will be in effect for television and radio advertising between 05:30 A.M and 21:00 P.M. In addition, gambling advertisements may only be directed at individuals who both hold an account with the gambling operator and actively follow the operator’s social media.
3. Inducements: While inducements such as free bets and special offers may be offered to the public, the Act prohibits them from being targeted at specific individuals or groups.
4. Gambling Controls: The Act prohibits the use of credit cards and credit facilities for gambling, and ATMs will also be banned from gambling locations. Licence holders must also provide features for customers to set monetary limits on their accounts.
5. National Gambling Exclusion Register:The register will allow individuals to voluntarily exclude themselves from accessing any licensed online gambling services. Licence holders will be prohibited from accepting payments from, or communicating with, individuals on this register.
6. Enforcement Powers:The GRAI is afforded substantial enforcement powers under the Act. Breaches of the Act can result in significant financial penalties of up to €20 million or 10% of the licensee’s annual turnover (whichever is greater). The GRAI can also make an application to the Court for orders to cease prohibited gambling activities, or to direct internet service providers to block access to gambling platforms.

It is important to recognise that the Act itself has laid down strict rules that reflect government policy which was developed through extensive consultation. These restrictions signal the overarching objective of the Act, which is to promote responsible gambling practices and minimise gambling related harm, particularly towards minors and vulnerable groups. Crucially, the Act affords the GRAI flexibility to adjust requirements (including by way of Code of Practice) to respond to emerging risks and feedback from both the public and industry stakeholders.

Wider Regulatory Considerations

Industry stakeholders will also need to consider other recent regulatory and industry developments alongside the Act. In particular, the Accessibility Act and the recent report of ICPEN on manipulative design practices.

European Accessibility Act (Directive (EU) 2019/882) (the “Accessibility Act”)

The Accessibility Act came into effect across the European Union in June 2025 and is transposed into Irish law by S.I. No. 636 of 2023. The Accessibility Act sets out accessibility requirements for a wide range of products and services, with significant implications for businesses operating in digital environments (including online gambling operators). Online gambling operators are considered ‘service providers’ for the purpose of the Accessibility Act, as they offer consumers an array of digital services as opposed to physical goods. Online gambling operators should consider the extent of their obligations under the Accessibility Act, and any updates to gambling platforms required to comply with such obligations.

International Consumer Protection and Enforcement Network (“ICPEN”)

The ICPEN recently published a report examining the use of manipulative design practices around mobile and online gaming applications. The report highlights growing regulatory concern around game mechanics that blur the line between entertainment and gambling, such as in-app purchases, countdown timers and a particular focus on loot boxes. Gambling operators in Ireland are advised to critically assess and revise any monetisation mechanics embedded in their platform that may be considered aggressive. The report suggests a heightened focus from regulators and legislators, indicating a potential increased likelihood of enforcement action for non-compliance.

Conclusion

The rollout of the GRAI’s regulatory functions under the Act is a welcome move towards effective regulatory oversight and the sustainable development of the gambling sector in Ireland.

Gambling operators are encouraged to engage with the new renewal process as early as possible to ensure sufficient time for processing under the new regime. Early engagement will help support a smooth transition and allow for any additional steps that arise from the new requirements under the Act.  Awareness of other key new features of the Act and how it impacts their operations will also be key for gambling operators and will facilitate them taking the necessary compliance steps.

If you require assistance with any aspect of the Act, including licence renewals, please contact a member of our team. You can also view the Betting and Gaming section of our website for further information.