Every country that permits online gambling has to answer one structural question first: who is allowed to offer it? The answer defines the market. It shapes prices and product range, how much tax is collected, and how many players stay with supervised operators instead of drifting to unlicensed sites. This guide explains the main licensing models in use as of October 2026, with examples. For the country-by-country picture, see the global regulation hub.
The five main models
| Model | How it works | Examples (online) |
|---|---|---|
| Open licensing | Any operator meeting the criteria can apply; licences are not capped | United Kingdom, Sweden, Denmark, Spain, Netherlands |
| Concession / capped licensing | A fixed number of licences awarded by tender for a set term | Italy (nine-year concessions from 2025–26) |
| Monopoly | A state-owned or designated operator holds exclusive rights | Norway, Finland (until 2027), Austria |
| Hybrid | Some products are licensed, others are monopolised or banned | France, Germany, Switzerland, Belgium |
| Sub-national | States or provinces decide individually | United States, Canada, Australia |
A sixth category sits outside this table: licensing hubs such as Malta, Gibraltar, the Isle of Man and Curaçao. These jurisdictions license operators that mostly serve customers abroad.
Open licensing
In an open model the regulator sets the conditions: fitness and propriety checks, technical standards, anti-money laundering controls and player-protection duties. Any company meeting them can apply. The UK’s Gambling Commission has run this system since the Gambling Act 2005. Denmark opened its market in 2012, Spain in 2012, Sweden in 2019 and the Netherlands in October 2021.
The argument for open licensing is “channelisation”. If legal operators can offer an attractive product, most players stay where rules on fairness, fund protection and harm prevention apply. The trade-off is commercial pressure: many competitors means heavy marketing, and regulators in open markets tend to pile on advertising, bonus and affordability rules over time.
Concessions
Italy uses a concession model. Under Legislative Decree 41/2024 it ran a new tender. The fee was €7 million per concession for a nine-year term, and 52 concessions went to 46 operators in 2025, with platforms going live around early 2026. A concession model gives the state tight control over who is in the market, but high entry costs favour large groups.
Monopolies
Norway is the clearest European monopoly. Norsk Tipping and Norsk Rikstoto hold exclusive rights, and the state blocks payments and, since January 2025, websites of unlicensed operators. Finland is moving away from its Veikkaus monopoly. Licence applications opened in March 2026, and the regulated competitive market is scheduled to open in July 2027.
Monopolies are legal under EU law only if they genuinely pursue consumer-protection or public-order aims in a consistent way. A monopoly that markets aggressively to grow revenue invites legal challenge (see EU gambling law and the single market).
Hybrid systems
Hybrids are often the result of political compromise.
- France licenses online sports betting, horse-race betting and poker through the ANJ. Online casino games remain illegal, and the lottery stays with FDJ.
- Germany, under the 2021 State Treaty, licenses virtual slots, online poker and sports betting through the joint regulator GGL. Online table games are left to the individual federal states.
- Switzerland allows online casino games only through licences attached to existing land-based casinos.
- Belgium grants online licences only to operators that already hold a land-based licence.
Sub-national regulation
In the United States, legal online casino and sports betting depend on state law. Sports betting is legal in a large majority of states, while real-money online casino gaming is legal in only a handful. In Canada, provinces control gambling. Ontario has run a competitive iGaming market through iGaming Ontario since April 2022, while most other provinces offer only a provincial lottery corporation’s site. Australian states and territories license wagering, but federal law prohibits online casino-style games for Australian residents.
Markets in transition
Several countries are changing model:
- Ireland: under the Gambling Regulation Act 2024, the Gambling Regulatory Authority of Ireland began issuing remote betting licences on 1 July 2026. Online gaming licences are expected in a later phase.
- Brazil: the federally licensed fixed-odds betting and online gaming market opened on 1 January 2025 under Law 14.790/2023.
- Finland: licensing replaces the monopoly for online casino and betting from mid-2027.
- Curaçao: replaced its master-licence and sub-licence system with a new national ordinance and a new regulator from late 2024.
Why the model matters to players
For an individual player, the model determines:
- Whether a site is legal to use. An offshore licence does not override a local requirement. In April 2026 the EU Court of Justice confirmed that member states may ban online casino games even where an operator holds a licence from another member state (case C-440/23).
- Which protections apply. Self-exclusion registers, deposit limits and complaint routes generally cover only locally licensed operators.
- Where to complain. Complaints go to the local regulator or its approved dispute-resolution bodies.
Our guide on how to check whether a gambling site is licensed explains how to verify a licence. The business side, including fees and application steps, is covered in how to obtain a gambling licence. Licensing rules change often, so anyone making legal or commercial decisions should take advice from a qualified lawyer in the relevant jurisdiction.
Frequently asked questions
Which licensing model is safest for players?
No model is automatically safest. Protection depends on the rules each regulator imposes and how well it enforces them, and how much play actually stays inside the regulated system.
Why do some EU countries still have gambling monopolies?
EU law allows member states to restrict gambling to protect consumers and public order, provided the restrictions are consistent and proportionate. Several countries have used that latitude to keep state-owned operators.
Is a Malta or Curaçao licence valid everywhere?
No. It authorises the operator under that jurisdiction's law. Countries with their own licensing regime treat operators without a local licence as unlicensed, and the EU Court of Justice confirmed in 2026 that national bans can stand despite a licence held elsewhere.
What does a 'sub-national' model mean?
It means states, provinces or territories decide whether and how to license gambling, so the same product can be legal in one state and illegal next door.
Important: This article is general information, not legal, financial or medical advice. Rules change — always confirm with the relevant regulator. If gambling is causing you harm, free support is available.
