The European Union’s digital legislation may significantly impact gambling operators both within and outside the EU.
In their recent analytical report dedicated to the gambling industry – “Betting on Compliance: What the New EU Digital Regulations Mean for Gambling Companies” – lawyers Ted Shapiro and Tamas Szigeti from the law firm Wiggin LLP examined the implications of new EU-wide regulations for the gambling sector.
The Digital Services Act (DSA) (Regulation 2022/2065), the European Accessibility Act (EAA) (Directive 2019/882), and the Artificial Intelligence Act (AI Act) (Regulation 2024/1689) introduce extensive and far-reaching obligations.
Shapiro and Szigeti emphasized that these initiatives are aimed at strengthening consumer protection, improving digital accessibility, and regulating the use of new technologies.
A key feature of these laws is not only their breadth but also their extraterritorial effect, requiring even non-EU companies to reassess their compliance strategies when targeting European consumers.
On June 28, 2025, the European Accessibility Act (EAA) will come into effect, mandating that all digital services provided to EU consumers meet specific accessibility standards. While the EAA is formally a directive (to be implemented into the national laws of EU member states), it essentially becomes a market access requirement.
According to the EAA, any company offering online services in the EU – including gambling platforms – must ensure that their services are perceivable, operable, understandable, and robust for individuals with disabilities.
Although gambling games themselves may fall outside the direct scope of the directive, critical functions such as e-commerce features, user accounts, registration systems, and support tools are likely to be covered.
This means operators will need to adapt their website architecture, mobile interfaces, and customer support services accordingly.
However, regulatory uncertainty is expected, as uniform technical standards may not be in place by the directive’s enforcement date. Although there is a five-year transition period for existing contracts, the lack of clarity could create additional compliance challenges.
While the EAA primarily targets B2C services, its impact is also expected to extend to B2B suppliers, particularly technology providers, who may face increasing pressure to meet new requirements as demanded by their clients.
Since February 2024, the Digital Services Act (DSA) has been in force, regulating the operations of digital intermediaries and platforms.
Depending on service classification (e.g., hosting provider, online platform), different levels of obligations are imposed.
Gambling websites that include chat functions, forums, or social interaction features fall within the scope of these rules. This means:
- Stricter moderation of user-generated content;
- Transparent reporting on moderation efforts;
- Tighter terms of service policies and more responsive removal of illegal content.
The DSA also puts strong emphasis on advertising:
- Ads (including those on gambling websites) must be clearly and transparently labeled in real time;
- This requirement applies to both websites and mobile applications;
- An additional EU-wide code of conduct for fair advertising is expected, further increasing pressure on operators.
The Artificial Intelligence Act (AI Act), adopted in 2024, is still in its implementation phase but already affects gambling companies using AI technologies.
Typical uses of AI in the gambling sector include:
- Fraud detection systems;
- Player behavior analytics;
- Personalized marketing and content delivery.
The law requires AI developers to:
- Ensure algorithmic transparency;
- Comply with specific requirements when using high-risk systems (such as chatbots or customer service tools).
Particular attention will be given to AI-based decision-making, especially when it relates to:
- User verification;
- Responsible gambling practices;
- Advertising personalization.
Operators will need to document and justify their decisions regarding the implementation of such technologies, even if active enforcement has not yet begun.
Taken together, the EAA, DSA, and AI Act reflect a broader EU policy focus on user protection and digital inclusion. Their extraterritorial provisions serve as a warning to gambling operators worldwide: if you serve EU consumers, you must comply with EU regulations.
Failure to do so may result in fines, reputational damage, and potentially being excluded from the EU market.
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