The Gambling Regulatory Authority of Ireland (the “GRAI”) is actively issuing licences for remote and in-person gambling and enforcing the regulatory framework established by the Gambling Regulation Act 2024 (the “Act”).
S.I. No. 31/2026 brought a substantial body of Act provisions into force on 5 February 2026, including those enabling the GRAI to grant the various categories of gambling licence and establishing the civil and criminal compliance and enforcement framework. [1]
A further commencement order, S.I. No. 304/2026, has since been published, bringing the remaining provisions of Chapter 4 of Part 2 (Social Impact Fund) into operation on 30 June 2026.
Licensing
As set out in our previous update, the Act provides for several licence categories – each available for in-person and/or remote gambling – comprising Business to Consumer (B2C) and Business to Business (B2B) gambling licences, licences for charitable or philanthropic purposes, gaming licences, and lottery licences.[2]
The February commencement enabled the GRAI to begin accepting applications and issuing licences to new entrants. Existing operators transition to GRAI licences as their Revenue Commissioners licences expire: remote operators’ licences expired on 1 July 2026; in-person operators face a deadline of 1 December 2026.[3] Both transitions are managed through the GRAI’s new operator portal.
The Gambling (Licence Application Fees) Regulations 2026 and the Gambling (Licensing of Gambling Activities) Regulations 2026 have also been signed, prescribing application fees for betting and gaming licences, and the duration of B2C gambling licences.
Complaints procedures
Part 7 of the Act allows any person to complain directly to the GRAI about an alleged contravention by a licensee of a relevant obligation. The Gambling (Complaints Procedures) Regulations 2026 (S.I. No. 170/2026), published on 24 April 2026, prescribe the procedural steps to be followed by the complainant, licensee, and the GRAI.
The complaints process serves as a gateway to the enforcement framework under Part 8 of the Act. Where the GRAI considers that a licensee has contravened or is contravening a relevant obligation, it may enter into a compliance agreement with the licensee, issue a preliminary notice (followed, where non-compliance persists, by a notice of non-compliance), or carry out a directed investigation.
Enforcement mechanisms
Beyond those powers, the GRAI holds wide-ranging sanction and enforcement powers under Part 8 of the Act, including the ability to:
- conduct inspections and obtain information;
- refer alleged contraventions for adjudication by an independent adjudication officer, who may make a decision as to contravention and impose appropriate administrative sanctions; and
- apply to the High Court for emergency orders to protect the public from the consequences of contraventions by a licensee.
The GRAI may take action against licensees that fail to comply with the terms, conditions or regulations of their licences, and can also act against unlicensed operators or those operating under the wrong licence category.
Available administrative sanctions include the suspension, revocation or imposition of conditions on any gambling licence, and financial penalties of up to €20 million or, if greater, 10% of the licensee’s annual turnover.
Many criminal provisions of the Act have also been commenced, covering unlicensed betting, gaming or lottery activities,[4] cheating, permitting child participation, and falsely representing oneself as a licensee.
In its Statement of Strategy 2025–2027, the GRAI identified the establishment of a robust enforcement framework – including the investigation and prosecution of criminal offences – as a key deliverable by Q3 2026.
The Act further empowers the GRAI to seek court orders directing persons to cease prohibited gambling activities, providing a swift civil remedy alongside the criminal provisions.
Other safeguards and protections
Part 6 of the Act establishes a comprehensive consumer protection framework, now substantially in force.
The framework includes:
- prohibitions on credit card payments;
- mandatory spending limit facilities; and
- remote gambling account regulation, covering account opening, verification, funding, closure and refunds.
Several child protection provisions have also been commenced, including:
- prohibitions on permitting children to gamble; and
- prohibitions on employing children in gambling operations, together with specific obligations on remote operators to verify age[5] and prevent underage access online.
Licensees must notify the GRAI of suspicious gambling patterns that may indicate match-fixing, money laundering or other illicit conduct, and are under a statutory obligation to pay out winnings to participants.
Outstanding provisions
Several further provisions of the Act remain uncommenced, including:
- provisions relating to inducements to gamble and sponsorship;
- provisions relating to approved training programmes for licensee staff, which will require certain Business to Consumer licensees to ensure staff are trained to identify and respond to problem gambling behaviours;
- certain provisions within Part 5 relating to gaming licences and lottery licences (though the general licensing framework applicable to all licence types has been substantially commenced); and
- some additional provisions within Part 5 relating to Business to Business gambling licences and charitable or philanthropic gambling licences (though the core licensing frameworks have been commenced).
No timetable has been announced for bringing these provisions into force, though further commencement orders are expected as the GRAI’s regulatory operations mature.
Recent CJEU case-law – a note of caution for cross-border operators
A recent CJEU ruling is instructive for operators providing online gambling services across the EU. Case C-440/23 (FB v European Lotto and Betting Ltd, Deutsche Lotto Und Sportwetten Ltd) concerned two online gambling operators established in Malta and licensed by the Maltese Gaming Authority whose services were directed at, and accessed by, players resident in Germany – where, at the relevant time, online games of chance were prohibited save for limited exceptions.
The CJEU held that, in the absence of EU-level harmonisation, EU law does not preclude national legislation prohibiting the organisation of online gambling, where that legislation aims to “steer the natural gambling instinct of the population into orderly and supervised channels” and to counter the growth of unauthorised parallel markets. Given the significant moral, religious and cultural differences between Member States on games of chance, each state retains the right to set its own regulatory framework. As a result, consumers may bring restitution claims for lost stakes – on grounds of illegality – against operators licensed in another Member State, where the games at issue were prohibited in the consumer’s Member State of residence.
Operators licensed in an EU Member State, including Ireland, should carefully assess the legal framework in any other Member State where their services are accessible.
What does the Irish framework mean for operators?
Operators in the Irish gambling sector should ensure they are familiar with the new licensing requirements. Remote operators are already operating under the GRAI framework. In-person operators must submit their applications promptly to meet the 1 December 2026 deadline.
The GRAI’s civil and criminal enforcement framework is now substantially in place. All operators should have compliance programmes operational without delay; in-person operators should do so well ahead of the December 2026 transition.
We will continue to monitor developments as further provisions of the Act are commenced. For questions about how these changes may affect your business, or for assistance with licence applications or compliance matters, please contact Karen Reynolds, Connor Cassidy, Marie McGinley, Sarah Jayne Hanna or your usual Matheson contact.
References
[1] The sections of the Act that amend and repeal certain existing legislation have also been commenced.
[2] Various technical amendments have also been made to the licensing provisions in the Act with effect from 30 January 2026, following the commencement of certain provisions of the Courts and Civil Law (Miscellaneous Provisions) Act 2025, by S.I. No. 21/2026. Those amendments address a number of cross-referencing inconsistencies, as well as clarifying that Business to Consumer, Business to Business and gambling licences for charitable or philanthropic purposes will remain in force pending the GRAI’s renewal decision and any appeal determination.
[3] Note that section 85(1)(c), which provides for the issue of combined in-person and remote betting licences, has not yet been commenced.
[4] Note that the criminal provisions relating to unlicensed activity are only partly commenced.
[5] The Gambling Regulation Act 2024 (Verification of Identity and Age) Regulations 2026 prescribe additional means by which a remote gambling licensee can verify the age (and also identity) of a person applying to the licensee to open a gambling account.
