Ireland's Gambling Regulatory Authority (GRAI) has published its response to a critical public consultation, marking a decisive step toward implementing the country's new gambling licensing framework. The regulator commissioned Governance Ireland to analyse stakeholder feedback and will now proceed with formal European Union notification procedures.
Independent analysis reveals stakeholder support
GRAI published Governance Ireland's comprehensive analysis on 05 Jun 25, covering feedback received during a four-week consultation period between April and May 2025. The independent governance consultancy reviewed 27 formal submissions from industry operators, representative bodies, consultants, public bodies, and civil society organisations.
The consultation specifically addressed three key provisions of the Gambling Regulation Act 2024 (Number 35 of 2024): Section 38 covering application fees, Section 108 on licence durations, and Section 129 regarding additional licence conditions.
According to the analysis, the majority of submissions expressed either supportive or pragmatic views on the proposals, with constructive enhancement suggestions rather than fundamental objections. Industry operators particularly demonstrated acceptance of the regulatory framework, despite some concerns around fee structures and licence duration terms.
27
Formal submissions received
4 weeks
Consultation period duration
3
Key Act provisions addressed
3 years
Proposed licence duration
1 year
Minimum licence duration by law
Fee structure concerns addressed
Several respondents raised concerns about application fee structures, often stemming from misunderstandings or divergent interpretations of key terms within the Act, particularly "turnover". GRAI acknowledged these interpretation challenges and committed to addressing definitional clarity through future guidance documents.
"The GRAI commits to address the misunderstanding of terms/definitions through guidance documents in the future."
— Gambling Regulatory Authority of Ireland
The regulator recognised that stakeholders faced difficulty providing comprehensive analysis without full visibility of the complete fee governance framework, including renewal fees and charges. GRAI pledged to communicate relevant fee structures in a timely and constructive manner moving forward.
Comparative analysis with other jurisdictions, particularly the UK, featured prominently in submissions. However, GRAI determined these comparisons were not directly applicable due to fundamental differences in regulatory structure and responsibilities between Ireland and Great Britain.
Regulatory scope differences
GRAI highlighted that many regulatory obligations under its remit fall outside the Gambling Commission's responsibilities in Great Britain, where local councils handle equivalent functions. Market size variations, taxation policy differences, and varying sectoral regulation across jurisdictions further complicate direct fee comparisons.
The regulator emphasised its responsibility to balance licensing complexity with proportionate cost recovery from licensees, ensuring fees reflect regulatory costs based on operator business size and complexity relative to licensing objective risks.
Jurisdictional Comparison Best Practice
When benchmarking Irish fees against other markets, operators should factor in regulatory scope variations. For example, UK operators pay additional local authority fees (£2,000-£10,000 annually) plus separate compliance costs that GRAI incorporates into single licence fees, potentially making direct cost comparisons misleading.
GRAI Fee Structure Transparency
Unlike many regulators that publish complete fee schedules upfront, GRAI's phased approach means operators must navigate initial uncertainty around renewal costs and ongoing charges. Industry sources suggest this mirrors early-stage regulatory development in Malta and Gibraltar, where fee clarity improved over 18-24 months post-launch.
Licence duration framework confirmed
Governance Ireland’s ‘Public Consultation Response Report’
The Gambling Regulation Act 2024 specifies a minimum licence duration of one year. GRAI proposed three-year licence terms, which received support from three consultation respondents. While acknowledging stakeholder themes regarding potential licence term extensions, the regulator confirmed three-year duration as an appropriate starting point.
"The GRAI will commit to keeping the licence term under review as the licensing regulatory framework is established but are satisfied that three-years duration is an appropriate starting point."
— Gambling Regulatory Authority of Ireland
This approach reflects GRAI's commitment to monitoring framework effectiveness while establishing initial regulatory foundations.
Remote gaming licensing context
GRAI noted that remote gaming is not currently licensed within Ireland, making direct application fee cost comparisons potentially inconsistent. The new framework represents a self-financing regulatory regime with enhanced oversight and longer licence terms compared to Ireland's existing excise licensing system.
This regulatory gap underscores the significance of the new licensing framework in establishing comprehensive gambling oversight across all sectors, including previously unregulated remote gaming operations.
Warning
Remote gaming operators currently serving Irish customers without local licensing face potential enforcement action once GRAI's framework activates. The regulator has indicated it will review existing market participants and may require immediate licence applications or market exit for non-compliant operators.
EU notification process advances
Following careful consideration of consultation feedback and Governance Ireland's analysis, GRAI confirmed its intention to proceed with formal notification under the Technical Regulation Information System (TRIS). This standard procedural requirement, governed by Directive (EU) 2015/1535, ensures regulatory coherence across the European Union.
The TRIS notification process involves formal communication to the European Commission, Member States, and the public, representing a crucial milestone in Ireland's gambling regulation modernisation.
"The GRAI intends to proceed with the formal notification of the regulations to the European Commission, Member States, and the public under the Technical Regulation Information System (TRIS), in line with Directive (EU) 2015/1535."
— Gambling Regulatory Authority of Ireland
TRIS Timeline Implications
The Technical Regulation Information System notification typically involves a 3-month standstill period where the European Commission and Member States can raise objections. This means Ireland's licensing framework likely won't be operational until Q4 2025 at earliest, giving operators additional preparation time.
Ongoing stakeholder engagement commitment
GRAI reaffirmed its commitment to continued stakeholder engagement throughout licensing framework implementation, promising additional guidance where necessary. The regulator emphasised constructive dialogue as central to its approach, welcoming collaboration with industry participants, public health bodies, civil society groups, and regulatory peers.
This inclusive methodology reflects GRAI's evidence-led approach to regulatory development, balancing public interest considerations with statutory obligations under the gambling legislation.
Strategic implications for European gambling regulation
Ireland's progression toward comprehensive gambling regulation establishes important precedents for EU member states developing modern regulatory frameworks. The consultation process demonstrates effective stakeholder engagement methodologies while maintaining regulatory independence through external analysis.
The TRIS notification procedure will provide European regulators with insights into Ireland's licensing approach, potentially influencing cross-border regulatory harmonisation efforts. GRAI's commitment to proportionate fee structures based on business complexity and risk assessment offers a template for other jurisdictions balancing cost recovery with market accessibility.
The three-year licence duration framework, subject to ongoing review, strikes a balance between regulatory stability and adaptive oversight – a consideration increasingly relevant as gambling markets evolve rapidly across digital and traditional channels.
Ireland's consultation-driven approach and three-year licence terms could establish new EU regulatory standards, balancing market stability with adaptive oversight as digital gambling evolves.
According to GRAI.
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