White Flag Raised On Ireland’s Licensing Regime
The white flag has finally been raised on Ireland’s new regulatory regime with the Gambling Regulatory Authority of Ireland (GRAI) this week announcing that from Monday 9 February 2026 the GRAI would commence accepting B2C Betting licence applications via its online portal. The announcement followed the Minister for Justice’s signing of a commencement order to bring certain provisions of the Gambling Regulation Act, 2024 (“GRAI Act”) into operation. This order brought key elements of the GRAI Act into force, including the GRAI’s enforcement and complaints function. B2C remote betting operators can be licenced from 1 July 2026 with B2C in-person betting operators being licenced from 1 December 2026. The GRAI’s CEO has encouraged operators to engage with the new process as soon as possible to avoid delays.
In addition, the GRAI has released several guidance notes and template documents to assist prospective licensees with navigating the application process and their new obligations. We have set out below a brief overview of a number of the key publications.
1. Guidance on Licensing Obligations
A key set of guidelines which the GRAI recently issued was the Guidance on Relevant Obligations for Business to Consumer Licensees (available here). The document goes through the sections of the GRAI Act which contain obligations which will apply to B2C licensees. The guidance note also provides helpful practical examples of what might constitute a breach of the various obligations. For example, under section 165, licensees are under obligations in respect of the method of payment used by their customers; the guidance underlines that “buy now, pay later” schemes are prohibited and that licensees must ensure that e-wallets are not funded by credit cards. Similarly, under the section 157 obligation not to offer inducements to gamble, the guidance makes clear that licensees cannot offer a loyalty scheme for customers who bet a certain volume over a particular period of time or where the inducements are targeted at a particular cohort of customers e.g. those who follow a particular football team.
The GRAI have said that this guidance will be updated as obligations take effect and that where regulations are required to do this, licensees will be notified in advance of any changes.
2. Guidance on Advertising
Licensees will also have to comply with a series of obligations relating to advertising. Given the extent of these requirements, the GRAI have published a separate guidance note on the topic (available here). The document deals with some of the key GRAI Act obligations on advertising, branded clothing and sponsorship. It follows a similar format to the Licensing Obligations guidance, setting out the relevant provisions in the Act and providing useful practical examples. For instance, under section 146 of the Act, licensees are restricted in their ability to engage others to advertise relevant content on social media or video-sharing platforms on their behalf. The guidance explains that an Instagram social media influencer could not advertise content on behalf of a licensee unless the intended recipient has an account with Instagram and is ‘following’ the social media influencer and licensee on Instagram.
3. Licensing Application Guidelines
The GRAI have set out a broad overview of the new licensing application process in the Licensing Application Guidelines. In summary, following the publishing of a ‘Notice of Intention’ in a national newspaper, the GRAI licensing portal will require details on the applicant business entity, including licensing history in Ireland and abroad, as well as internal policy documents, financial records and business plans. Beneficial owners and relevant officers will also be required to provide details of their licence history, criminal convictions and tax clearances. Once these steps have been approved, the licence application itself takes place. The webinar carried out by the Authority in December (available here) also adds helpful colour on the how the new process will work.
Most recently, the GRAI has published draft guidance on fees. Notably, the application fee that is payable will be based on gross profit generated by the operator on betting activities from Irish customers only. Free bets or bonuses are only counted when calculating gross gaming revenue (“GGR”) if the customer has the unrestricted right to receive the cash equivalent to the value of that free bet or bonus. Application fees are set on a tiered basis commensurate with the applicant’s GGR from the related gambling activities in the preceding year of operation (or the estimated GGR from the provision of such activities for the first financial year of the applicant following the grant of the licence).
5. Legal and Corporate Assessment Guide
This guidance sets out the information that applicants will be required to provide to the GRAI for the legal and corporate assessment, which forms part of the licence application process. This assessment will ensure the accuracy of the information and documentation submitted by the proposed licensee under sections 96 and 97 of the Act. The guidance stresses that the level of detail required on the company, including its current and previous licences (in Ireland and overseas) will depend on the size of the business involved and the type of entity. Moreover, it confirms that the proposed licensee will not receive feedback on this specific process.
For any operator hoping to apply for an in-person licence this year, the GRAI has outlined the sort of information that applicants will need to provide and what the Authority will consider when deciding whether or not to issue an in-person licence. In particular, for non-relevant premises, applicants will need to produce proof of ownership of the premises, planning permission documents and insurance details. There are further requirements where it is proposed to permit children on the premises, or where it is proposed to provide ATMs.
7. Templates
Finally, the GRAI has published several template documents to assist licensees with the new application process. Draft Notices of Intention to apply for a gambling licence have been published, to facilitate compliance with section 95 of the Act, which requires applicants to publish their intention to apply for a licence in a newspaper 28 days prior to making their application. The GRAI has also released guidance on how to navigate the draft notices (available here). A template ‘Declaration and Consent’ document has been published too, which is required in respect of the proposed licensee, as well as any relevant officers or beneficial owners. Business Plan Templates for Medium & Large Operators / Sole Traders & Smaller Operators will assist applicants with their section 96(1)(e) obligations, and the Premises Template will be relevant for applicants intending to provide gambling services from 5 or more premises only.
The publication of these guidance notes will be welcomed by operators as they come to terms with the requirements of the GRAI Act. We anticipate that over the coming weeks as operators have further queries on the new regime that the GRAI will continue to publish further guidance notes and FAQ briefings. If you would like assistance making a licence application to the GRAI or for further information, please contact the team below or your usual McCann FitzGerald LLP contact.
This document has been prepared by McCann FitzGerald LLP for general guidance only and should not be regarded as a substitute for professional advice. Such advice should always be taken before acting on any of the matters discussed.
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