“The concession system for the management and distribution of public gaming with cash winnings ensures the protection of security and public order, as well as the fight against the infiltration of criminal organizations and the offer of illegal gaming. AGIC (Game and Entertainment Concession Association), a new association belonging to the national Confindustria, represents the main concessionaire companies in the public and regulated gaming sector in Italy, including International Game Technology (IGT), Lottomatica, Sisal Italia and Snaitech, which represent approximately 70% of the Italian legal gaming market and are present in our country with the aim of guaranteeing concrete and professional representation of the sector, enhancing actions and investments in legality, safety and responsibility towards consumers and community, values that have always been at the center of the activities of the participating companies and essential principles for building a solid and modern Italian gaming industry. The Italian Tobacconists Federation (FIT) and the Sports Totoricevitori Union (STS) represent almost all of the monopoly retailers and tobacconists who own gaming, betting, prediction competitions and entertainment machines. Monopoly retailers are State concessionaires for the sale of tobacco and similar products, and professional operators for the collection of gambling who are exclusively entrusted with the concession for the collection of Gambling. Lotto. Furthermore, they constitute the largest sales network for national lotteries with instant draws (Gratta e Vinci) and deferred draws as well as other classic betting games (Superenalotto, betting corners, prediction competitions, AWP)”. This is what we read in a note signed by Union of sports receivers (STS), Italian Federation of Tobacconists (FIT) e Concession Gaming and Entertainment Association (AGIC).
“The public gaming concessionaires and the tobacconist distribution network therefore guarantee a concrete and professional representation of the sector, enhance actions and investments in terms of technology, safety and social responsibility and, while maximizing tax revenues, position themselves as subjects capable of to limit gaming opportunities, combat illegal collection and crime, values and principles that are indispensable for consolidating a solid and modern Italian gaming industry. The two entities considered together - continues the note - can count on a network of over 50.000 physical points, effectively constituting the most important and numerous representation of the sector at a national level. Given their role within the public gaming management and collection system in our country, AGIC and FIT-STS have decided to undertake a path together through which to identify solutions that can be incorporated into the regulatory body of the Reorganization of the sector.
The current picture
In recent years, in the absence of an organic reorganization of the gaming sector, the legislator has been forced to resort to the continuous use of extensions necessary for the continuation of the management of the public service on the physical network, for betting and prediction competitions, entertainment machines with cash winnings, bingo, and on the collection of gambling games. The same Budget Law for 2023 - the associations highlight - has determined the regime for the extensions of these games until 31/12/2024. This tool, although it allowed the continuation of operations, also to the benefit of tax revenues, contributed to generating:
- lack of planning;
- permanence of regulatory uncertainty;
- failure to adapt the sector to technological developments and changes in the market;
- uncertainty for potential investors, including international ones, and poor credibility regarding the industrial sector.
The reorganization of the gaming sector
The current regulatory structure of the sector is characterized by the overcoming of a centralized and organic regulation of the exercise of the gaming offer in the territory, gradually replaced by local regulatory interventions of Regions and Municipalities, limiting the location and opening hours of the points of sale of the game. The overlap and heterogeneity of the aforementioned local regulations - we read further in the note -, in addition to having represented in recent years a serious limitation of the prerogatives of the management of concessions, today constitutes an obstacle to the calling of tenders, preventing the identification of criteria that can guide the management and programming of the game, as well as the design of the territorial network of gaming points on the physical network. An organic reorganization of the gaming sector is therefore necessary, called for by many parties both at an institutional and judicial level, aimed at making it possible to: overcome the extension regime; resolve the territorial issue; guarantee long-term industrial planning; introduce an innovative concession system that takes into account the changed market context and which can be truly effective in the long term.
The art. 15 of Law 9 August 2023, n. 111 ("Fiscal Delegation") provided for the delegation to the Government for the systematic reorganization of the regulatory provisions regarding public gaming, to be carried out through one or more legislative decrees, both with reference to the physical and remote gaming sectors. At present - add the associations - the Government has launched the first reorganization decree on remote gaming, which is being examined by the competent Commissions, and it is hoped that the legislator will be able to continue the work in a short time also for physical gaming, along five lines fundamentals:
- Confirmation of the current concession model, and raising the quality levels of the Concessionaires selected for the management of the electronic network;
- Technological innovation and physical sales networks also in order to resolve the "territory question" and allow the launch for the assignment of the new betting, ADI and Bingo concessions;
- Guarantee of the certainty and stability of the tax levy for the entire duration of the concession relationship;
- Increase in player protection measures towards increasingly ethical, supportive and sustainable models;
- Entrusting of the collection activity to professional and reliable entities, on the one hand the tobacconists receiving them, as direct concessionaires of the State, on the other the specialized and generalist networks, upon possession of specifically identified subjective and objective requirements.
Partnerships between the State and Dealers and between the latter and the operators of the sales networks affiliated with them can become the strategic fulcrum of a qualitative and innovative evolution; equally, selection procedures acquire decisive importance to identify operators who are able to plan, guide and implement this innovation. With specific reference to physical networks - the associations write - the combined provisions of the art. 15 of the Fiscal Delegation and the principles introduced by the new Public Contracts Code will guarantee selection procedures that will have the aim of raising the standards of player/consumer protection, the safety levels and the qualitative and technological profiles of the sales networks, the establishment of an offer network made up of adequately selected tobacconists, specialized points and generalist points, for even more responsible gaming.
Thanks to the dialogue with the territory and through initiatives that we will present in the near future, we will have the opportunity to support the Regulator in achieving the objectives mentioned previously, thus facilitating the overcoming of the "distance meter" logic which has not had positive effects in the fight to gambling addiction and indeed it has caused negative externalities, first of all the expulsion of numerous gambling establishments with consequent repercussions on public safety, employment levels and tax revenue", concludes the note.
