Italy Clarifies Traceable Payments Above €100 Weekly PVR Deposit Limit

Italy’s gambling regulator, ADM, has clarified how players can fund licensed online gambling accounts above the €100 weekly cash limit at retail recharge points known as PVRs.

Determination 675265/RU, dated October 22, establishes requirements for traceable payment instruments, including named systems funded through PINs or vouchers. Qualifying instruments can operate outside the cash restriction, provided they meet identification, traceability and anti-money-laundering requirements. 

The measure does not remove the €100 limit for cash deposits. It defines which alternative payment systems qualify for different treatment and places verification responsibilities on licensed operators.

Named Instruments Must Match the Player

For dedicated recharge instruments, the purchaser must be identified and must be the same person who holds the gambling account.

The payment can be used only to fund that person’s own account. It must not be transferable to another person, and the payment operation must not be alterable. Only the identified holder may reload the instrument, using a PIN, voucher or another method uniquely associated with it.

These conditions distinguish qualifying systems from anonymous or freely transferable prepaid codes. The reference to vouchers does not authorise every voucher product for deposits above the cash threshold. 

Independent Attestation Required

Issuers must document compliance through a sworn report prepared by an independent expert in banking or anti-money-laundering matters.

An operator wishing to use the instrument must check that report and submit it to ADM. The regulator forwards the documentation to the Bank of Italy and financial police for their respective checks. Operators must also verify that the required characteristics remain in place during use. 

Existing instruments that already satisfy the requirements may continue under transitional arrangements, with the expert report due by March 31, 2027. That deadline concerns documentation for existing systems, rather than a prohibition on introducing new instruments afterwards. 

Cards, Transfers and Withdrawals

The determination also covers transfers, direct debits, payment cards and prepaid cards offered by Italian or EU-established payment providers. Qualifying services must identify the payer and beneficiary and record the transaction’s date, amount and purpose. They need not have been previously designated and validated against the gambling account under the restriction addressed by the determination. 

Withdrawals remain subject to separate safeguards. Operators must verify that the destination payment account or instrument belongs to the player before transferring funds.

Cash withdrawals through PVRs or other gambling retail outlets remain prohibited, including locations within the operator’s own physical network.