On 16 June 2025, Italy's Customs and Monopolies Agency (AdM) issued the "Guidelines for Verification Bodies on the technical rules concerning the offer of online gaming services under the scope of Article 6, paragraph 1, letters a) to f), of Legislative Decree No. 41 of 25 March 2024".
Verification Bodies (so-called "Organismi di Verificazione" or "ODV" in short) are duly AdM-registered and accredited entities in charge of carrying out periodical checks on the AdM licensees to verify that they fully comply with the technical requirements.
The scope of the Guidelines is to provide operational and procedural recommendations to be followed by the ODVs in order to adequately verify that the systems conform to the requirements of the AdM Technical Rules underlying the online game offer.
The Guidelines regulate in detail the vetting activity to be carried out by the ODVs, the analysis of the key components of the licensee's system and the methodology to be applied to accurately track and record the outcome of the verification process that must be comprehensive, exhaustive and may also include inspection of the source codes.
All findings must be supported by compilation logs, cryptographic digests and test reports. Such material will then have to be uploaded on the dedicated section of the AdM portal.
The whole verification process is broken down and spelled out in three separate sections of the Guidelines, namely:
- Section A – Verifications pertaining to the requirements specified in the technical rules regarding the licence agreement for the operation and collection of games referred to in Article 6, paragraph 3, of Legislative Decree No.41 of 25 March 2024;
- Section B – Verifications conducted in accordance with the current regulations;
- Section C – Specific features of the various gaming options.
Interim provisions are also encompassed in the last section of the Guidelines for purposes of managing transition to the new operational system, that notably apply to both licensees with proprietary platforms that had already been vetted under the scope of the old AdM rules and those who may be planning to integrate any third party provider components.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
