The aim was to develop a licensing system that is proportionate, transparent, and aligned with public interest objectives such as consumer protection and harm reduction.
A total of 27 formal submissions were received, predominantly from industry stakeholders, including operators, consultants, and representative bodies. Public entities, NGOs, and private individuals also contributed to the consultation.
Strong pushback on turnover-based fees
The proposed turnover-based model for calculating application fees emerged as the most contentious issue.
Most respondents warned the model could impose prohibitively high costs, particularly for smaller operators.
Twelve submissions flagged affordability concerns, and nine questioned the definition of “turnover” itself.
Several respondents advocated for a tiered fee model based on Gross Gambling Yield (GGY), a metric widely used across European jurisdictions.
This model, they argued, would better reflect the economic realities of different gambling operators and promote fairness.
Additional recommendations included prorated fees, exemptions or reductions for small-scale operators, and adjustments to the €1,200 per-premises fee, which some claimed disproportionately affected smaller businesses.
for longer licence durations
Most respondents also favoured extending the proposed three-year licence term to five years or more, citing international norms, business certainty, and istrative efficiency.
Respondents pointed to systems in , , Greece, and Belgium, where licence range from five to ten years.
A few respondents also suggested risk-based or performance-based models, where well-performing operators could qualify for longer licence .
Only three respondents endorsed the three-year licence term, generally viewing it as an appropriate starting point for a new regulatory regime.
There was also a call for clarity around renewal procedures, including whether fees would be re-applied and what documentation would be required.
Some warned that high costs combined with short licence durations could inadvertently drive smaller operators out of the regulated sector.Cost concerns and calls for clarity
The third major theme, additional licence conditions, drew input from 19 respondents. Unlike the other two themes, commentary in this area came from both industry and non-industry stakeholders.
There was broad for the introduction of clear, enforceable standards aimed at enhancing consumer protections. However, several submissions flagged potential compliance costs, particularly for smaller operators.
These concerns were paired with calls for early publication of standards and close consultation with stakeholders during their development.
The most frequently suggested measure in this category was the establishment of formal engagement processes with all relevant stakeholders, including public health bodies and civil society organisations.
This would help ensure that technical standards, advertising rules, safer gambling protocols, and data protection requirements are fit for purpose.
Additional recommendations included avoiding overly prescriptive conditions, setting proportionate compliance thresholds, and aligning with established regulatory practices from other European jurisdictions.
Particular emphasis was placed on the implementation of the National Gambling Exclusion (NGER).
Stakeholders advocated for mandatory registration, interoperability across operators, and the inclusion of lifetime exclusion options.
There were also calls for technical guidance and timelines to be published in advance of the application process to allow for proper preparation and budgeting.
Next steps for GRAI
While concerns were raised in fewer than half of submissions per topic, the consultation surfaced consistent themes: a need for clearer terminology, more proportionate fee structures, and regulatory alignment with EU standards.
The GRAI has acknowledged these insights and outlined several observations in response.
These include exploring the tiered GGY-based fee structure, adjusting the premises fee according to operational scale, clarifying definitions, considering longer licence durations for compliant operators and publishing comprehensive renewal guidelines.
The authority also emphasised the importance of early engagement with stakeholders and the timely release of regulatory standards to facilitate smooth implementation.
The report’s findings are intended to shape not only immediate regulatory decisions but also the broader trajectory of gambling policy in Ireland.
The regulator is still in the early stages, but is making significant progress toward its full development.
