Chambers Global Trends And Developments: Gaming Law 2025

Introduction

Malta has steadily evolved into a leading hub for online gaming over the years. Today, hundreds of gaming operators are based on the island, making it a global centre for the iGaming industry. In fact, the gaming industry contributed just under 7% of the Gross Value Added of the Maltese economy in 2024. This consistent performance since 2022 highlights the industry's continued strategic relevance for the Maltese economy.

The Maltese gaming industry continues to undergo a process of consolidation and quality improvements, addressing trends and developments within the ecosystem to ensure that gaming regulation and the overall business ecosystem remains both valid and relevant.

Remarkably, around 10% of online gaming companies worldwide hold a licence issued by the Malta Gaming Authority (MGA) which is the primary regulator of the gaming industry in Malta. In this piece, reference will be made to recent news items, guidance notes or policies that the Authority issued which we have considered to be of note for business looking to establish a footprint in Malta.

Regulatory Landscape and Jurisdictional Sovereignty

The regulatory framework applicable to online and land-based gaming in Malta is consolidated under the Gaming Act (Chapter 583 of the Laws of Malta) and Subsidiary Legislation (SL) 583.01 to 583.12, adopted under that Law.

Article 56A, of the Gaming Act – which is often referred to in its format as a parliamentary bill, namely Bill 55 of 2023 – sparked recent backlash with the European Commission (EC), . Through the EC's Letter of Formal Notice dated 18 June 2025 relating to this legal provision, the discussion has been reignited about Malta's recognition of foreign judgments in the gambling sphere, particularly as various parties in Austria and Germany seek to enforce favourable judgments against Malta-licensed operators .. Although certain media outlets have portrayed Article 56A as an attempt to shield Malta-licensed gaming operators from cross-border enforcement, the true legal position is far more nuanced .

According to the MGA, Article 56A does not create a blanket prohibition on the enforcement of European judgments against Malta-licensed gaming operators, nor does it provide immunity from legal proceedings initiated in other EU jurisdictions. Instead, the provision reaffirms Malta's established public policy on online gaming and aligns with existing EU legal principles—particularly the ordre public exception under the Brussels I Recast Regulation. It does not introduce any new or distinct basis for rejecting foreign judgments.

The MGA emphasises that Article 56A of the Gaming Act merely codifies Malta's long-standing public policy in the gaming sector and does not expand the existing legal grounds for refusing recognition or enforcement of judgments under Regulation (EU) 1215/2012. The Authority reaffirmed its commitment to supporting the Maltese Government in maintaining open and constructive dialogue with the European Commission with a view towards identifying a sensible solution to strike the right balance between the various interests involved.

As at October 2025, the matter remains at the preliminary stage of the infringement procedure. Malta has submitted its formal observations in response to the Commission's notice, and no Reasoned Opinion has yet been issued. The case therefore remains pending before the European Commission, and potential referral to the Court of Justice of the European Union cannot be excluded.

AML & Ownership Transparency

According to the Ministry for Finance's 2018 National Risk Assessment on Money Laundering and Terrorist Financing, remote gaming is particularly vulnerable to financial crime. This is due to factors such as a high number of players, large volumes of transactions, lack of face-to-face interaction, significant participation by non-residents, and the use of unlinked prepaid cards.

The gaming industry continues to face increasing regulatory pressure driven by the Financial Action Task Force (FATF)'s enhanced AML/CFT standards and national enforcement, particularly from bodies such as Malta's Financial Intelligence Analysis Unit (FIAU). Regulators are focusing on transparency, beneficial ownership verification, and compliance monitoring in response to global efforts to curb money laundering and terrorism financing.

In Malta, the FIAU's 2025 Risk Evaluation Questionnaire and Implementing Procedures for the Remote Gaming Sector highlight intensified supervision. These measures aim to ensure accurate disclosure of ownership structures, ongoing monitoring, and sector-specific compliance. Across Europe, the EU AML Regulation (EU 2024/1624) already harmonises requirements and increase consistency in beneficial ownership verification, further tightening oversight on gaming operators.

The FATF's Guidance on Transparency and Beneficial Ownership's revised Recommendations 24 and 25 have raised the bar for beneficial ownership transparency, mandating jurisdictions to collect accurate, up-to-date information through a multi-pronged approach. Regulators now cross-check beneficial ownership data, imposing sanctions where discrepancies arise.

Market Dynamics: Mergers & Acquisitions

The gaming industry has experienced significant merger and acquisition (M&A) activity in 2025, driven by consolidation, diversification, and strategic refocusing.

In 2025 the European gambling and iGaming sector witnessed several landmark transactions, signalling a new wave of consolidation and strategic repositioning. Notably, Greek operator OPAP completed the acquisition of the remaining stake in Stoiximan in July, securing full ownership of the online operator in Greece and Cyprus. Also in Greece, lottery and gaming services provider INTRALOT announced the acquisition of Bally's International Interactive business for roughly €2.7 billion, a combination of cash and newly issued shares, to create a combined technology, lottery-plus-digital gaming group with a strong European and UK presence. Meanwhile, as part of a broader strategic acquisition, Glitnor Group agreed to acquire OneCasino, an online casino operator active in regulated markets including the Netherlands, Spain and Denmark.

Perhaps the most headline-grabbing was the proposed merger between lottery giant Allwyn International and OPAP, structured as an all-share transaction valuing the combined entity at about €16 billion, aimed at creating one of the largest listed gambling companies in Europe. These transactions reflect three major themes: first, full ownership consolidation of high-growth online operations (Stoiximan/OPAP); second, creation of scale and technology integration across online and lottery (INTRALOT/Bally's); and third, mega-scale merger to build a pan-European "champion" operator (Allwyn/OPAP). Each transaction aligns with predictions for 2025 that the iGaming sector would accelerate strategic M&A as regulatory and regional market pressures mount.

M&A activity remains complex due to regulatory scrutiny, competition law reviews, and sector-specific licensing hurdles, particularly in gambling and iGaming. Transactions involving a change of control often trigger regulatory notifications, creating potential deal delays or conditions for approval. Cross-border acquisitions are especially challenging, as each jurisdiction imposes distinct rules on ownership, licensing, and anti-money laundering compliance.

Legal and due diligence risks remain central. Buyers must assess exposure to legacy compliance breaches, unresolved litigation, or violations of national gaming laws. The FDJ–Unibet case in Malta- with a Malta-based subsidiary tied to the Unibet business being implicated in multiple lawsuits over operations in unlicensed markets- underscored the risk of historical licensing issues creating significant legal exposure for the purchaser. Operationally, integration of acquired studios raises difficulties in unifying corporate culture, technology platforms, and regulatory frameworks, while maintaining continuity of live gaming services.

Financially, rising interest rates have made leveraged buyouts riskier, leading to selective acquisitions and divestments of underperforming units. Meanwhile, the industry faces the challenge of balancing innovation and creative independence against corporate consolidation. Overall, gaming M&A in 2025 is defined by strategic restructuring, stricter regulation, and operational complexity — signalling a maturing yet tightly regulated global market.

Innovation (AI, Blockchain, and Sandbox Developments)

The gaming industry is undergoing rapid transformation through AI, blockchain, and regulatory sandbox innovations, each bringing major opportunities alongside new compliance trade-offs. Nonethless, demand in the online gaming industry continues to grow due to the advancements in technology, including the influence of AI.

The 2024 MGA Annual Report held that the EU has experienced a notable increase in demand for varied and interactive gaming platforms, especially in nations with widespread broadband access and a predominantly youthful demographic. On a global scale, the expansion of e-sports and live casino services has further fuelled steady growth. Gamers are showing a growing preference for immersive and highly engaging gaming experiences.

AI is revolutionising game development through automated content creation, smarter non-player characters, and advanced analytics. Developers use generative AI for dialogue, level design, and real-time visual generation, while machine learning optimises gameplay and player engagement. However, AI use raises data protection, intellectual property, and fairness concerns. Regulators are increasingly scrutinising the use of player data under frameworks like the GDPR, and the opacity of AI-driven outcomes poses risks around transparency and accountability.

Blockchain and GameFi models enable new forms of player ownership through NFTs, tokens, and decentralised economies, allowing in-game assets to be traded across platforms. They create novel monetisation and governance systems, but also blur the line between gaming and finance. Compliance challenges include securities regulation, AML/KYC obligations, and exposure to token volatility and smart contract vulnerabilities. Regulators are applying the FATF Travel Rule to token transfers, increasing reporting and due diligence requirements for developers and exchanges.

Meanwhile, regulatory sandboxes, such as the EU Blockchain Sandbox, provide a controlled environment for AI and blockchain experimentation under regulatory supervision. These frameworks support innovation but impose conditions, limited scope, and uncertainty once projects leave the sandbox.

Overall, the convergence of AI and blockchain offers immense creative and commercial potential. Yet, maintaining compliance, data security, and player trust remains essential as regulators push for clearer rules on transparency, accountability, and financial integrity within gaming innovation.

Responsible Gambling & ESG

The gaming industry is increasingly aligning Responsible Gambling (RG) initiatives with broader Environmental, Social, and Governance (ESG) objectives, recognising that player protection is integral to long-term sustainability. Responsible gambling has evolved from a compliance obligation into a key social and governance pillar within ESG frameworks. The European Gaming and Betting Association (EGBA) 2025 Sustainability Report highlights growing transparency, with operators reporting on safer gambling communications, tool usage, and workforce diversity.

Major operators are investing in innovation through initiatives like the Player Protection Lab, supporting research into safer gambling technologies and behavioral analytics. Industry-wide, the use of AI and data-driven tools to personalise player messaging and detect risky behaviour is expanding rapidly. Studies suggest tailored interventions are more effective than generic warnings, helping operators meet regulatory expectations while maintaining player engagement.

At the same time, events such as iGB Live now feature dedicated Sustainable Gambling Zones, reinforcing RG as a shared industry commitment. Collaboration across regulators, platforms, and research institutions is improving standardisation and accountability.

The MGA in its efforts to allign with RG and ESG has a dedicated ESG Committe which lays the foundations for the Authority to lead by example by tracking, measuring and reporting its ESG data. Furthermore, in 2024 the MGA organised a 'Meets' session focused on their voluntary ESG Code of Good Practice and subsequently awarded the first-ever ESG Code Approval Seals to licensees committed to responsible and sustainable practices. Fourteen online gaming operators voluntarily disclosed their ESG practices, marking a significant step forward for the industry. Also in its 2024 Annual Report, the Authority stated that it is preparing for the 2025 ESG reporting cycle which they anticipated will bring further enhancements in future ESG disclosures, reinforcing the gaming industry's role in supporting Malta's broader sustainability goals.

Looking Ahead

Looking ahead, the gaming industry is poised for continued transformation as innovation, regulation, and sustainability converge. Malta's reputation among iGaming companies and players continues to rise. At the core of this success lies the MGA, which plays a pivotal role by consistently introducing well-defined Directives, Policies and Guidance Documents that foster the growth of the gaming industry while maintaining strict oversight to ensure compliance.

As gaming companies navigate evolving technologies such as AI-driven personalization, Web3 economies, and data-centric compliance systems, Malta's collaborative ecosystem of service providers and operators, all working within a robustly regulated framework, will likely continue to attract global investment. The future of gaming will be defined by those who can balance innovation with integrity—leveraging new technologies responsibly, embedding ESG principles into strategy, and maintaining trust with players and regulators alike.

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.