On December 18 2025, a meeting was held between the Customs and Monopolies Agency and the new online gaming concessionaires, during which several interpretative questions arose regarding the relationships between concessionaires and Top-Up Points of Sale (PVR).

In this regard, A.D.M. has clarified some particularly important operational and regulatory aspects, as summarized below:

a) Advertising. ADM has clarified that the ban on posting gambling advertising material, which applies both inside and outside PVRs, does not apply to informational communications related to opening and recharging a gaming account. Therefore, such material does not fall within the restrictions set for advertising.

b) PVR Register. Detailed instructions have also been provided regarding the registration of Recharge Points of Sale in the Register. PVR holders must register, entering all the required information. At the same time, the dealer will be required to record the contractual relationship details for each individual PVR. Only upon completion of this step will the point of sale be considered active. The Agency has also specified that the platform dedicated to managing contracts between dealers and Recharge Points of Sale will become available only after the administrative dispute currently underway regarding the Register has been resolved and the Register is fully operational.

c) Opening gaming accounts. Further clarifications were provided regarding gaming account opening procedures and authentication systems. ADM reiterated that account opening cannot occur without obtaining a valid identity document. However, concessionaires retain the right to organize the process into multiple phases, allowing data entry at different times and providing for a temporary suspension of the process. Regarding two-factor authentication, concessionaires can adopt various solutions, including tools such as SPID or access via personal accounts, such as Google or Apple ID