Attorney Sbordoni, a speaker at the workshop on PVRs as part of ICE 2026, held in Barcelona from January 19th to 21st, clarified some aspects of the current regulatory and case law situation regarding payment, focusing on PVRs. “The PVRs are somewhat of a sore point in the reform,” the lawyer explained, “in that they are still being considered by the competent courts, in this case the Lazio Regional Administrative Court. The PVR is a familiar figure, one that dates back a long time, dating back to 2007, or even 2006, and has since taken various forms. Today, it’s the point of contact between physical and online, and for this reason, it represents both a bulwark and a problem to be solved. This is the administration’s—or, more precisely, the government’s—idea, because Decree 41 of 24, which initiated the reorganization of gaming, addressing online, specifically establishes the PVR figure in Article 13, establishing its own register. It states that these points of sale, let’s say the points on the current panel, are what takes place at the point of sale, i.e., the payment of the top-up to the gaming account we’re interested in. This five-paragraph Article 13 outlined some of the specific features of the PVR, including the establishment of a register and the traceability, reporting, and enforceability of transactions carried out in PVRs. “Until now,” Sbordoni continues, “we know and don’t know that the use of the PVR is somewhat more flexible among some, many, or few operators, because ‘in and out’ transactions are carried out that are not directly reflected in the legislation. Precisely to limit these transactions, Article 13 established both the register and the famous, controversial limit of €100 per customer per week on top-ups—which has created enormous turbulence in the market—the operating conditions, meaning no cash outs or payment of winnings, and the recognizability of the PVR through the position of an external plate or an identifiable QR code.
The standard contract that must be signed and whose essential elements are communicated by the administration itself requires payments to be made using instruments that ensure the traceability of the transaction, i.e., cash with the aforementioned limit. For other payment methods, such as scratch cards or other methods, they must be brought within the cash limit. All of this is detailed, but in particular the register and the €100 limit are under review because some operators have challenged this provision before the Lazio Regional Administrative Court (TAR). We are now at a final postponement, which then went to the Council of State following a ruling that was subsequently appealed. The Council of State will be held on September 26, 2026, the next date. This creates the uncertainty of applicability that some institutions believe is actually there, as I’ve described it, while others believe it must await the outcome of the trial. Therefore, the outcome has been postponed, as mentioned, until September.”