In an interview with Gioconews on March 3, Attorney Stefano Sbordoni answered several questions regarding the government’s planned decree to reorganize physical gaming.

1. You stated that gaming “deserves to be addressed in a non-propagandistic manner.” From this perspective, how do you assess the approach of the decree reorganizing land-based gaming that the Government is preparing? Also, considering a more active involvement of local authorities, do you believe there is room for a new narrative — especially political — around the sector?

I believe the fundamental prerequisite is to move away from an emergency-driven and symbolic approach and towards a structural and coherent regulatory framework. Public gaming is a lawful activity, licensed and regulated by the State; as such, it should be governed through balanced legal instruments, not through measures inspired by consensus-building needs or ideological interpretations of the phenomenon.

If the reorganization decree moves in the direction of greater legal certainty, homogeneous territorial planning, and a clear allocation of powers between the State and local authorities, then we may truly speak of a paradigm shift. The involvement of territorial entities is positive, provided that it does not result in regulatory fragmentation which, in the past, has generated litigation and uncertainty for operators.

A new narrative is possible only if one principle is affirmed: regulation does not mean promotion, but neither does it mean demonization. It means consumer protection, safeguarding legality, combating illegality, and ensuring the economic sustainability of the sector. This is the balance against which politics should measure itself.

2. The debate refers to a “radical reform of licenses,” with proposals involving large concession lots and a strong concentration of supply. From your ASTRO-Utis perspective, what risks do you see for the network of small land-based outlets, and what corrective measures would you propose to avoid a market effectively reserved to large global operators?

First of all, what you refer to as the UTIS observatory is now ASTRO-Utis, following the merger of Utis into ASTRO. In reality, a complete answer should begin with the current data on market share distribution. The risk may lie in costs and break-even times. The challenge is to find the right balance between guarantees for the granting State, allowing activities to be carried out sustainably, and access to the service according to the principles of freedom of enterprise and competition law limitations.

Concessions structured in large lots, economically and financially accessible only to multinational operators, could satisfy certain needs but not others.

For the network of small physical outlets — which represent not only an economic but also a social and territorial presence — this scenario must not translate into progressive marginalization or into unbalanced contractual dependence on large concessionaires.

In my view, corrective measures should move along three main lines:

Accessibility of tenders, with proportionate lots and adequate — even significant, but not punitive — economic and financial requirements.
Network protection clauses, ensuring fair contractual conditions between concessionaires and retail outlets.
Recognition of the value of historical networks, such as those represented by ASTRO-Utis, as entities that have contributed to building the Italian concession-based system and ensuring its lawful territorial capillarity.

A reorganization producing an exclusively financial selection process would risk impoverishing the distribution network and, paradoxically, encouraging less controllable channels.

If the reorganization truly leads to an intense phase of mergers and acquisitions, including the circulation of player databases, what regulatory and supervisory safeguards are necessary, in your opinion, to ensure that the economic value of data does not prevail over consumer protection and the protection of vulnerable individuals?

Here the issue moves onto particularly delicate ground: the protection of personal data and vulnerable individuals.

In an M&A scenario, it would be advisable for the circulation of databases to be subject to strict controls, both under GDPR and sector-specific regulations. Formal compliance with notices and consent requirements is not sufficient: it is necessary to ensure that data transfers do not result in excessively aggressive commercial practices or targeted profiling likely to increase spending among the most vulnerable players.

Possible measures could include:

Regulatory due diligence procedures in acquisition transactions.
Guidelines from the regulatory Authority and the Privacy Authority regarding database transfers.
Enhanced obligations concerning traceability and segmentation of data relating to self-excluded or at-risk individuals.

Player data cannot be considered merely a corporate asset: it is sensitive information affecting the fundamental rights of individuals.

The Government is considering a possible revision of the ban on gambling sponsorships in sports introduced by the “Decreto Dignità.” Within the framework of the new land-based gaming reform, how can the return of operators to club jerseys be reconciled with the need to prevent gambling disorders and ensure social responsibility?

The absolute ban has shown evident limits, including in terms of concrete effectiveness, especially considering the growing advertising exposure originating from abroad and from digital channels.

Any revision, however, should be based on a regulated and responsible model, not on indiscriminate liberalization. In addition to the obligations concerning clear and visible responsible gaming messages already provided for in the new online concessions, the following measures could also be envisaged:

Quantitative and qualitative limits on advertising messages, excluding suggestive or aggressive content.
Allocation of part of advertising investments to funds dedicated to the prevention and treatment of gambling disorders.

Reconciliation is possible only if the “all-or-nothing” logic is overcome and a system is built in which sponsorship is allowed within a virtuous framework of social responsibility.

Between territorial planning, distance restrictions from sensitive places, and network rationalization, the land-based gaming reform promises greater “predictability” for investors but also fewer outlets across the territory. From the perspective of sports betting retailers, which distribution model appears most sustainable in the medium term, and what role do you believe should be recognized for the historical networks represented by Utis within the new balance between traditional retail and large international players?

Again, it should be clarified that what were once known as sports betting retailers are now more generally referred to as operators or retailers.

As for medium-term sustainability, this should not be measured solely by the number of outlets, but by their quality, contractual stability, and integration within a coherent system.

A balanced model should provide for:

Planned rather than random distribution, avoiding both irrational concentrations and territorial desertification.
Formal recognition of those who were once sports betting retailers, and are now operators, as professional actors with specific experience and training. As UTIS, we proposed the adoption of the “Retailer’s License” among the measures aimed at enhancing the traditional network as a safeguard of legality and social control, particularly with regard to illegal or quasi-legal phenomena.

Historical networks should not seek corporatist protections, but rather equal dignity and non-discriminatory market conditions. In a mature system, pluralism among land-based operators and their quality are not obstacles but guarantees of balance.

In summary, the reorganization will truly constitute reform only if it succeeds in combining three needs: legal certainty, effective consumer protection, and the economic sustainability of the sector. Privileging only one of these dimensions would mean compromising the overall balance of the system.