The Gambling Regulatory Authority of Ireland (GRAI) is now set to consider implementing a tiered licensing fee structure and a five-year licence term. This decision follows a recent public consultation that revealed significant industry concerns about the proposed costs and duration of gambling licenses under the new Gambling Regulation Act 2024.

The GRAI conducted its public consultation between April 7 and May 5, 2025, seeking feedback from industry stakeholders on two sets of proposed regulations under the Gambling Regulation Act 2024. These covered the application fee for betting and gaming licences (section 38 of the Act) and the duration of a gambling licence (section 108), along with additional conditions (section 129). The Irish gambling regulator reported receiving 27 formal responses from various industry areas, including operators, representative bodies, consultants, public bodies, and civil society organisations. Evaluating these submissions, GRAI stated that most responses, particularly from operators, demonstrated “supportive or pragmatic views on the proposals, including constructive suggestions for enhancement, rather than fundamental objections.”

Consultation Highlights Industry Concerns on Fees

One of the most common concerns raised regarding the application fee was that a turnover model for calculating the total licence cost is considered “unfair.” Respondents argued it “does not take into account the differentiation in the margins earned through different operator and game types,” thereby penalising businesses with low margins. Additionally, respondents highlighted that the proposed definition of turnover was not aligned with what is widely used within the industry.

Concerns were also expressed about the €20,000 baseline fee for a remote licence. This fee was viewed as “a major increase in the minimum cost of a licence vis a vis the current licensing system” and was deemed “prohibitively expensive for small operators,” as well as “far higher than what is charged in the UK and other European markets.” Regarding the €1,200 per premises fee, most respondents felt this was unfair because the same fee would apply across premises regardless of their size, penalising smaller local operators, while no such fee applies to remote operators. There was also confusion regarding the proposed fee structure due to a perceived “lack of clarity on some components.” Specific concerns included that a turnover-based system creates “a disconnect between fees and actual operator revenue” and could pose a threat to the “sustainability of specialised betting offerings” in the market.

In response, most respondents called for a tiered licensing fee structure with metrics that “ensure it is proportionate to the size and economics of the operator,” advocating for a gross gaming revenue (GGY) formula for calculating licence costs. They also sought a scaled entry-level approach for the remote licence for smaller operators and start-ups, and a scaled approach to the in-person premises fee based on gaming unit numbers.

GRAI Responds with Tiered Fee Consideration

GRAI stated that it will consider a tiered licensing fee model based on GGY or a hybrid of turnover and GGY, as this approach “enhances fairness, and minimises market distortion.” The regulator will also consider a layering premises fee that is “commensurate with the scale of the operation within the premises,” and committed to publishing clear definitions for financial terms and transparent methodologies for calculating fees. GRAI also commented on reviewing fees against those in other jurisdictions, such as the UK, but noted, as reported by iGaming Times, that the fees are not directly comparable due to differences in “regulatory structure and responsibility,” “market size variations, differences in taxation policies and sectors that are regulated by Regulators in other jurisdictions.”

Debating Licence Terms: Industry Calls for Longevity

Regarding the licence term, respondents highlighted that longer or indefinite licence periods are common in many international markets due to the administrative burden of renewals. Concerns included uncertainty about whether an application fee would be required again upon renewal after three years, and a perceived “lack of clarity on anticipated frequency and ongoing checks and information requests.” Respondents also warned that high fees combined with short licence durations could “discourage full compliance and potentially drive marginal operators underground,” and that the renewal process would “place a burden on the licensee’s resources.” Suggestions put forward included a five-year or indefinite licence, with the latter potentially offering long-term benefits for both operator and regulator, as well as considering a licence structure that “offers longevity to operators with more robust safer gambling set-ups.”

In response, GRAI stated that it will consider a five-year licence or providing longer terms to operators with a strong compliance history, as this would incentivise good governance and reduce administrative renewal burdens. The regulator also committed to publishing clear and timely licence renewal guidelines for greater certainty and to help operators plan and prepare for renewal. While the proposed three-year licence term had some support, GRAI acknowledged the overall call for extension, stating, as reported by iGaming Times, that it “will commit to keeping the licence term under review as the licensing regulatory framework is established, but are satisfied that three-years duration is an appropriate starting point.”

Next Steps for Regulatory Implementation

With the consultation concluded, GRAI will now send a formal notification of the regulations to the European Commission, member states, and the public under the Technical Regulation Information System (TRIS). This is a standard procedural requirement for technical regulations, ensuring regulatory coherence across the European Union. The regulator stated it will continue to engage with stakeholders as the licensing framework is implemented, providing further guidance when necessary. The GRAI also stated, as reported by iGaming Times, that “Constructive dialogue remains central to our approach,” expressing welcome for ongoing collaboration with all relevant parties, including industry participants, public health bodies, members of the public, civil society groups, and regulatory peers, and reaffirming its commitment to “transparent, proportionate and effective regulation of Ireland’s gambling industry.”

The GRAI’s proactive engagement with industry feedback and its commitment to reviewing key aspects of its proposed licensing framework signal a flexible approach to establishing Ireland’s new gambling regulatory landscape, balancing revenue generation with industry sustainability and consumer protection.