Ireland - move to new regulator

(Section: "Markets and Jurisdictions")

1) What reform is about and why it is important

Ireland is moving from fragmented regulation (historic betting acts 1931 and games/lotteries acts 1956) to a single oversight regime under the auspices of a new body, the Gambling Regulatory Authority of Ireland (GRAI). The base is the Gambling Regulation Act 2024 (No. 35/2024), which introduces a new licensing system, uniform consumer protection standards and a modern AML/CIS framework.

2) Transition key dates and timelines

October 23, 2024 - Gambling Regulation Act 2024 is adopted and published; the act includes transitional provisions for "old" permits (including under the act of 1956).
March 4, 2025 - The Justice Secretary signs the first order enacting parts of the law to launch a new regulator.
March 5, 2025 - "day of establishment" GRAI (state body created on a statutory basis); this is anchored by the S.I. series (S.I. No. 58/2025 и Commencement Order). From that day on, GRAI is the current body.

July - October 2025 - publication of the GRAI Licensing Guide and Strategy 2025-2027; confirmed priority: licensing, monitoring and compliance, enforcement, consumer protection, "digital-first."

3) Who does what now

GRAI is a single independent regulator under the mandate of the Ministry of Justice: licensing of all forms (with the exception of the National Lottery), supervision, compliance and enforcement, consumer protection, advertising and education policies.
Composition and management: chairman, members of the body, CEO (Anne Marie Caulfield) and operational areas (licensing, monitoring, enforcement, consumer protection, etc.).

4) Transition from "old" permissions to a new system

The 2024 Act contains transitional provisions for holders of valid licenses/permits under former laws (Betting Act 1931; Gaming and Lotteries Act 1956): valid rights and obligations are not "terminated," but transferred to a new mode in accordance with the established terms and conditions of GRAI (before expiration, re-registration or migration to new categories). Operators are advised to check the types of current permissions in advance with upcoming GRAI categories and prepare a conversion/re-licensing package.

5) Licensing architecture (high level)

A single "family" of licenses for online/offline products (fixed odds bets, casino games, bingo, etc.), with a clear distinction between B2C/B2B roles.
Flexible matrix of conditions: technical suitability of the platform (RNG/calculation modules), data/logging requirements, financial stability, fit & proper for key persons, RG and AML procedures.
GRAI (Guidance) publications serve as an application map: form structure, document list, upload formats and deadlines.

6) Tax contour (how to "think" when planning)

• Separate the GGR/NGR base (bets − wins) and turnover (handle) where it is directly required by law/by-laws.
• Maintain separate accounting offline/online and by product/channel.
• Prepare monthly declarations and annual reports with audit confirmation.
• (Specific rates/formulas depend on the type of license and current fiscal acts; GRAI requires tax calculations to be traceable from betting/winning/adjustment logs.)

7) Advertising, inductions and player protection

The 2024 law gives GRAI the authority to regulate advertising (including the "watershed" in time) and limit inducements (promotional incentives, "free bets," VIP practices) - in order to reduce harm and protect young people. State communications in 2025 confirm the course towards banning most advertising between the early morning and 21:00, expanding the list of prohibited inductions and increasing responsibility for violation. When implementing - focus on the texts of the Commencement Orders/codes and GRAI notices.

8) AML/CIS: what will be required on "day X"

KYC/KYB Risk-Based Policies: Verification of Age and Identity Prior to Admission to Play/Payouts; sanctions/RAP; source of funds by triggers.
Transactional monitoring: limits, atypical patterns, connections of accounts/means of payment; logging and STR/SAR escalation to competent authorities.
Data storage and GDPR: retention of KYC dossiers and logs; data protection in accordance with European and national law; readiness for supervision requests.

(The AML/CIS framework is integrated into the GRAI license terms and supported by common Irish/EU regulations.)

9) Technical requirements and "digital-first"

GRAI declares a digital approach: API/uploads, test accounts of the regulator, immutable logs (WORM), time synchronization, version control, regular penetration tests and DR/BCP plans with target RPO/RTO. This should ensure that the rate → settlement → payment → adjustment chain is verifiable and that the RG tax calculations/metrics are reproducible.

10) Inspections and enforcement

Office: reconciliation of reporting, payment discipline and GGR/NGR/handle anomalies.
Field/IT audit: log/module inspection, mystery shopping, verification of advertising materials/inductions and traffic attraction channels.

Sanctions: fines, prescriptions, suspension/revocation of licenses; blocking domains/payments. (Confirmed by government releases launching GRAI credentials in 2025)

11) Roadmap for operators and providers

1. Permit mapping: map current licenses (1931/1956) to new GRAI categories; Define a migration scenario.
2. Ready for submission: study Licensing Application Guidance (forms, lists, SLAs, data formats).
3. Finkontur: align GGR/NGR/handle models, bonus accounting schemes/void/cashout, deadline control.
4. AML/RG: Update policies, include deposit/loss/session limits, self-exclusion and marketing filters.
5. IT circuit: WORM logs, API/uploads for GRAI, DR/BCP, penetration tests, version control.
6. Marketing: audit of creatives/inductions for upcoming advertising restrictions and codes; evidence log (screenshots/URLs/dates).
7. UAT and pilot: tax base calculation test cases and RG mechanics; readiness for regulator requests.
8. Go-Live: freeze configurations, runbook incidents, contact window with GRAI.

12) Compliance checklists

Licensing

• Verified GRAI future license category and migration roadmap.
• Kit prepared: fit & proper, financial stability, IT/security descriptions, RG/AML policies.
• Download formats and regular reporting are configured.

Taxes and accounting

• Separate accounting offline/online and by product/channel.
• Traced logs for GGR/NGR/handle and bonuses/void/cashout.
• Monthly Payment/Declaration Calendar.

AML/CIS and RG

• KYC/KYB with sanctions/PEP and source of trigger funds.
• Self-exclusion, deposit/loss/session limits, "cooling."
• STR/SAR logs, KYC retention and logs.

IT and Security

• WORM logs, time synchronization, version control.
• DR/BCP with target RPO/RTO, regular pentests.
• Ready APIs/uploads for GRAI and test accesses.

Marketing and Advertising

• Pre-moderation of creatives and rejection of prohibited inductions.
• Self-excluded filter in CRM/CDP and frequency caps.
• Compliance Evidence Journal.

13) Transition KPI

Fiscal: timely filing ≥99%; discrepancy otchetnost↔billing <0.5%.
Licensing: dossier readiness and successful filing in the first wave; TTR to GRAI requests.
AML/RG: share of players with active limits; blocking time at self-exclusion <1 min; SLA of STR/SAR escalations.
IT/Security: MTTR incidents; coverage with pentests ≥2 times a year; completion of DR tests.
Marketing: 0 violations of the advertising "watershed"; refusal of prohibited inductions.

14) FAQ

When did GRAI become a "live" regulator?
March 5, 2025 - the "day of establishment" was established and key provisions for the start of the organ were put into effect.

What should current licensees do under the "old" acts?
Focus on the transitional provisions of the 2024 Act and Guidance GRAI: prepare re-registration/migration to new categories and keep compliance continuity.

Where to follow the practical steps (forms, deadlines, requirements)?
In publications and news GRAI: Licensing Application Guidance, Strategy Statement 2025-2027 and official notifications of the Ministry of Justice.

What about advertising and inductions?
GRAI is empowered to regulate advertising (including the "watershed") and limit inductions; details are fixed in the introduced sections of the law/codes and government notifications.

Note

This article describes the transition frame and key guidelines. Before submitting applications and the first reporting period, be sure to check the current Commencement Orders, GRAI guidelines and transitional provisions of the 2024 Law - this will reduce the risk of additional charges, prescriptions and pauses in operating activities.