Gambling Compliance Audits in the EU: Regulatory Inspections, Audit Requirements, and Country-by-Country Analysis

Understanding Gambling Compliance Audits

Compliance audits are the primary mechanism through which EU gambling regulators ensure licensed operators adhere to their legal obligations. Unlike the initial licensing process, which verifies an operator's capability to comply, ongoing audits assess actual performance against regulatory requirements. For operators, preparing for and successfully navigating compliance audits is essential to maintaining their license and market access.

The audit landscape in EU gambling has intensified significantly since 2020, driven by several factors: the implementation of the Fifth Anti-Money Laundering Directive (AMLD5), increased regulatory focus on responsible gambling following COVID-19 gambling increases, and the establishment of new regulatory authorities in Germany and the Netherlands. Operators must now demonstrate compliance across multiple overlapping frameworks, from EU-level AML requirements to national gambling regulations.

This guide examines how compliance audits work across major EU gambling markets, what regulators typically inspect, and how operators can prepare for both scheduled and unannounced audits. For information on the consequences of audit failures, see our guide to gambling license revocation and enforcement actions in the EU.

Core Areas of Compliance Audits

While audit scope varies by jurisdiction and operator type, most EU gambling compliance audits cover six core areas. Operators should maintain continuous compliance and documentation across all these domains.

1. Anti-Money Laundering (AML) and Customer Due Diligence

AML compliance is perhaps the most scrutinized area in gambling audits, reflecting the sector's vulnerability to money laundering and the requirements of EU anti-money laundering directives. According to the Financial Action Task Force (FATF), gambling is a designated non-financial business requiring enhanced due diligence.

Auditors typically examine:

• Customer due diligence (CDD) procedures: Verification of identity documents, source of funds inquiries for high-value transactions, and enhanced due diligence for politically exposed persons (PEPs)
• Transaction monitoring systems: Automated detection of suspicious patterns, threshold-based alerts, and investigation procedures
• Suspicious activity reporting: Timely submission of SARs to relevant Financial Intelligence Units (FIUs), documentation of reporting decisions
• Record-keeping: Retention of CDD documentation and transaction records for the legally required period (typically 5-7 years)
• Staff training: Evidence of AML training for all customer-facing and compliance personnel, refresher training schedules
• Risk assessment: Documented enterprise-wide risk assessment and country/product-specific risk evaluations

For detailed information on AML requirements, see our comprehensive guide to gambling and money laundering compliance in the EU.

2. Responsible Gambling Measures

Responsible gambling compliance has become increasingly prominent in EU gambling audits, with regulators examining both the presence and effectiveness of player protection measures.

Key audit areas include:

• Self-exclusion systems: Integration with national registers (OASIS in Germany, Cruks in Netherlands, ROFUS in Denmark), proper blocking of self-excluded players, breach monitoring
• Deposit and loss limits: Implementation of mandatory limits, cross-provider limit enforcement, cooling-off periods for limit increases
• Reality check notifications: Frequency and prominence of session time reminders, player acknowledgment tracking
• Behavioral monitoring: Systems to identify problem gambling indicators, intervention procedures for at-risk players
• Marketing to vulnerable persons: Procedures to prevent targeting of self-excluded or problem gambling customers

Our guide to responsible gambling operator requirements in the EU provides detailed information on technical standards and player protection measures.

3. Technical Standards and RNG Certification

Technical compliance audits verify that gambling software operates fairly and as advertised. This includes:

• Random Number Generator (RNG) certification: Valid certificates from accredited testing laboratories (eCOGRA, GLI, BMM, iTech Labs)
• Return-to-player (RTP) accuracy: Verification that actual RTP matches advertised rates
• Game fairness: Testing of game logic and outcome distribution
• System integrity: Security controls, data protection, and system availability
• Geolocation and access controls: Proper blocking of players from excluded jurisdictions

For B2B suppliers, see our guide to B2B gambling licensing in the EU for software supplier certification requirements.

4. Marketing and Advertising Compliance

Given the extensive advertising restrictions across EU countries, marketing compliance is a major audit focus:

• Advertising content review: Verification that all marketing materials comply with national rules on claims, targeting, and content
• Affiliate compliance: Contracts and monitoring of affiliate marketing partners, responsibility for affiliate content
• Age-targeting: Evidence that advertising reaches appropriate audiences, age-gating on digital channels
• Bonus terms disclosure: Clear presentation of wagering requirements and bonus conditions
• Social media and influencer compliance: Proper disclosure and content standards for sponsored content

5. Age Verification and KYC

Preventing underage gambling is a universal regulatory priority. Audits examine:

• Registration verification: Mandatory age verification before first deposit or play
• Ongoing verification: Re-verification procedures for account changes or suspicious activity
• Documentation standards: Acceptable forms of ID, verification technology providers
• Failed verification handling: Account blocking procedures when verification cannot be completed

See our detailed guide to age verification and KYC requirements in EU gambling.

6. Financial Reporting and Tax Compliance

Operators must demonstrate accurate financial reporting and tax payment:

• Gross gaming revenue (GGR) reporting: Accurate calculation and timely submission
• Tax payments: Correct computation and payment of gambling taxes
• Player funds protection: Segregation of player funds from operational funds
• Financial statements: Audited accounts where required by license conditions

Country-by-Country Audit Practices

Germany: GGL Intensive Supervision

The Gemeinsame Glücksspielbehörde der Länder (GGL) has established itself as one of Europe's most intensive gambling regulators. Following the grant of online gambling licenses under the Interstate Treaty in 2023, the GGL has conducted extensive compliance monitoring.

GGL Audit Characteristics:

• Frequency: New licensees face heightened scrutiny in their first 12-24 months; established operators subject to periodic and risk-based audits
• Unannounced inspections: GGL explicitly reserves the right to surprise audits without prior notice
• Focus areas: OASIS self-exclusion integration, €1,000 monthly deposit limit enforcement, €1 slot stake limit compliance, five-second spin delay implementation
• Remote capabilities: GGL can access operator systems remotely for real-time compliance monitoring
• Documentation language: German-language documentation required for key compliance records

Recent Enforcement: The GGL has issued multiple warnings and sanctions since beginning active supervision. Operators have been cited for advertising violations, self-exclusion failures, and technical non-compliance. The regulator has shown willingness to suspend or revoke licenses for serious violations.

For detailed information on German regulations, see our Germany gambling regulations page.

Netherlands: KSA Risk-Based Supervision

The Kansspelautoriteit (KSA) employs a risk-based supervision model, concentrating audit resources on operators and issues presenting the highest risk to regulatory objectives.

KSA Audit Characteristics:

• Risk categorization: Operators classified by risk level based on size, product types, compliance history, and complaint volumes
• Thematic inspections: KSA conducts industry-wide audits focused on specific issues (e.g., young adult protection, advertising compliance)
• Cruks integration: Mandatory integration with the central self-exclusion register is a primary audit focus
• Advertising monitoring: Active monitoring of advertising across all channels, including affiliate and social media
• Enhanced young adult focus: Special attention to protection measures for players aged 18-24

Recent Enforcement: The KSA has imposed significant fines for advertising violations and has required operators to implement enhanced player protection measures. The authority publishes enforcement decisions, providing transparency on compliance expectations.

See our Netherlands gambling regulations page for complete regulatory information.

Malta: MGA Comprehensive Framework

The Malta Gaming Authority (MGA) regulates one of Europe's largest concentrations of gambling operators and has developed a mature audit framework.

MGA Audit Characteristics:

• Scheduled audits: B2C operators typically audited every 12-18 months; B2B suppliers face annual certification reviews
• Audit notice: Routine audits generally conducted with advance notice; surprise audits for suspected violations
• Player Protection Directive: Audits verify compliance with detailed responsible gambling requirements
• AML/CFT emphasis: Following FATF recommendations, enhanced focus on anti-money laundering controls
• System testing: May include technical testing of games and platform functionality
• Annual compliance reporting: Operators must submit detailed annual compliance certificates

Recent Developments: The MGA has increased enforcement activity, cancelling licenses for AML failures and imposing significant administrative penalties. The authority has also enhanced its guidance on compliance expectations.

Italy: ADM Structural Reform

The Agenzia delle Dogane e dei Monopoli (ADM) oversees Italy's gambling market, which is undergoing significant structural reform with the new 2026 licensing regime.

ADM Audit Characteristics:

• Tax-focused: Significant emphasis on accurate GGR reporting and tax compliance given Italy's high tax rates
• Concession system: Audits tied to concession requirements, with enhanced obligations for new 2026 licensees
• Synchronized self-exclusion: New instant cross-operator self-exclusion creates audit requirements for immediate blocking
• Land-based coordination: Integrated oversight of online and land-based operations
• Advertising ban enforcement: Monitoring compliance with Decreto Dignità advertising prohibition

See our Italy gambling regulations page for comprehensive regulatory information.

Spain: DGOJ Player Protection Focus

The Dirección General de Ordenación del Juego (DGOJ) has intensified compliance monitoring following concerns about gambling activity increases.

DGOJ Audit Characteristics:

• Registration verification: Enhanced scrutiny of player registration and verification procedures
• Self-exclusion (RGIAJ): Verification of integration with the national self-exclusion register
• Advertising compliance: Active enforcement of advertising restrictions, including celebrity endorsement bans
• Bonus marketing: Scrutiny of promotional offers following welcome bonus reinstatement controversy
• Complaint-driven audits: Responsive audits based on player complaints and detected irregularities

Our Spain gambling regulations page provides detailed regulatory information.

Other EU Markets

Preparing for Compliance Audits

Documentation Requirements

Operators should maintain comprehensive documentation readily accessible for audit purposes. The European Gaming and Betting Association (EGBA) recommends operators maintain at minimum:

• Policies and procedures: Current versions of all compliance policies, with evidence of board approval and staff dissemination
• Training records: Documentation of staff training including dates, content, and attendee confirmation
• Risk assessments: Enterprise-wide and product-specific risk assessments, updated at least annually
• Incident logs: Records of compliance incidents, investigations, and remediation actions
• Audit trails: System logs demonstrating control effectiveness and exception handling
• Third-party certificates: Current RNG certifications, testing laboratory reports, and supplier due diligence
• Regulatory correspondence: All communications with licensing authorities

Staff Preparation

Auditors typically interview staff across multiple functions. Operators should ensure:

• Designated audit contacts: Clear responsibility for coordinating audit responses
• Subject matter availability: Compliance, AML, customer service, and technical staff available during audit periods
• Knowledge currency: Staff understand current policies and can explain procedures to auditors
• Documentation access: Staff can locate and present required documentation promptly

System Readiness

Technical systems must support audit requirements:

• Report generation: Ability to produce compliance reports on demand (player activity, self-exclusion checks, AML alerts)
• Remote access: If required by regulator, secure remote access for auditor review
• Historical data: Accessible records for the full retention period required by law
• Test environments: Ability to demonstrate system functionality without affecting live operations

Consequences of Audit Failures

The consequences of non-compliance identified during audits range from informal warnings to license revocation, depending on severity, jurisdiction, and compliance history.

Graduated Enforcement

Most EU regulators follow a graduated enforcement approach:

• Informal guidance: Minor issues may be addressed through informal recommendations without formal action
• Formal warnings: Written warnings requiring specific remediation within defined timeframes
• Compliance directions: Mandatory requirements to implement specific measures
• Financial penalties: Fines ranging from thousands to millions of euros depending on violation severity and jurisdiction
• License conditions: Additional restrictions or monitoring requirements attached to the license
• License suspension: Temporary suspension of operating rights pending remediation
• License revocation: Permanent cancellation of the gambling license

For detailed information on enforcement actions, see our guide to gambling license revocation and enforcement in the EU.

Notable Enforcement Examples

Recent enforcement actions demonstrate regulator willingness to act on audit findings:

• Germany: Multiple operators warned or sanctioned by GGL for technical violations and self-exclusion failures
• Netherlands: KSA imposed fines exceeding €400,000 for advertising violations by major operators
• Malta: MGA cancelled multiple licenses for AML failures and inadequate player protection
• Sweden: Spelinspektionen suspended operators for bonus and advertising violations

Audit Trends and Future Developments

Increased Cross-Border Coordination

EU gambling regulators are increasingly coordinating on compliance matters. The Gaming Regulators European Forum (GREF) facilitates information sharing between national authorities. Operators licensed in multiple jurisdictions should expect coordinated scrutiny of cross-border operations.

Technology-Enabled Auditing

Regulators are investing in technology to enhance audit capabilities:

• Automated monitoring: Real-time data feeds allowing continuous compliance monitoring
• AI-powered analysis: Machine learning to identify compliance patterns and anomalies
• Remote system access: Direct auditor access to operator systems for verification
• Data analytics: Sophisticated analysis of player behavior and operator response

Enhanced AML/CFT Focus

Following FATF evaluations and the proposed EU Anti-Money Laundering Authority (AMLA), gambling AML audits will intensify. Operators should prepare for:

• More detailed source of funds inquiries
• Enhanced transaction monitoring requirements
• Greater scrutiny of high-value and VIP customers
• Cryptocurrency transaction monitoring where applicable

Conclusion

Compliance audits are an essential component of EU gambling regulation, and their intensity continues to increase. Operators must view compliance not as a periodic exercise but as a continuous obligation requiring robust systems, comprehensive documentation, and trained staff. The consequences of audit failures have become more severe, with regulators demonstrating increased willingness to impose significant penalties and revoke licenses.

Successful navigation of compliance audits requires proactive preparation, genuine commitment to regulatory objectives, and the resources to maintain compliance across all required areas. Operators entering EU markets or expanding their presence should factor audit readiness into their operational planning and budget accordingly.

Last Updated: January 2026