Geolocation and Player Location Verification in EU Online Gambling

Introduction: Why Geolocation Matters in EU Gambling

Geolocation verification is one of the most critical compliance requirements for online gambling operators in the European Union. Unlike some industries where EU single market principles allow cross-border service provision, gambling remains regulated at the national level. As explained in our guide to EU gambling laws, there is no EU-wide gambling license, meaning operators must hold separate authorizations for each country where they wish to offer services.

This jurisdictional fragmentation creates a fundamental compliance challenge: operators must accurately determine where each player is physically located and ensure they only serve players in territories where they hold valid licenses. Geolocation technology provides the technical means to achieve this, but implementing effective location verification requires understanding both the technology and the varying regulatory requirements across EU member states.

According to research published by the European Gaming and Betting Association (EGBA), geolocation compliance is increasingly scrutinized by national regulators, with several high-profile enforcement actions in recent years targeting operators who failed to prevent access from unauthorized jurisdictions.

The Regulatory Framework for Geolocation

EU member states take different approaches to regulating geolocation verification, ranging from detailed technical specifications to general license conditions requiring operators to implement "appropriate measures" to verify player location.

Explicit Technical Requirements

Some jurisdictions have established specific technical standards for geolocation:

• Germany (GGL): The Gemeinsame Glücksspielbehörde der Länder requires operators to verify that players are physically located in Germany before allowing gambling activity. The OASIS self-exclusion system integration also relies on accurate player identification and location. The German Interstate Treaty on Gambling (GlüStV 2021) mandates geo-blocking of players outside German territory.
• Netherlands (KSA): The Kansspelautoriteit requires licensed operators to implement location verification systems that prevent access from outside the Netherlands. The KSA has issued guidance emphasizing that IP-based geolocation alone may be insufficient, recommending multi-factor location verification.
• Malta (MGA): The Malta Gaming Authority includes geolocation requirements in its technical compliance framework. Operators licensed by the MGA serving regulated EU markets must implement location verification appropriate to each target jurisdiction.
• Spain (DGOJ): The Dirección General de Ordenación del Juego requires operators to implement systems preventing access from outside Spain and to integrate with the RGIAJ self-exclusion register, which depends on accurate player identification.

General License Conditions

Other jurisdictions include geolocation requirements within broader license conditions:

• Italy (ADM): The Agenzia delle Dogane e dei Monopoli requires operators to restrict services to players within Italian territory as part of general compliance obligations. Technical audits verify geolocation implementation.
• France (ANJ): The Autorité Nationale des Jeux requires operators to serve only players located in France, with geolocation forming part of technical compliance requirements.
• Sweden (Spelinspektionen): Licensed operators must ensure services are provided only to players in Sweden, with the Swedish Gambling Authority including location verification in compliance assessments.

Geolocation Technologies and Methods

Effective geolocation verification typically requires combining multiple data sources to achieve acceptable accuracy and prevent circumvention. The European Commission's data protection framework also applies to the collection and processing of location data under GDPR.

IP Address Geolocation

IP-based geolocation is the foundational layer for most location verification systems. It works by mapping IP addresses to geographic locations using databases maintained by specialized providers. While relatively easy to implement, IP geolocation has significant limitations:

• Accuracy limitations: IP geolocation typically provides country-level accuracy but can be imprecise at regional or city levels
• VPN vulnerability: Users can easily mask their true IP address using VPN services
• Dynamic IP addresses: IP assignments can change, and mobile networks may route through unexpected locations
• Proxy servers: Corporate networks and ISP configurations can misrepresent user locations

For these reasons, most regulators consider IP geolocation necessary but insufficient when used alone. Our security standards guide discusses how geolocation fits within broader technical security requirements.

GPS and Device Location Services

Mobile devices can provide precise location data through GPS (Global Positioning System) and related satellite navigation systems. GPS offers accuracy to within a few meters under optimal conditions, making it highly effective for gambling apps. However, GPS has its own challenges:

• Permission requirements: Users must grant location access permissions, which some may decline
• Indoor limitations: GPS signals may be weak or unavailable inside buildings
• Spoofing potential: Sophisticated users can fake GPS coordinates using specialized software
• Battery consumption: Continuous GPS monitoring impacts device battery life

Our mobile gambling regulation guide explains how GPS geolocation integrates with other mobile-specific compliance requirements.

Wi-Fi Positioning

Wi-Fi positioning uses the presence and signal strength of nearby wireless networks to estimate location. This method can provide location data even when GPS is unavailable, making it useful for indoor environments. Wi-Fi positioning databases maintained by providers like Google and Apple map network identifiers to locations based on crowd-sourced data collection.

Cell Tower Triangulation

Mobile devices connected to cellular networks can be located based on which cell towers they connect to and the signal characteristics. While less precise than GPS, cell tower data provides a secondary verification layer that's difficult to spoof without physical presence in an area.

Device and Behavioral Fingerprinting

Beyond direct location signals, operators can analyze device characteristics and user behavior patterns to identify location spoofing attempts:

• Timezone settings: A device claiming to be in Germany but with a US timezone setting raises red flags
• Language settings: Operating system and browser language configurations can indicate inconsistencies
• Connection patterns: Latency measurements may reveal that traffic is being routed through distant servers
• Hardware identifiers: Device identifiers can help track users across sessions to detect pattern anomalies

The use of device fingerprinting for geolocation must comply with GDPR data protection requirements, including transparency about data collection and appropriate legal bases for processing.

VPN Detection and Circumvention Prevention

Virtual Private Networks (VPNs) pose the most significant challenge to geolocation verification. VPNs route internet traffic through servers in different locations, masking the user's true IP address. While VPNs have legitimate privacy and security uses, in the gambling context they enable users to circumvent geo-restrictions.

How Operators Detect VPN Usage

Licensed operators employ multiple methods to identify VPN connections:

• Known VPN IP databases: Specialized services maintain constantly updated lists of IP addresses associated with VPN providers. Operators can block or flag connections from these addresses.
• Data center detection: VPN servers typically run in commercial data centers rather than residential ISP networks. Connections originating from data center IP ranges are flagged for additional scrutiny.
• Traffic analysis: VPN connections often exhibit characteristic patterns, including unusual latency profiles and connection behaviors that differ from normal residential internet access.
• Multi-signal inconsistencies: When a user's IP suggests one location but GPS, timezone, or other signals indicate a different location, operators can identify potential spoofing.
• Behavioral analysis: Users who frequently appear to "teleport" between distant locations or exhibit impossible travel patterns may be flagged for review.

Regulatory Expectations for VPN Blocking

Most EU gambling regulators expect operators to actively prevent VPN usage rather than simply detecting it after the fact. The UK Gambling Commission's approach to geolocation compliance has influenced EU regulators, with many adopting similar expectations that operators must use "reasonable measures" to prevent circumvention.

Operators found to have knowingly or negligently allowed VPN access to players from unauthorized jurisdictions face potential enforcement action. Our guide to gambling operator fines includes examples of penalties related to geolocation compliance failures.

Country-by-Country Geolocation Requirements

Geolocation requirements vary across EU member states. This section summarizes key requirements for major regulated markets:

Germany

Germany's Interstate Treaty on Gambling (GlüStV) requires operators to verify players are located within German territory. The GGL expects operators to:

• Verify location at session initiation
• Use multiple location data sources beyond IP address alone
• Integrate with the OASIS self-exclusion system (which requires player identification)
• Block access from VPNs and proxy servers
• Maintain logs of location verification for regulatory audit purposes

Netherlands

The KSA has been particularly active in geolocation enforcement. Dutch requirements include:

• Prohibition of services to players outside the Netherlands
• Multi-factor location verification recommended
• Active VPN detection and blocking
• Integration with CRUKS self-exclusion register

Spain

Spanish regulations under the DGOJ require:

• Restriction of services to players physically in Spain
• Integration with RGIAJ self-exclusion register
• Technical systems to prevent circumvention
• Geolocation verification included in technical compliance audits

Italy

The ADM's Italian licensing framework requires operators to:

• Serve only players within Italian territory
• Implement technical measures preventing unauthorized access
• Connect to the ADM's centralized systems
• Undergo periodic technical compliance assessments

France

The ANJ requires French-licensed operators to:

• Restrict services to players in France
• Implement effective geo-blocking for unauthorized territories
• Include geolocation in technical compliance frameworks

Implementation Best Practices

Based on regulatory guidance and industry standards, the following best practices support effective geolocation compliance:

Multi-Layer Verification

Relying on a single geolocation signal creates vulnerabilities. Best practice involves combining multiple data sources:

1. Primary check: IP address geolocation for initial country-level screening
2. Secondary verification: GPS or device location services (especially for mobile)
3. Cross-validation: Comparison with timezone, language, and device settings
4. Anomaly detection: Behavioral analysis to identify inconsistencies over time

Appropriate Check Frequency

Regulatory requirements vary on how often location must be verified:

• At login: Universally required; verify location before allowing account access
• Before transactions: Many operators verify location before deposits and wagers
• Periodic re-verification: Some regulators require location checks during sessions, particularly for extended play
• Continuous monitoring: The most stringent approach, with ongoing location verification throughout sessions

Clear User Communication

Operators should clearly communicate geolocation requirements to users, including:

• Why location verification is required (regulatory compliance)
• What location permissions are needed
• What happens if location cannot be verified
• That VPN usage is prohibited and will result in account restrictions

This communication supports both compliance and user experience, reducing frustration when legitimate users encounter location-related access issues.

Audit Logging and Documentation

Regulators expect operators to maintain records of location verification activities. The compliance audits guide explains how geolocation logs fit within broader audit requirements. Documentation should include:

• Location data collected and verification methods used
• Outcomes of verification attempts (approved, denied, flagged for review)
• Actions taken when verification failed or VPN usage was detected
• System configurations and updates to geolocation technology

Challenges and Limitations

Despite advances in geolocation technology, several challenges remain:

Border Area Issues

Players located near national borders may experience inconsistent geolocation results, particularly when using mobile devices that may connect to cell towers in neighboring countries. Operators must balance preventing unauthorized access with avoiding false positives that frustrate legitimate users.

Privacy Considerations

Detailed location tracking raises privacy concerns. Under the General Data Protection Regulation (GDPR), operators must ensure location data collection has a valid legal basis, is limited to what's necessary for compliance purposes, and is properly secured. Our GDPR compliance guide discusses data protection obligations in detail.

Emerging Circumvention Technologies

As geolocation verification improves, circumvention methods also evolve. Residential proxy services that route traffic through genuine residential IP addresses are harder to detect than traditional VPNs. GPS spoofing apps can fake device location on compromised mobile devices. Operators must continuously update their detection capabilities to address emerging threats.

Cost and Technical Complexity

Implementing robust geolocation verification requires significant technical investment. Smaller operators may struggle to meet the same standards as large, well-resourced companies. This can create competitive disadvantages and compliance challenges, particularly for operators targeting multiple EU jurisdictions with different requirements.

Enforcement and Penalties

Regulators have increasingly focused on geolocation compliance, with notable enforcement actions in recent years:

• License conditions: All EU gambling licenses include requirements to serve only players in authorized territories. Geolocation failures constitute license condition breaches.
• Financial penalties: Our penalty estimator tool helps operators understand potential fine ranges for compliance failures, including geolocation-related violations.
• License suspension/revocation: Serious or repeated geolocation compliance failures can result in license suspension or revocation.
• Criminal liability: In some jurisdictions, knowingly serving players from prohibited territories may constitute criminal offenses.

Future Developments

Several trends are likely to shape geolocation regulation in the coming years:

Enhanced Technical Standards

As regulators gain more technical expertise, we can expect more detailed specifications for geolocation verification. The trend toward explicit technical requirements (as seen in Germany and the Netherlands) is likely to spread to other EU markets.

Cross-Border Regulatory Cooperation

Improved regulatory cooperation may lead to more consistent geolocation standards across EU member states. Organizations like the Gaming Regulators European Forum (GREF) facilitate information sharing on technical compliance best practices.

AI and Machine Learning

Advanced analytics using artificial intelligence can improve detection of location spoofing by identifying subtle patterns in user behavior and device characteristics. Machine learning models can adapt to new circumvention techniques faster than rule-based systems.

Blockchain and Decentralized Identity

Emerging identity verification technologies may offer new approaches to confirming player location while potentially enhancing privacy. However, regulatory acceptance of such technologies remains uncertain.

Last Updated: January 2026