Land-Based Casino Regulation in the EU: Licensing, Location Restrictions, and Operating Requirements

Understanding Land-Based Casino Regulation

Land-based casinos occupy a distinct position in European gambling regulation. Unlike online gambling, which has seen liberalization across many EU markets over the past two decades, physical casinos remain subject to traditional regulatory frameworks that often date back decades. These frameworks typically feature stricter entry barriers, location-based restrictions, and more intensive ongoing supervision than their online counterparts.

According to the European Gaming and Betting Association (EGBA), the EU land-based casino sector generates approximately EUR 10-12 billion in gross gaming revenue annually, representing a significant but declining share of total gambling revenue as online channels continue to grow. This shift has prompted some regulators to reconsider land-based licensing frameworks, though fundamental approaches have remained largely stable.

The Court of Justice of the European Union (CJEU) has consistently upheld the right of member states to restrict gambling, including through concession systems and numerical caps on casino licenses, provided such restrictions are genuinely aimed at public interest objectives like consumer protection and crime prevention rather than economic protectionism. This judicial approach has preserved significant national discretion in land-based casino regulation.

Licensing Models Across the EU

EU member states employ several distinct approaches to land-based casino licensing, each reflecting different policy priorities and historical developments:

Concession Systems

The concession model represents the most restrictive approach to land-based casino licensing. Under this system, governments grant a limited number of long-term licenses through competitive tender processes, typically with significant upfront payments and ongoing revenue sharing:

• Italy: The Agenzia delle Dogane e dei Monopoli (ADM) oversees four historic casino concessions (Venice, Sanremo, Campione d'Italia, and Saint-Vincent) plus additional gaming hall permits. Concession terms extend decades and involve substantial fees. For more on Italian regulation, see our Italy country guide.
• Portugal: The Servico de Regulacao e Inspecao de Jogos (SRIJ) manages casino concessions in designated gaming zones including Estoril, Lisbon, Povoa de Varzim, and the Algarve. Concessions run for 15-20 years with competitive renewal processes.
• Austria: Casinos Austria AG holds exclusive concession rights for land-based casino operation, with 12 casinos across the country. The concession system has faced EU law scrutiny but remains operational.

Limited Licensing with Geographic Restrictions

Several countries permit private casino operators but impose strict geographic and numerical limitations:

• France: French casinos may only operate in designated spa towns, coastal resorts, and certain mountain communities. According to data from the Autorité Nationale des Jeux (ANJ), France has approximately 200 licensed casinos concentrated in these permitted locations. Municipal approval is required, and the communes share in gaming revenue. See our France country page for more details.
• Spain: Casino licensing in Spain is delegated to autonomous communities, resulting in varied approaches. Most regions limit casino numbers and require location in tourist or entertainment zones. The national regulator, Dirección General de Ordenación del Juego (DGOJ), maintains oversight of general gambling policy. More information is available on our Spain country page.
• Germany: The Gemeinsame Glücksspielbehörde der Länder (GGL) coordinates between state regulators. Land-based casino licensing remains a Länder (state) competence, with most states operating state-owned casinos or granting limited private concessions. Our Germany country guide provides comprehensive coverage of the German regulatory framework.

State Monopoly Models

Some EU countries maintain state monopolies for land-based casino operation, either prohibiting private operators entirely or limiting them to specific segments. These monopolies have faced CJEU scrutiny but can be maintained if genuinely aimed at consumer protection:

• Finland: Veikkaus holds an exclusive monopoly for all gambling including land-based casinos. The Casino Helsinki is Finland's only full-scale casino.
• Poland: Totalizator Sportowy operates under a state monopoly framework. Private casino operators are not permitted.
• Sweden: While online gambling was liberalized in 2019, land-based casinos remain under the state-owned Svenska Spel's Casino Cosmopol brand, operating four casinos in Stockholm, Gothenburg, Malmö, and Sundsvall.

For more on state monopoly models, see our article on State Gambling Monopolies in the EU.

Open Licensing Jurisdictions

A few EU jurisdictions have more open approaches to land-based casino licensing:

• Malta: While Malta is renowned for online gambling licensing through the Malta Gaming Authority (MGA), the island nation has no land-based casinos. This reflects deliberate policy choice and the island's focus on the digital gambling sector.
• Cyprus: Following 2015 legislation, Cyprus awarded an integrated resort casino license to City of Dreams Mediterranean. Additional satellite casinos are permitted under the regulatory framework.

Location and Zoning Requirements

Land-based casino regulation typically includes significant location restrictions designed to limit gambling accessibility and protect vulnerable populations:

Common Location Restrictions

• Distance from sensitive locations: Many jurisdictions require minimum distances between casinos and schools, religious buildings, hospitals, and residential neighborhoods. These buffer zones can range from 100 meters to several kilometers.
• Tourist/resort area requirements: Countries like France explicitly limit casinos to resort areas, while others informally concentrate licenses in tourist destinations.
• Municipal approval: Local government consent is commonly required, giving municipalities effective veto power over new casino developments.
• Regional caps: Some countries limit the number of casinos per administrative region or per capita population.
• Integrated resort models: Newer developments often require casinos to be part of larger integrated resort complexes including hotels, convention centers, and entertainment venues.

Zoning and Planning Considerations

Casino developments typically require planning permission in addition to gambling licenses. Planning authorities may impose conditions regarding:

• Building design and integration with local architecture
• Traffic management and parking facilities
• Environmental impact assessments
• Community benefit provisions
• Operating hour limitations based on local conditions

Licensing Requirements and Procedures

Land-based casino license applications across EU jurisdictions typically involve rigorous assessment of multiple factors:

Applicant Suitability

• Corporate structure: Detailed disclosure of ownership, beneficial owners, and group structure
• Financial capacity: Evidence of sufficient capital for establishment and ongoing operation, typically requiring substantial minimum capitalization
• Criminal background checks: Comprehensive screening of directors, key executives, and significant shareholders
• Technical competence: Demonstrated experience in casino operation or equivalent entertainment/hospitality sectors
• Integrity assessment: Reputation checks including regulatory history in other jurisdictions

Business Plan Requirements

Casino license applications typically require detailed business plans covering:

• Gaming floor layout and game mix
• Staffing plans and training programs
• Security and surveillance arrangements
• Responsible gambling policies and procedures
• Anti-money laundering controls
• Financial projections and viability analysis

Tender Processes

In concession systems, licenses are typically awarded through competitive tenders. The European Commission requires that such processes comply with EU procurement principles including transparency, equal treatment, and non-discrimination. Evaluation criteria commonly include:

• License fee and revenue-sharing proposals
• Investment commitments
• Job creation projections
• Responsible gambling undertakings
• Integration with tourism and economic development

Operating Requirements

Licensed land-based casinos must comply with extensive ongoing requirements covering all aspects of operation:

Gaming Floor Regulations

• Game approval: All games offered must be approved by the regulator, with specified rules and payout percentages
• Table limits: Minimum and maximum betting limits subject to regulatory approval
• Equipment standards: Gaming equipment (cards, wheels, electronic gaming machines) must meet certified standards
• Layout approval: Gaming floor configurations typically require regulatory sign-off

Security and Surveillance

Casinos must maintain comprehensive security infrastructure:

• CCTV coverage: Complete surveillance of gaming areas with footage retained for specified periods (typically 30-90 days)
• Trained security personnel: Qualified security staff with background checks
• Cash handling procedures: Documented processes for money movement and count rooms
• Incident reporting: Mandatory reporting of security incidents to regulators

Financial Controls

• Revenue reporting: Regular detailed reports on gross gaming revenue by game type
• Taxation compliance: Gaming taxes, typically calculated on GGR, must be calculated and remitted accurately. See our article on Gambling Operator Taxation in the EU for tax rate details.
• Audit requirements: Regular financial audits, often including specific gaming audit procedures
• Chip accountability: Strict tracking of casino chips and tokens

Operating Hours

Operating hour restrictions vary significantly across EU jurisdictions:

Staffing and Employment Requirements

Casino operators must meet specific staffing requirements designed to ensure competent, honest operation:

Key Personnel Licensing

• Personal licenses: Directors, managers, and gaming staff typically require individual licenses or registrations
• Background screening: Criminal record checks for all casino employees
• Ongoing monitoring: Continuing obligations to report changes in personnel circumstances

Training Requirements

• Dealer certification: Croupiers and dealers must complete approved training programs covering game procedures
• Responsible gambling training: Staff must be trained to recognize signs of problem gambling and intervention protocols
• AML training: Employees handling transactions must understand anti-money laundering obligations
• Customer service: Standards for player interaction and complaint handling

Employment Conditions

Some jurisdictions impose specific requirements on casino employment:

• Minimum staffing levels during operating hours
• Restrictions on staff accepting gratuities
• Cooling-off periods before staff can gamble at their employer's premises
• Specific requirements for dealing with staff gambling problems

Responsible Gambling Requirements

Land-based casinos must implement comprehensive responsible gambling measures:

Patron Identification and Registration

• Entry requirements: Most EU casinos require ID verification before entry, with visitor details recorded
• Age verification: Strict checks to prevent underage gambling (typically 18+, 21+ in some jurisdictions). See our article on Age Verification and KYC Requirements for more details.
• Self-exclusion checks: Integration with national self-exclusion registers (OASIS in Germany, Cruks in Netherlands, RGIAJ in Spain)

On-Floor Interventions

• Staff training: Personnel trained to identify problem gambling behaviors
• Intervention protocols: Documented procedures for approaching patrons displaying concerning behavior
• Time reminders: Some jurisdictions require periodic reminders to patrons about time spent gaming
• Break encouragement: Policies encouraging patrons to take regular breaks

Information and Support

• Visible messaging: Responsible gambling information prominently displayed
• Helpline details: National gambling helpline numbers available
• Self-assessment: Materials allowing patrons to assess their gambling behavior. See our Gambling Self-Assessment Tool.
• Referral pathways: Processes for connecting patrons with support services

For more on responsible gambling requirements, see our article on Responsible Gambling Operator Requirements in the EU.

Anti-Money Laundering Obligations

Land-based casinos face significant AML obligations under EU law, implemented through national legislation:

Customer Due Diligence

• Entry identification: Recording patron details upon casino entry
• Transaction thresholds: Enhanced verification for transactions above specified thresholds (typically EUR 2,000-3,000 for chip purchases)
• Source of funds: Inquiry into the source of significant sums
• Ongoing monitoring: Tracking patron behavior for suspicious patterns

Record Keeping and Reporting

• Transaction records: Detailed records of significant transactions retained for 5-10 years
• Suspicious activity reports: Mandatory reporting of suspicious transactions to national FIUs
• Staff training: Regular AML training for all relevant personnel

For comprehensive AML coverage, see our article on Gambling and Money Laundering: AML Compliance Requirements in the EU.

Country-by-Country Analysis

France: The Largest Market

France hosts the EU's largest land-based casino sector with approximately 200 licensed casinos concentrated in designated resort areas:

• Location restrictions: Casinos permitted only in spa towns (stations thermales), coastal resorts (stations balnéaires), and certain mountain communities
• Municipal involvement: Communes grant authorization and receive a percentage of gross gaming revenue
• Game restrictions: Slot machines (machines à sous) permitted since 1987; table games including blackjack, roulette, poker
• Operating structure: Major operators include Barrière Group and Partouche Group
• Online contrast: While land-based casinos flourish, online casino games remain prohibited in France

Germany: Federal Complexity

Germany's federal structure creates a complex land-based casino landscape:

• Länder competence: Each of Germany's 16 states regulates land-based casinos independently
• Mixed ownership: Some states operate state-owned casinos; others license private operators
• Major operators: Spielbank Berlin, Spielbanken Bayern, Westspiel (NRW)
• OASIS integration: All casinos must check patrons against the national self-exclusion register
• Game selection: Roulette, blackjack, poker, and slot machines commonly available

Italy: Historic Concessions

Italy's land-based casino sector is characterized by a small number of historic concessions:

• Four major casinos: Venice, Sanremo, Saint-Vincent, and Campione d'Italia (though Campione faced financial difficulties)
• Concession model: Long-term concessions with significant municipal involvement
• Gaming halls: Separate regulatory framework for gaming halls (sale bingo) with VLTs and AWPs
• ADM oversight: Agenzia delle Dogane e dei Monopoli regulates all gambling

Spain: Regional Variation

Spain's autonomous communities control casino licensing, creating regional diversity:

• Major casinos: Casino de Barcelona, Gran Casino Madrid, Casino Mediterraneo
• Regional licensing: Each autonomous community sets its own casino numbers and requirements
• Integrated resorts: Some regions have explored integrated resort-style development
• Self-exclusion: National RGIAJ register applies to all casinos

Netherlands: State Monopoly Transition

The Netherlands has maintained a state monopoly for land-based casinos while liberalizing online:

• Holland Casino: State-owned operator with 14 venues across the country
• Partial privatization: Discussions about Holland Casino privatization have recurred but not been implemented
• Cruks integration: All casino entries checked against the national self-exclusion register
• KSA oversight: Kansspelautoriteit regulates alongside online gambling

Land-Based vs Online Casino Regulation Comparison

For more on how rules differ between casino types, see our article on Online Casino vs Sports Betting: How Rules Differ Across the EU.

Emerging Trends and Future Developments

Integrated Resort Development

Several EU member states have explored or implemented integrated resort-style casino development:

• Cyprus: City of Dreams Mediterranean represents the EU's largest integrated resort casino project
• Greece: Hellinikon project near Athens includes casino resort components
• Spain: Various integrated resort proposals have been discussed, including the controversial EuroVegas project (abandoned)

Smoking Restrictions

Indoor smoking bans have significantly impacted casino operations across Europe. Most EU countries now prohibit or restrict smoking in casinos, leading some operators to develop outdoor gaming areas or accept revenue impacts.

Digitalization of Land-Based Gaming

Land-based casinos are increasingly incorporating digital elements:

• Electronic table games and automated roulette
• Digital player tracking and loyalty systems
• Cashless gaming solutions
• Integration with online accounts (where permitted)

Post-Pandemic Recovery

COVID-19 closures significantly impacted land-based casino revenue across Europe. Recovery has been uneven, with some markets returning to pre-pandemic levels while others continue to see reduced visitation as gambling activity shifted online.

Related Resources

• Live Casino Regulation in the EU - How streaming technology bridges online and land-based gaming
• Online Casino vs Sports Betting: How Rules Differ - Product-specific regulatory comparison
• State Gambling Monopolies in the EU - Nordic models and market access
• EU Gambling License Cost Estimator - Interactive licensing cost comparison
• EU Gambling Compliance Risk Assessor - Evaluate regulatory complexity by market