Mobile Gambling Regulation in the EU: App Store Policies, Technical Standards, and Compliance Requirements

The Rise of Mobile Gambling in Europe

Mobile devices have fundamentally transformed the European gambling landscape. According to European Gaming and Betting Association (EGBA) data, mobile gambling now accounts for the majority of online gambling activity across regulated EU markets, with some jurisdictions reporting mobile shares exceeding 75% of total online gross gaming revenue. This shift has prompted regulators throughout Europe to adapt their frameworks to address the unique challenges and opportunities presented by smartphone and tablet gambling.

The convenience of mobile gambling, enabling users to place bets or play casino games from virtually anywhere, has accelerated adoption while simultaneously raising regulatory concerns about increased accessibility, problem gambling risks, and the technical complexities of ensuring compliance across diverse mobile platforms. As detailed in the European Commission's gambling overview, member states retain primary authority over gambling regulation, including mobile gambling, leading to a patchwork of national approaches to mobile-specific requirements.

App Store Policies for Gambling Applications

Distribution of mobile gambling applications presents unique challenges due to the gatekeeping role of platform providers. Both Apple and Google maintain strict policies governing real-money gambling apps, requiring operators to demonstrate valid licensing before apps can be listed in their respective stores.

Apple App Store Requirements

Apple's App Store Review Guidelines contain specific provisions for gambling apps under section 5.3. According to Apple's developer documentation, gambling apps must:

• Be free to download from the App Store (in-app purchases for chips or credits are not permitted for real-money gambling)
• Restrict availability to jurisdictions where the operator holds valid gambling licenses
• Implement geolocation services to verify user location within licensed territories
• Complete Apple's gambling application process with license documentation for each country
• Display age rating of 17+ and implement age gate functionality
• Include responsible gambling information and links to support resources

Apple reviews gambling license documentation for each jurisdiction and uses its geo-restriction capabilities to limit app availability to licensed markets. This means a gambling operator licensed in Spain by DGOJ but not in France cannot have their app available to French App Store users, even if Spanish users traveling to France could theoretically use it (subject to the operator's terms and geolocation restrictions).

Google Play Store Requirements

Google's approach to gambling apps has evolved significantly. Originally more restrictive than Apple, Google Play's Real-Money Gambling policy now permits real-money gambling apps in numerous countries, including most regulated EU markets. Key requirements include:

• Completion of Google's gambling application form with license verification
• Distribution limited to jurisdictions where licenses are held and verified by Google
• Implementation of age verification before real-money transactions
• Responsible gambling features including deposit limits and self-exclusion options
• Clear terms of service disclosing gambling mechanics and odds where required
• No promotion of gambling to minors through advertising or content

Google maintains a list of approved jurisdictions for gambling app distribution and requires operators to submit licensing documentation for each market. The approval process typically takes several weeks and involves verification with the relevant gambling regulator.

Alternative Distribution Methods

Some operators distribute mobile gambling apps outside official app stores, particularly on Android where sideloading is more accessible. This approach allows operators to bypass app store restrictions but creates challenges for user trust and security. Major regulated operators typically prefer official app store distribution due to:

• Enhanced user trust and discovery through legitimate app stores
• Automatic updates and security patch distribution
• Compliance with platform security requirements
• Reduced friction for user installation

Regulators in some EU jurisdictions, including Germany and Italy, have expressed concerns about off-store gambling app distribution and encourage operators to use official channels where possible.

Technical Standards for Mobile Gambling

Mobile gambling applications must meet extensive technical requirements mandated by EU gambling regulators. These standards address unique mobile-specific considerations while incorporating broader responsible gambling operator requirements applicable to all online gambling channels.

Geolocation Verification

Geolocation is arguably the most critical technical requirement for mobile gambling apps in the EU. Operators must verify that users are physically located within jurisdictions where they hold valid licenses before allowing gambling activity. The German gambling authority (GGL) and Netherlands' Kansspelautoriteit (KSA) have been particularly active in mandating robust geolocation standards.

Technical geolocation requirements typically include:

• Multi-source verification: Combining GPS coordinates, Wi-Fi positioning, cellular tower triangulation, and IP address geolocation
• Accuracy thresholds: Location verification must meet specified accuracy levels (often within 100 meters of licensed territory boundaries)
• VPN and proxy detection: Systems must identify and block attempts to mask or spoof location
• Continuous monitoring: Location checks at login and periodically during gambling sessions (intervals vary by regulator)
• Boundary compliance: Automatic session termination if user crosses into unlicensed territory

The practical implementation of geolocation creates significant technical challenges, particularly in border regions. For example, an operator licensed in the Netherlands but not in Germany must prevent Dutch users near the German border from continuing to gamble if they cross into Germany during an active session.

KYC and Age Verification Integration

Mobile gambling apps must integrate with identity verification systems to comply with EU KYC and age verification requirements. Mobile-specific considerations include:

• Document scanning: Using device cameras for ID document capture and verification
• Biometric verification: Facial recognition comparison against ID photos
• Database verification: Integration with national ID verification databases where available
• Device binding: Associating verified accounts with specific devices for enhanced security

Mobile KYC processes must balance regulatory requirements with user experience. Many operators implement tiered verification allowing limited play before full verification, though deposit and withdrawal limits apply until complete identity confirmation. The AML compliance framework requires ongoing monitoring regardless of the verification method used.

Self-Exclusion Database Connectivity

Mobile gambling apps in regulated EU markets must connect to national self-exclusion databases to prevent excluded individuals from gambling. As documented in our self-exclusion systems overview, major systems include:

Technical implementation requires secure API connections to government-operated databases, with appropriate handling of system unavailability (most regulators require gambling to be suspended if database connectivity is lost).

Responsible Gambling Features

Mobile gambling apps must implement comprehensive responsible gambling features, often with mobile-specific considerations:

• Push notification limits: Restrictions on promotional push notifications to users showing problem gambling indicators
• Session time tracking: Displaying time spent gambling and mandatory session break reminders
• Reality checks: Pop-up notifications showing net win/loss at specified intervals
• Deposit limit enforcement: Cross-channel limits that apply to mobile and desktop activity combined
• Cool-off periods: Ability to immediately suspend gambling with minimum wait times
• Self-exclusion access: Easy access to self-exclusion registration within the app
• Support resources: Direct links to problem gambling helplines and support organizations

Germany's Interstate Treaty requires particularly strict responsible gambling features including mandatory five-second pauses between slot spins and monthly deposit limits across all licensed operators (tracked via OASIS). The Personal Gambling Limits Calculator demonstrates the type of limit-setting functionality expected in mobile applications.

Payment Processing and PSD2 Compliance

Mobile gambling payments in the EU must comply with the Second Payment Services Directive (PSD2), which mandates Strong Customer Authentication (SCA) for electronic payments. According to the European Banking Authority's PSD2 guidance, this affects mobile gambling through:

• Two-factor authentication: Deposits typically require SCA verification via banking apps or SMS
• Biometric authentication: Fingerprint or face recognition can satisfy SCA requirements
• Tokenization: Secure storage of payment credentials for repeat transactions
• Transaction monitoring: Real-time fraud detection and suspicious transaction blocking

Our analysis of payment blocking and AML issues covers the broader context of gambling payment challenges, which are particularly relevant for mobile transactions where users may encounter bank blocks on gambling deposits.

Country-by-Country Mobile Gambling Requirements

While mobile gambling regulation falls under general online gambling frameworks in most EU jurisdictions, several countries have implemented mobile-specific provisions or interpretations.

Germany

The German Interstate Treaty on Gambling (Glücksspielstaatsvertrag) applies equally to mobile and desktop gambling. The GGL (Gemeinsame Glücksspielbehörde der Länder) requires mobile operators to implement:

• OASIS self-exclusion database integration with login verification
• Monthly deposit limit of EUR 1,000 across all licensed operators (tracked cross-platform)
• Strict slot limitations including five-second spin delays and EUR 1 maximum stake
• Mandatory account verification before first deposit
• Geolocation to restrict play to German territory

Germany's relatively restrictive framework has led to significant channelization challenges, with the GGL actively pursuing unlicensed operators accessible via mobile browsers. See our Germany gambling regulation page for comprehensive details.

Netherlands

The Kansspelautoriteit (KSA) regulates mobile gambling under the Remote Gambling Act (Wet kansspelen op afstand). Mobile-specific requirements include:

• Cruks self-exclusion check before every gambling session
• Geolocation verification using multiple data sources
• Advertising restrictions affecting push notifications and in-app promotions
• Strict cool-off periods between promotional offers

The KSA has shown particular concern about mobile gambling accessibility and has implemented some of the EU's strictest advertising restrictions, as detailed in our advertising bans analysis.

Spain

Spain's DGOJ (Dirección General de Ordenación del Juego) regulates mobile gambling as part of online gambling licenses. Royal Decree 958/2020 introduced enhanced consumer protection measures applicable to mobile:

• Mandatory 30-day waiting period for welcome bonus claims
• Session duration limits and break requirements
• Prominent responsible gambling messaging within apps
• Advertising restrictions limiting promotional communications

Our Spain gambling regulation page covers the broader regulatory context including recent advertising and sponsorship restrictions.

Italy

Italy's ADM (Agenzia delle Dogane e dei Monopoli) oversees mobile gambling under online gambling licenses. Italian mobile requirements include:

• Registration with Agenzia delle Entrate for tax compliance
• Integration with national self-exclusion database
• Comprehensive advertising ban (Dignity Decree) affecting mobile promotions
• Payment processing through ADM-approved providers

Italy's 2026 licensing round introduced EUR 7 million license fees, among the highest in Europe. See our Italy gambling regulation page and License Cost Estimator for details.

France

France regulates mobile gambling through ANJ (Autorité Nationale des Jeux). Notably, online casino games remain prohibited in France (including on mobile), while sports betting, horse racing, and poker are licensed. Mobile-specific considerations include:

• App store distribution for licensed sports betting and poker only
• Self-exclusion registration via national database
• Geolocation verification for territorial compliance
• Pending legislation may expand mobile casino access (2026 proposals under consideration)

Our France gambling regulation page analyzes the current restrictions and potential liberalization timeline.

Mobile-Specific Regulatory Challenges

Cross-Border Gambling and Roaming

Mobile gambling creates unique challenges when users travel across EU borders. A German resident visiting Spain may have access to differently-licensed operators through location-based app store visibility. Key considerations include:

• License validity: Operators typically require local licenses for each jurisdiction; foreign-licensed operators may be accessible but operate in legal gray areas
• Geolocation switching: Users crossing borders may find their access changes based on physical location
• Account restrictions: Some operators restrict accounts to the country of registration regardless of current location
• Tax implications: Gambling in foreign jurisdictions may create tax complications, as explored in our Player Winnings Tax Calculator

The EU's free movement principles create tension with nationally-regulated gambling markets, an issue extensively covered in our cross-border gambling analysis.

In-App Purchase Mechanics

The relationship between gambling and in-app purchases remains contentious. While direct purchase of gambling credits is prohibited on iOS, the line between entertainment and gambling blurs with mechanics like:

• Social casino games: Free-to-play games with gambling mechanics but no cash prizes (covered in our social casino analysis)
• Loot boxes: Randomized reward systems that some jurisdictions classify as gambling (see our loot box regulation guide)
• Virtual currencies: In-game currencies that can be purchased but not withdrawn

Push Notifications and Advertising

Mobile devices enable direct promotional messaging through push notifications, raising regulatory concerns about gambling advertising reaching vulnerable individuals. Several EU jurisdictions have implemented restrictions:

• Netherlands: Strict limitations on untargeted gambling advertising, including push notifications
• Belgium: Complete gambling advertising ban (2023) affects mobile promotional messaging
• Italy: Dignity Decree prohibits gambling advertising, limiting push notification use
• Spain: Time-based restrictions on gambling advertising extend to mobile communications

Our affiliate marketing guide discusses the broader advertising landscape affecting mobile gambling promotion.

Security and Fraud Prevention

Mobile gambling platforms must implement robust security measures to protect users and prevent fraud. Key security requirements include:

Device Security

• Secure session management: Encrypted communication and automatic session timeout
• Device binding: Associating accounts with verified devices to prevent unauthorized access
• Jailbreak/root detection: Identifying compromised devices that may pose security risks
• Certificate pinning: Preventing man-in-the-middle attacks on mobile connections

Fraud Prevention

• Multi-accounting detection: Identifying users attempting to register multiple accounts
• Collusion detection: Monitoring for coordinated play in poker and multiplayer games
• Bonus abuse prevention: Systems to identify and prevent promotional exploitation
• Transaction monitoring: Real-time analysis for suspicious deposit and withdrawal patterns

These security measures complement GDPR data protection requirements that govern how operators collect, process, and store user data on mobile platforms.

Testing and Certification

Mobile gambling applications must undergo testing and certification before deployment in regulated EU markets. Testing typically covers:

• Random Number Generator (RNG): Verification that games produce fair, random outcomes on mobile platforms
• Return to Player (RTP): Confirmation that advertised payout percentages are accurate
• Geolocation accuracy: Testing of location verification systems across various scenarios
• Responsible gambling features: Verification that limits, self-exclusion, and reality checks function correctly
• Security assessment: Penetration testing and vulnerability assessment

Approved testing laboratories include organizations like eCOGRA, BMM Testlabs, GLI, and iTech Labs. Most EU regulators require testing by accredited laboratories before granting or renewing licenses.

Future Trends in Mobile Gambling Regulation

Several developments are likely to shape mobile gambling regulation in the coming years:

Enhanced Player Protection Technology

Artificial intelligence and machine learning are increasingly being deployed to identify problem gambling behaviors on mobile platforms. Regulators are expected to mandate algorithmic monitoring for early intervention, building on existing operator requirements.

5G and Emerging Technologies

The rollout of 5G networks enables richer mobile gambling experiences including enhanced live casino streaming. Regulators will need to address new formats enabled by improved mobile connectivity while maintaining player protection standards.

Digital Wallet Integration

Integration with digital wallets and cryptocurrency payment systems raises questions about cryptocurrency gambling compliance on mobile platforms, particularly regarding AML monitoring and withdrawal verification.

Regulatory Harmonization

While EU-wide gambling harmonization remains unlikely in the short term, organizations like the EGBA continue to advocate for common technical standards that would simplify cross-border mobile gambling compliance. The EU gambling laws overview explains why harmonization faces significant obstacles.

Conclusion

Mobile gambling regulation in the EU reflects the broader complexity of Europe's fragmented gambling regulatory landscape. While mobile distribution is enabled through platform-level policies from Apple and Google, compliance ultimately depends on meeting national regulatory requirements in each target market. Operators must navigate technical challenges including geolocation verification, self-exclusion database integration, and responsible gambling feature implementation while adapting to evolving requirements from regulators concerned about the accessibility of mobile gambling.

For users, the mobile gambling environment offers convenience but requires awareness of licensing status, responsible gambling tools, and the limitations that apply when crossing borders within the EU. As mobile continues to dominate online gambling activity, regulatory focus on mobile-specific issues is likely to intensify, with enhanced player protection measures and stricter technical standards on the horizon.

Last Updated: December 2025