Ireland’s Gambling Regulatory Authority (GRAI) opened for B2C remote betting licence applications in February 2026 — the first operational phase under the Gambling Regulation Act 2024. If you’re targeting Irish players, whether through a remote sportsbook, a betting shop, a gaming platform, or a lottery, a GRAI licence is a legal requirement. There’s no workaround.
The new regime is more demanding than the Revenue Commissioners system it replaces. Applications move through defined phases, each with its own eligibility window, fee bracket, and compliance threshold. From first filing to licence grant: realistically six to twelve months. First-year budgets for new entrants typically land between €150,000 and €310,000, once fees, advisory costs, and ongoing obligations are factored in.
This guide covers every decision point that matters: which licence category fits your model, how the phased rollout affects your launch window, what a complete filing pack must contain, how costs compare to other EU regimes, and what to look for — and avoid — when choosing an advisory firm to handle your GRAI submission.
Who needs a GRAI licence and which category fits your business model
Betting, gambling, and lottery operators in Ireland must identify which GRAI licence category applies to their business. The relevant licence type and application window both depend on the operating model — B2C, B2B, or charitable operator.
The Gambling Regulation Act 2024 does not ask whether a licence is required — it asks two other questions: which specific activity is being licensed, and whether the corresponding application window is already open. A remote bookmaker and a gaming machine supplier serving land-based venues are both within scope — but at different phases of the phased rollout.
| Business type | Licence family | Rollout phase | Typical example |
| B2C remote betting | Remote Betting Licence | Open (applications from February 2026) | Online bookmaker serving Irish players |
| B2C in-person betting | In-Person Betting Licence | Open (from December 2026) | Street-level betting shop |
| B2C gaming / casino | Gaming Licence | 2027–2028 | Online casino, gaming hall |
| B2B supplier | B2B Licence | 2027–2028 | Platform, RGS, affiliate technology |
| Charitable / philanthropic lottery | Exemption or Lottery Permit | Separate track | Local charity draw |
B2B companies — software suppliers, payment processors, platforms — are not included in the first licensing phases. If your revenue depends on Irish B2C operators but you supply services rather than serve players directly, you can continue operating under existing arrangements: GRAI is building the B2B framework in 2027–2028.
GRAI licence rollout phases: planned dates, real-world delays and what they mean for your business
Timelines depend on licence category and launch phase. The key distinction is between the date an application window opens and the date a licence can realistically be granted.
B2C remote betting applications opened on 9 February 2026; licences are issued from 1 July 2026. In-person betting licences follow from 1 December 2026. Remote gaming, lotteries, and B2B categories are scheduled for 2027–2028. This means a casino operator or B2B software supplier cannot apply now — regardless of how prepared they are.
After submission, allow 6–12 months for review. That is not a guaranteed timeframe — it reflects the realistic throughput of a newly established regulator processing both transition applications from existing operators and new-entrant filings simultaneously. Common causes of delay: incomplete beneficial ownership documentation, AML/KYC policies below GRAI standard, and additional clarification rounds.
What to do before your category opens:
- Register an Irish legal entity and build the corporate structure
- Prepare AML/CTF, responsible gambling, and data protection policies to GRAI standard
- Identify beneficial owners holding above 25% and gather supporting documents
- Engage a certified system supplier and begin technical testing
- Monitor the GRAI portal and commencement orders for your licence category
If remote gaming licence issuance slips further into 2028, operators planning an Irish market entry should structure investment rounds and software contracts with contingency — assuming the Irish licence will not arrive before late 2028 and that another EU jurisdiction will provide coverage in the interim.
How the GRAI application process works from notice of intention to portal submission
The process runs in four steps: document preparation, notice publication, portal submission, and regulator review.
Step 1 — Pre-submission preparation. Before any public action, assemble corporate documentation, AML/KYC policies, a responsible gambling framework, and a business plan (GRAI provides separate templates for medium/large operators and sole traders). Technical materials are also required at this stage: architecture diagrams, RNG certification, security policies, and penetration test reports. GDPR and data-retention documentation must be ready before submission.
Step 2 — Notice of Intention publication. Remote operators publish a notice in a national newspaper; in-person operators publish in both a national and a local paper. Publication must appear at least 28 days before the portal submission date. GRAI provides ready-to-use notice templates — use them.
Step 3 — Portal submission. Register on the GRAI Operator Portal, upload documents, complete the application form, and pay the applicable fee. The portal is the only submission channel. An incomplete document pack is the most common cause of delay.
Step 4 — GRAI review. The regulator assesses beneficial owners (25% threshold), responsible officers, financial standing, and policy completeness. Incomplete ownership chains and vague responsible gambling measures consistently extend review timelines.
Documents and controls GRAI expects in a complete filing pack
A credible filing pack covers ownership and control information, officer details, financial evidence, corporate records, and the core AML, KYC, and responsible-gambling policies. Each document needs to show GRAI that the business can actually operate safely — not just that policies exist on paper.
Organise the bundle so every item answers a specific question: who controls the business, is the entity financially sound, does the operational framework hold up under scrutiny.
Ownership and control
- Corporate structure chart showing all entities and beneficial owners above the 25% threshold
- Certified register of relevant officers with CVs, identity documents, and fit-and-proper declarations
- Disclosure of any licences held (or refused) in Ireland or other jurisdictions
Financial and corporate records
- Audited accounts for the last two to three financial years
- Evidence of financial capacity to meet player funds ring-fencing requirements
- Certificate of incorporation and constitutional documents
Operational policies
- AML and KYC policy, including CDD procedures and the €10,000 transaction trigger
- Responsible-gambling framework covering deposit limits, self-exclusion, and spending limit refund processes
- GDPR and data-breach response procedure aligned with the 72-hour notification rule
- Advertising compliance policy, especially the 5:30 am–9:00 pm broadcast restriction
Write each policy against GRAI-specific standards. Recycling documents from another jurisdiction is a common mistake — the regulator reads submissions against the Gambling Regulation Act 2024, not generic best practice.
Irish gaming licence cost: fees, taxes and a realistic total budget
The cost is a mix of regulatory fees, taxes where applicable, and professional and technical budget items, so the real budget depends on licence type, scale, and how much external support the operator needs.
Application fees are tiered by Irish-customer gross win from the preceding year (or estimated first-year GGR for new entrants), starting at €20,000 and rising through brackets up to €400,000 for the largest operators. That single line item is only the entry point.
A realistic Year 1 total for a new remote betting entrant runs from €150,000 to €310,000, covering the application fee, Irish entity formation, local legal counsel, AML/KYC framework build, technical certification, and initial compliance staffing. Years 2 and 3 carry lower one-off costs but add ongoing GRAI charges, Social Impact Fund contributions, and the licence’s annual compliance burden.
On the tax side, confirmed figures apply immediately: 2% betting duty on every stake, 23% VAT on gaming, and 12.5% corporate tax (rising to a 15% minimum under Pillar Two for groups above €750 million global revenue). These interact — duty on stakes, not margin, hits high-volume low-margin books hardest.
Budget for contingency. GRAI can request additional information during review, triggering extra legal hours. Remediation of a compliance gap found post-licence can cost significantly more than getting the framework right before filing. Factor at least 15–20% headroom above your baseline estimate, and treat the maximum penalty exposure — up to €20 million or 10% of annual turnover — as a risk-quantification input when sizing your compliance investment.
Strategic licence portfolio decisions: Irish GRAI vs other EU regimes and group structuring
The right choice depends on target market, tax profile, regulatory burden, and group structure. A GRAI licence is mandatory for direct access to the Irish market, but it should be evaluated alongside Malta, UK, and other EU options before a decision is made.
When Ireland is the right primary choice. A GRAI licence is required if your players are in Ireland after 1 July 2026. It also resolves a practical banking problem: major EU acquirers and payment providers that decline offshore operators work with GRAI-licensed entities. A 12.5% corporate tax rate, more than 70 double-taxation treaties, and a common-law English-language environment make Ireland a viable EU hub for mid-size operators — not just a single-market pass.
Ireland alongside another EU licence. A GRAI licence carries no EU passport — it covers Irish players only. Operators targeting a broader European market typically hold a Malta MGA licence for EU coverage and GRAI for the Irish market. The trade-off is clear: Ireland requires more resources at application stage and carries a higher ongoing regulatory burden than Malta or Gibraltar, but delivers better banking access and a stronger reputation than offshore options.
Group structuring. Most operators entering Ireland through a group structure place the Irish operating entity under an EU or Irish holding company, separate from entities holding other jurisdictional licences. GRAI scrutinises complex group structures: all beneficial owners above 25% must be fully disclosed, and intercompany agreements must be documented before submission. Shared-services arrangements between the Irish operating entity and affiliated structures require clear contractual boundaries — GRAI expects this as part of the group AML policy.
Board-level questions before deciding:
- Is Ireland a standalone market opportunity or part of an EU hub strategy?
- Does your current banking infrastructure require an EU-regulated licence?
- Can your compliance function support a separate AML framework meeting GRAI standards?
- Have you modelled the impact of 2% betting duty on margin before approving the business case?
Transition from legacy Revenue gaming licences to the GRAI regime
Existing Revenue licence holders need to watch three things at once: when their current licence expires, when GRAI opens their category, and whether they’ve documented enough to show good faith if anyone asks.
The deadlines are concrete. Remote betting licences under the old Betting Acts expire 30 June 2026 — the same date GRAI starts issuing remote betting licences. In-person Revenue licences run to 30 November 2026, lining up with the December 2026 GRAI in-person window. Gaming and lottery categories move across 2027 and 2028. Until your category opens, GRAI’s guidance is unambiguous: keep renewing with Revenue and go to Revenue for any new applications.
Good-faith compliance during the overlap means:
- Renew your current Revenue licence before it lapses — don’t let it expire while you wait for GRAI
- File your Notice of Intention at least 28 days before your intended GRAI application date
- Keep a paper trail: renewal receipts, correspondence with both authorities, a written record of your intention to migrate
- Watch GRAI’s phasing announcements — gaming and lottery timelines aren’t fixed yet
Enforcement risk is real, but targeted. GRAI is far more likely to go after operators who let licences lapse without renewal or communication than those who document every step.
How to pick an advisory firm for GRAI filings without overpaying or under-specifying support
Choose a firm with genuine GRAI experience — not general Irish corporate practice, but gambling-specific regulatory work. They should be able to submit documents themselves, provide pricing in writing, and explain how they manage conflicts of interest.
Before paying anyone, work through this checklist:
- Irish regulatory track record. Has the firm worked with GRAI, the Revenue Commissioners, or the Department of Justice specifically on gambling matters — not just Irish corporate law in general?
- Portal submission capability. Do they file directly through the GRAI Operator Portal, or do they outsource that step? Who is actually responsible for the submission?
- Fee transparency. Require written estimates. A fixed price for document preparation, hourly rates for advisory work, and a retainer for ongoing compliance are each appropriate in the right context. When they are mixed without a defined scope, the invoice grows quietly.
- Conflict disclosure. If the firm advises multiple operators in the same niche, ask how they separate work and information. A written conflicts policy matters: market position is commercially sensitive information during a licence application.
- Scope fit. A one-off filing needs a project team. A full compliance build needs a retained partner with AML, responsible gambling, and HR policy expertise. Post-licence support needs agreed SLAs. Do not pay a retainer for one-off work.
- References. Ask for at least one completed GRAI submission or a comparable EU regulatory case — not just an advisory opinion.
Ongoing obligations for GRAI licence holders after approval
After approval, the work doesn’t stop — it shifts. The Gambling Regulation Act 2024 and GRAI’s Guidance on Relevant Obligations treat compliance as a continuous cycle, not a box ticked at application stage.
Key obligations that run throughout the licence term:
- AML controls need regular review. Transactions above €10,000 trigger enhanced due diligence and reporting.
- Safer gambling measures — deposit limits, self-exclusion, and the National Gambling Exclusion Register — must stay operational and auditable at all times.
- Material changes to ownership (any UBO holding above 25%), key personnel, or corporate structure must reach GRAI within 7 days.
- Licence renewal runs on a 3-year term. Treat preparation seriously — not as a formality.
- Advertising rules apply from day one of trading: the post-watershed restriction window and social media targeting requirements don’t kick in later.
The GRAI Operator Portal handles submissions, updates, and renewals. Keep portal access current, version-control compliance policies, and run internal audits quarterly. Operators who treat these as live disciplines rather than annual tasks are the ones who avoid enforcement action.
Where to track GRAI guidance, licensing notices and rollout updates
Reliable updates come from GRAI guidance documents, licensing notices, and official rollout announcements — these sources determine when application windows and requirements actually change.
For operators planning licence applications, the most actionable sources to monitor are:
- GRAI.ie guidance library — publishes Notice of Intention templates, Licensing Application Guidance, Legal and Corporate Assessment Guidance, Premises Assessment Guidance, and Pool Betting Guidance; requirements are formally set here, not interpreted elsewhere
- GRAI portal announcements — category opening dates and commencement orders appear here first; the move from B2C remote to in-person betting licences showed how quickly sequencing can shift
- Minister for Justice commencement orders — statutory instruments that bring provisions into force, separate from GRAI communications
- Revenue Commissioners updates — still relevant for operators holding legacy gaming licences during the transition window
- Specialist regulatory advisers such as MGL Solutions — publish fast-turnaround analysis when GRAI releases new guidance rounds; MGL Solutions advises operators at every stage of the GRAI process, from pre-application structure and policy drafting through portal submission and post-licence compliance, and can flag material changes to fee guidance, category sequencing, and compliance templates as they are issued
Check these sources before locking in internal submission timelines. Application fee guidance, category sequencing, and compliance templates have all been updated after initial announcements.