Edited by Joseph Malvisini

We return to the topic of top-up points of sale to illustrate how the operation of PVRs is a topic of continuing interest due to its breadth and number, yet at the same time highly controversial due to differing positions on the legality of the phenomenon.

In this regard, a recent ruling by the Court of Auditors is interesting. In its report on the State General Budget for 2021, the Supreme Court expressed keen interest in the gaming sector, obviously in light of the lost revenue resulting from the closures caused by the Covid pandemic.

Quoting a passage from the Agimeg agency which directly quotes the report, “In 2021, gaming revenues, after a sharp decline in 2020 due to regulatory restrictions imposed to address the pandemic emergency, showed a significant recovery, reaching values ​​slightly higher than those seen in 2019. Total gross collections amounted to €110,9 billion, an increase of €22,5 billion compared to 2020, returning to 2019 levels; winnings amounted to €95,5 billion (an increase of approximately €20 billion compared to 2020 and €4,5 billion compared to 2019). The sector's tax return, measured in relation to gross collections in 2021, amounted to 7,6 percent.".

The note, beyond discussing economic data with the resulting decline in tax revenue and the shift of gaming activity from the retail channel (due to the closure and inactivity of points of sale) to the online channel, with a consequent increase in digital gaming activity (although this channel has a lower tax revenue margin), focuses on control activities.

We are interested in the reports received from the regional offices of the Customs and Monopolies Agency of suspected intermediation and illegal collection of gambling carried out through top-up points of sale.

Resuming what Agimeg reported regarding the content of the report according to the Court of Auditors "These PVRs represent a real critical issue in the public gaming system; inspections conducted over the years have revealed that a significant percentage of them, in addition to the marketing activities inherent to these establishments, also engage in the unauthorized collection of bets and payment of winnings. Finally, given the unique context of the pandemic emergency, especially during the months that witnessed the unique situation resulting from the closure of physical gaming, careful and constant monitoring was carried out, analyzing the economic and quantitative trends of online gaming. The findings were also compared both through bilateral meetings with representatives of equivalent national authorities and through the active working group of regulators from major European countries."

In light of the Supreme Court's findings above, I would like to share some thoughts.

Among the pandemic's effects, certainly most notable in the closure of retail outlets, is the economic impact on individual operators, forced into prolonged closures, more so than any other sector. This is the result of a political and cultural bias that still refuses to recognize legal gaming as a major contributor to tax revenue, as well as an industry in which tens of thousands of workers are employed, repeatedly forced to demonstrate, precisely during the pandemic, their simple right to "want to work."

Secondly, regarding the system of controls implemented, we are pleased with the measures aimed at sanctioning illegal activities (the unauthorized exercise of gambling collection activities, which, it should be noted, is a criminal offense), as well as the recent communication from the Customs and Monopolies Agency, which urged gaming concessionaires to carry out verification and control tasks, defining the definition of top-up activities and reaffirming the prohibition of intermediation. However, the main issue remains on the table: the reorganization of new regulations for the gaming sector, which is increasingly slow in coming, along with the implementation of existing regulatory provisions, such as the current wording of the anti-money laundering legislation, which has yet to see the creation of the Single Register of Gaming Operators, a register in which all operators in the sector must be registered, including any top-up points of sale and other stakeholders in the supply chain. This delay is no longer justifiable and is a crucial step towards defining a definitive line of separation from that world of "illegality" so often cited in the reports we enjoy reading, but which we are not always determined to eradicate with definitive interventions.