ADM to betting operators: ‘Odds errors and software bugs - here are the procedures’
Italy’s Customs and Monopolies Agency (ADM) has issued a new circular to betting licence holders clarifying how odds errors and gaming software malfunctions must be handled. The document follows what the authority describes as a growing number of requests to void bets, frequently justified by alleged anomalies in the odds offered or by technical issues affecting betting systems.
The regulator’s initiative aims to standardise operators’ conduct, strengthen player protection and ensure the proper application of contractual obligations. The operational guidelines apply to both remote gambling and the retail betting network, and also set out procedures for handling disputes, in full compliance with existing legislation and concession agreements.
Core principle: timely payments and direct liability
In outlining the general framework, ADM stresses that licence holders remain directly responsible for the accurate and timely payment of winnings and any refunds owed to players. The Agency retains its supervisory role and may impose contractual penalties where delays or failures in payment are identified.
The procedures introduced are intended as both preventive and cooperative measures. Their purpose is to provide operators with a clear framework for responding to disputes relating to incorrect odds or technical anomalies, thereby reducing the risk of non-compliant conduct. Given the structural differences between online operations and land-based betting shops, the circular sets out distinct operational instructions depending on the sales channel.
Managing odds errors in online betting
For remote gambling, the circular states that when a suspected odds error arises, the operator must follow the rules established by the Director’s Determination of 21 March 2024, which defines the criteria for recognising such anomalies. Operators are required to submit a formal request to ADM seeking verification of the error. Only if the Agency confirms the anomaly may the winnings be recalculated and the correct amount credited to the player’s account. If the error is not certified, the operator must pay the full amount calculated on the basis of the originally accepted odds, without resorting to refunds outside the cases permitted by the applicable regulations.
While operators retain the right to initiate legal proceedings, this does not alter their obligation to credit the player with the winnings. To prevent funds from being withdrawn during ongoing litigation, the operator may temporarily restrict their availability or suspend the gaming account, provided that ADM is formally notified and the relevant betting receipts are identified. At the same time, the operator must pursue legal action to seek cancellation of the participation receipts or formal recognition of the odds error. Account suspension may not exceed 180 days unless the Agency authorises an extension pending resolution of the dispute. Once proceedings have concluded, the operator must forward the judicial decision to ADM so that the player’s balance and any applicable single betting tax can be properly adjusted.
Rules for bets placed in retail outlets
A similar framework applies to bets placed through the land-based retail network. Where an operator submits a request for recognition of an odds error, payment of winnings takes place only after the Agency has completed its verification process. If ADM confirms the error, the amount is recalculated and paid accordingly. If not, the winnings must be paid based on the original odds, with no refunds outside those permitted by law.
Where betting slips have already reached payable status, an operator wishing to protect itself against the risk of being unable to recover funds must suspend the payment and promptly notify ADM, specifying the receipts involved and requesting suspension of the limitation period. In parallel, legal proceedings must be initiated to seek either cancellation of the bet or recognition of the error. Upon receiving proof that court proceedings have been filed, the Agency may suspend the time limits for payment of the winnings. Once the case has been resolved, the operator must notify ADM of the outcome so that the administrative and fiscal position can be regularised.
Software bugs and technical malfunctions: required verification steps
A particularly significant section of the circular addresses gaming software malfunctions, an increasingly critical issue in a market shaped by complex digital platforms. ADM refers to the existing certification guidelines, which state that an irreversible hardware or software malfunction must result in the suspension of betting operations, cancellation of the affected sessions and payments, and full reimbursement of the stakes involved, subject to specific exceptions for certain game types. The cost of such reimbursement remains the responsibility of the operator.
Before cancelling sessions, the operator must demonstrate the actual existence of an unforeseeable bug through a detailed technical report specifying the affected players, the sessions concerned and the actions performed. ADM reviews the documentation, including through technical audits and with the support of its technology partner Sogei. Only where authorisation is granted may the operator proceed with cancelling bets and payments. Otherwise, withdrawals must be allowed, or the operator must pursue judicial remedies.
During the verification phase or any subsequent litigation, the funds remain in players’ accounts. The operator may restrict their use or suspend the account, again subject to formal notification to the Agency. In this case, too, suspension may not exceed 180 days unless extended with ADM approval.
A compliance signal for the Italian betting market
The circular represents a significant regulatory intervention for the Italian betting market. Through these measures, ADM seeks to enhance procedural consistency, reduce disputes and ensure greater uniformity in how operators manage operational anomalies. As digitalisation accelerates and betting platforms grow more complex, the correct handling of odds errors and software bugs is becoming central to maintaining market stability and preserving player trust.
This article was first published in Italian on 17 February 2026.
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