EU Accessibility Act and AI Act: two new structural challenges for the European gambling industry
Operating in the online gambling sector has always meant working within a particularly strict regulatory framework. Over the past year, however, the European regulatory landscape has taken a further leap in complexity. The entry into force of three new European Union legislative acts – the EU Accessibility Act, the Digital Operational Resilience Act (DORA) and the AI Act – has opened an unprecedented phase for iGaming, forcing operators to reassess their technological, organisational and compliance models.
While DORA primarily targets the financial sector, with possible indirect effects on gaming platforms, it is above all the combined impact of the Accessibility Act and the AI Act that represents a concrete and immediate challenge for software developers, licence holders and digital service providers. Accessibility, security and artificial intelligence are no longer separate domains, but interconnected components within the same digital infrastructure.
An increasingly layered regulatory environment
The critical issue is not merely adapting to new rules, but managing their coexistence. Interface accessibility, the responsible use of artificial intelligence, personal data protection and operational continuity must now be addressed simultaneously. For many companies in the sector, already committed to complying with national gambling regulations and anti-money laundering requirements, this means revisiting the entire lifecycle of their digital products.
These are far from marginal adjustments. The new rules directly affect platform design, software architectures, data flows and the way users interact with gambling services. It is a structural shift that not all operators are fully prepared to face. According to industry analyses, including those by Mike De Graaff, Chief Compliance Officer at BetComply, published in SBC Leaders, the overlap between the EU Accessibility Act, DORA and the AI Act represents a tangible operational challenge for iGaming companies.
EU Accessibility Act: when gambling meets digital accessibility
The EU Accessibility Act was introduced with the aim of ensuring that digital products and services are accessible to people with disabilities, promoting inclusion and a fairer single market. Although the legislation does not explicitly mention gambling services, many online gambling platforms display characteristics that align them with digital and e-commerce services.
This aspect is particularly relevant in the Italian context, where the sector is preparing for the transition to a new online gambling licensing regime. The adoption of new platforms or the introduction of significant technical and contractual changes could lead a service to be classified as “new”, triggering the immediate application of accessibility obligations from the date of launch, without benefiting from the transitional regime in place until 2030 for existing services.
The Accessibility Act requires digital service providers to ensure compliance with specific technical requirements, which in practice translate into interfaces designed according to internationally recognised accessibility standards, clear information on compliance status and corrective mechanisms in cases of non-compliance.
In the gambling sector, implementing these obligations calls for a detailed, case-by-case assessment. Gaming platforms are often built on complex architectures, combining in-house developments with third-party components. Ancillary services such as live chat, messaging systems or customer support tools may also fall within the scope of the legislation, depending on their level of technical integration and the degree of control exercised by the operator.
For this reason, a growing view within the industry is that simple, piecemeal adjustments are no longer sufficient. An increasing number of companies are considering comprehensive platform overhauls, redesigning systems in a single phase to natively integrate accessibility requirements rather than relying on stop-gap solutions.
AI Act: a risk that is not only technological, but interpretative
If the Accessibility Act requires a rethink of how platforms are designed, the AI Act reshapes how artificial intelligence is used. The European regulation on AI introduces a risk-based approach, with obligations increasing in proportion to the potential impact of systems on fundamental rights, safety and public health.
In online gambling, artificial intelligence is already widely deployed. Behavioural analysis systems, fraud prevention tools, predictive models to identify problematic gambling and algorithms that personalise the user experience have become integral to digital offerings. It is precisely these applications, however, that may fall within the most sensitive categories identified by the regulation.
The main challenge is not purely technical, but legal. The AI Act is a complex piece of legislation, leaving significant room for interpretation. Many AI applications typical of the gambling sector may be subject to stringent requirements, particularly where they influence decisions with material effects on users. In such cases, the regulation imposes strict obligations in terms of data governance, transparency, documentation, continuous monitoring and risk management.
Personal data, transparency and algorithmic bias
A further layer of complexity arises from the processing of personal data. Artificial intelligence systems in online gambling operate on vast volumes of information, often of a sensitive nature, and must therefore be fully compliant with the General Data Protection Regulation and the relevant national implementing framework.
Operators are required to ensure that the use of AI is transparent, secure and understandable for users. In certain cases, this may involve obtaining explicit consent or providing detailed information on how algorithms process and use personal data.
Particular attention must also be paid to the risk of algorithmic bias. Uncorrected biases can lead to unfair or discriminatory outcomes, with consequences that extend beyond reputational damage to include regulatory exposure. The AI Act allows for the processing of sensitive data to identify and mitigate such risks, provided that appropriate safeguards are in place.
An unavoidable challenge for the entire sector
The picture that emerges is clear: the online gambling industry has entered a new phase, in which technological innovation must advance in parallel with increasingly sophisticated compliance. Accessibility and artificial intelligence are no longer optional topics or confined to experimental projects, but central elements of corporate strategy.
The question is not whether to comply, but how to do so without wasting time and capital or disrupting internal organisational structures. The market for specialised consultancy services is already gaining momentum, but ultimate responsibility remains with operators, who are required to make informed and timely decisions.
In this scenario, companies that are able to approach the EU Accessibility Act and the AI Act not merely as regulatory obligations, but as opportunities to enhance service quality and strengthen user trust, will be best positioned to turn regulatory complexity into a lasting competitive advantage.
This article was first published in Italian on 12 December 2025.
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