Gambling and betting lawyers

The gambling and gaming sector in France is built on a principle of general prohibition with limited derogations, set by article L.320-1 of the French Internal Security Code. Everything is prohibited unless expressly authorised by law.

The specialised lawyer masters this derogatory framework: French Act no. 2010-476 of 12 May 2010 as amended, Ordinance no. 2019-1015 of 2 October 2019 reforming regulation, articles L.320-1 et seq. of the Internal Security Code, articles 302 bis ZG to 302 bis ZO of the General Tax Code, articles L.137-19 to L.137-25 of the Social Security Code, and EU secondary law.

The firm supports operators throughout the regulatory life cycle: market entry (ANJ authorisation), operation (software approval, annual certification, supervision, promotional strategy), incidents (controls, sanctions, withdrawal), exit. We also act for peripheral actors: sports federations, organisers, media, influence agencies, technology providers and Web3 platforms facing the JONUM regime.

The scope covers online sports betting (mutual and fixed odds), online horse racing betting (mutual only), online poker (cash game and tournaments), the FDJ lottery monopoly, promotional lotteries and prize draws governed by the French Consumer Code, esports, JONUM in the experimental phase, land-based casinos and gaming clubs (Ministry of the Interior competence), and ongoing watch on the online casino file, whose legalisation remains, as of May 2026, under study.

We advise authorised operators, applicants for authorisation, sports federations, fantasy platforms, Web3 game publishers facing the JONUM regime, and media subject to gambling advertising rules. We combine this expertise with a deep knowledge of how the ANJ operates and its doctrine.

We adapt our involvement to the project's maturity: regulatory opportunity study, initial authorisation filing, renewal, substantial modification, litigation, transfer or market exit.

Maître Alexandre Bigot-Joly handles criminal aspects (illegal gambling, money laundering, betting manipulation) and media. Maître Raphaël Molina handles business law, contractual and advertising aspects. Maître Maria Berrada handles GDPR, JONUM and Web3 aspects where game mechanics use digital assets.

We draft structuring contracts: right-to-bet contracts with federations and organisers, contracts with technical providers (game frontend, supervision, archiving), sponsorship contracts, advertising and affiliation contracts, contracts with influence agencies within the limits of the French Act of 9 June 2023, and authorisation transfer contracts under ANJ control.

Any commercial communication for an authorised operator must comply with French Decree no. 2020-1349 of 4 November 2020 and its implementing orders: prohibition of inciting excessive gambling, trivialising or promoting such practice, suggesting that gambling contributes to social success, presenting gambling as a solution to difficulties, or as an alternative to work.

The annual promotional strategy must be approved by the ANJ. Mandatory mentions are imperative.

The ANJ sanctions committee, provided for in article 41 of the Act of 12 May 2010, is composed of six members from the Conseil d'État, the Cour de cassation and the Cour des comptes, appointed for six years renewable once.

It may issue a warning, reduce the authorisation duration by up to one year, suspend it for up to three months, withdraw it, and impose financial sanctions of up to 5 % of net turnover (10 % for repeat breaches), under article 43 of the Act. Decisions may be published in the Journal officiel and challenged before the administrative courts (article 44).

The choice of operating structure (legal form, registered office, capital, shareholding) directly conditions the admissibility of the authorisation file. The operator must have its registered office in an EU/EEA State having signed an assistance agreement with France.

We advise on legal and tax structuring and on alignment with ANJ requirements regarding the integrity of directors and capital transparency.

Trademarks, domain names and copyright on interfaces and logos are essential in a sector where confusion with legal sites is regularly used by illegal sites. We secure filing strategies and defend rights holders against mirror sites identified by the ANJ.

French Act no. 2010-476 of 12 May 2010 liberalised three online activities under authorisation: online horse racing (mutual), online sports betting (mutual or fixed odds) and online poker.

Ordinance no. 2019-1015 of 2 October 2019 created the Autorité nationale des jeux (ANJ), in place since 23 June 2020, an independent administrative authority with strengthened powers covering the whole regulated gambling sector.

Article 21 of the Act of 12 May 2010 opens three categories to competition: online horse racing (mutual only), online sports betting (mutual or fixed odds), online poker (cash game and tournaments). A separate authorisation is granted per category. The authorisation lasts five years, renewable and non-transferable.

Online casino games (slot machines, roulette, blackjack, baccarat) remain strictly prohibited in France as of 2 May 2026. The applicant must have its registered office in an EU Member State or in another EEA State having signed with France a convention containing an administrative assistance clause.

After a control, the ANJ board informs the operator of the alleged breaches and invites observations within at least thirty days. The board may then notify charges and refer the matter to the sanctions committee. Under article 43 of the Act of 12 May 2010, the committee may issue a warning, reduce authorisation duration by up to one year, suspend it for up to three months, or withdraw it.

It may also impose a financial sanction up to 5 % of net turnover for the relevant authorised activity (10 % for repeat breaches). Without prior activity, the sanction may not exceed EUR 150,000, raised to EUR 375,000 for repeated breach of the same obligation.

Articles L.324-1 et seq. of the Internal Security Code punish illegal operation. Carrying out gambling operations in violation of article L.320-1 is punishable by three years' imprisonment and EUR 90,000 fine, raised to seven years and EUR 200,000 in organised gangs (article L.324-1 CSI).

Violation of FDJ monopoly bans (article L.322-12 CSI) is punishable by three years and EUR 200,000, raised to seven years and EUR 500,000 in organised gangs (article L.324-11 CSI). Advertising for an unauthorised gambling site is punishable by EUR 100,000, the court being able to raise this to four times the advertising spend devoted to the illegal activity (article 57 of the Act of 12 May 2010).

Article 61 of the Act of 12 May 2010, amended by the Act of 2 March 2022, gives the president of the ANJ the power to block illegal gambling sites and stop advertising for them, without prior court referral.

The procedure unfolds in stages: notice to the publisher to cease the activity (with a five-day deadline for observations), notice to the author of the unauthorised advertising, copy to hosts, then orders to ISPs and search engines to block access or stop indexing. Per ANJ figures, several hundred blocking orders and over a thousand URLs are concerned each year, mostly mirror sites.

Article L.333-1-1 of the French Sport Code, created by the Act of 12 May 2010, grants sports event organisers the right to consent to bets being organised on their events. Article L.333-1-2 requires that, when granted by a federation or organiser, this right be the subject of a contract with the authorised sports betting operator. The draft contract is sent to the ANJ for opinion.

No discrimination may be applied between authorised online operators or between them and the rights holder. Exercising this right entitles the beneficiary to remuneration taking into account in particular incurred costs.

Taxation rests mainly on Gross Gambling Revenue (GGR), the difference between amounts wagered and amounts paid to winners, under articles 302 bis ZG to 302 bis ZO of the General Tax Code. Rates applicable to online sports betting, horse racing and online poker are regularly amended by successive finance acts and were notably revised by Act no. 2025-127 of 14 February 2025.

A social contribution is also due under articles L.137-19 et seq. of the Social Security Code.

Lotteries within the meaning of the 1836 Act, codified in articles L.322-1 et seq. of the Internal Security Code, are in principle prohibited, subject to the FDJ monopoly and limited derogations. Promotional lotteries, codified in article L.121-20 of the Consumer Code since Ordinance no. 2016-301 of 14 March 2016, are lawful provided they are not unfair within the meaning of article L.121-1.

Act no. 2014-1545 of 20 December 2014 abolished the obligation to refund participation costs, the bulletin formalism, the mandatory bailiff deposit and the obligation to provide rules free of charge. Any breach of remaining provisions is punishable by an administrative fine of up to EUR 75,000 for legal persons.

Article 40 of French Act no. 2024-449 of 21 May 2024 (SREN) created a three-year experimental regime for monetisable digital object games (JONUM), under ANJ supervision.

Implementing decree no. 2026-60 of 4 February 2026 sets the precise conditions: six authorised game categories, exclusion of casino mechanics, capping of accessory rewards, prior declaration to the ANJ, identification of the compliance officer, ban on minors and AML-CFT obligations. Any advertising for an illegal JONUM offer falls under the penalties applicable to unauthorised gambling.

The firm specifically supports Web3 publishers on the qualification of their reward mechanics.

Online casino games (slot machines, roulette, blackjack, baccarat) remain strictly prohibited in France as of 2 May 2026. The government amendment tabled on 19 October 2024 in the 2025 finance bill was withdrawn on 27 October 2024 following opposition from land-based casinos and public health actors. A consultation opened in November 2024 was suspended after the fall of the Barnier government.

No legalisation act has been adopted to date. The ANJ continues to administratively block online casino sites under article 61 of the Act of 12 May 2010 and article L.320-1 of the Internal Security Code. The firm provides active and forward-looking monitoring of this file.

Article 4 of French Act no. 2023-451 of 9 June 2023 governing commercial influence, in force until 1 July 2026 in its current wording, allows commercial communications for gambling only on platforms offering the technical possibility to exclude under-18 users from the audience, with that mechanism actually activated.

Communications must include a clear mention indicating the content is prohibited to under-18s, in line with a reference framework drawn up by ARCOM after consultation of the ANJ and the CNIL. Any direct or indirect promotion of subscriptions to sports tips is however prohibited. Breaches fall under article L.132-2 of the Consumer Code (two years' imprisonment and EUR 300,000 fine).

The online gambling sector inherently processes sensitive data (KYC identity checks, gambling behaviour, financial data, excessive practice markers). A DPIA is mandatory under article 35 GDPR. We secure legal bases, retention periods, risk profiles and international transfers, and defend operators in CNIL controls.