Gambling and decentralisation: Will Europe follow the U.S. model?

The gambling industry is one of the most dynamic and economically significant sectors in the world, generating billions of dollars in revenue and creating new opportunities for the development of local economies. However, approaches to gambling regulation differ significantly between regions. While Europe adheres to a strict, centralised policy, the United States employs a unique decentralised model, where each state independently determines the rules of the game.

European gambling legislation is characterised by a high level of centralisation, with key regulatory norms set at the national or supranational level. In most EU countries—such as Germany, France, or Italy—national regulators like the UK Gambling Commission or Italy’s Agenzia delle Dogane e dei Monopoli (AAMS) establish clear licensing requirements, tax rates, and responsible gambling rules.

In the UK, for example, operators are required to adhere to strict player protection standards, and gambling taxes are paid to the central budget. This centralised model has both advantages and disadvantages. In particular, it often fails to account for regional specificities, which can hinder the development of local economies or cause discontent among communities due to imposed, one-size-fits-all rules.

In contrast, the United States uses a decentralised model of gambling regulation. At the federal level, only general principles apply—such as the Unlawful Internet Gambling Enforcement Act (UIGEA) of 2006, which prohibits illegal online betting but leaves states free to determine their own regulatory policies. This model allows states to adapt rules to local economic, social, and cultural conditions, promoting economic growth, flexibility, and innovation. However, it also results in uneven standards, which can lead to inconsistencies in player protection.

Recently, Europe has shown signs of interest in the American model of decentralisation. For example, Romania is preparing a bill that could radically change the gambling regulatory field. According to it:

• local authorities (municipalities) will be empowered to decide whether to allow or prohibit casinos in their cities;

• cities will independently determine locations for gambling facilities and set tax rates;

• all tax revenues from gambling will remain in local budgets, which will stimulate economic development of the regions.

  
  

This approach resembles the American model, where states such as New Jersey and Nevada have regulatory autonomy. Understandably, other European countries will closely monitor Romania’s experience and, based on its outcomes, decide whether to follow this example or remain committed to a centralised approach.

Will Ukraine follow the path of decentralisation? The issue is indeed relevant, but any transition to a decentralised model is likely to be considered only in the post-war period. This is primarily because Russian aggression and ongoing hybrid threats—such as cyberattacks—necessitate centralised control for rapid response, which is feasible only within a centralised regulatory framework.

Moreover, centralised regulation ensures consistent revenue for the state budget. While decentralisation may offer long-term benefits for Ukraine, in the short term, a centralised model remains the only viable option.