Gambling on Credit Is Over in Ireland: Cards, E-Wallets and Buy-Now-Pay-Later

Gamblers who rely on credit will face a radical change in Ireland as of the new 2024 regulations. Section 165 (1) of the Gambling Regulation Act, 2024 bars licensed operators from taking payments by credit card or extending a credit facility. What’s more, the ban reaches electronic or digital payments that use money loaded from a credit card.

The Statutory Ban

Section 165 (1) states:

Licenses must not take payments by credit card, knowingly facilitate, or participate in giving credit in connection with gambling.

The Act explicitly includes payment by electronic or digital means which uses money loaded from a credit card. The Act establishes the new Gambling Regulatory Authority to enforce these and related rules and to license operators.

What the Law Clearly Catches

Licenses that accept credit cards, alone or nested in digital payment tools, are clearly caught.

Funds you deposit to play directly from a credit card are prohibited gambling credit.

Money you load to a digital payment instrument or online wallet from a credit card, then pull out again to play, is also prohibited gambling credit.

Even direct payment by credit card,, is prohibited for gambling in Ireland under the 2024 Act.

What Remains Unclear at the Edges

As the 2024 Act takes effect, some gray areas remain at the edges of cash and credit.

Charging is credit. Charge cards, though originally formulated as to avoid exceeding credit, are financings owed by the consumer. If they are treated the same as credit cards, they will be cut by the credit ban. However, the Act does not specify this categorically.

Credit card funding of e-wallets is credit, even if a cash transfer to a bank account happens in between. E-wallet funding from a credit card is prohibited under the Act. Yet, e-wallets funded by banking, payday, or peer-to-peer credit are not as plain a case for treatment as credit, because they do not fit so obviously within the definition of the Act's clear cut credit payments.

An overdraft is a loan contract. The consumer borrows money from the bank and agrees to pay it back. It is a credit extension, but the statute does not specify whether an overdraft counts as gambling credit, or only when the provider knowingly facilitates the funding of gambling.

Buy-Now-Pay-Later financing allows a purchase to be made now in exchange for an obligation to pay later. The Act does not clearly state if BNPL balances from online retailers that accept them as payment are prohibited.

Operator Duties and Compliance

With penalties that can reach €20,000 or 10% of the licensee's turnover, any hint of credit funding is trouble. Financial penalties for breaching the licensee's duty on gambling credit can reach €20,000.

A licensee can be fined up to €20,000 or 10% of turnover, whichever is greater. A medium one may find itself paying in the second bracket, or chucking a large chunk of turnover to Irish authorities in the first.

Licensees will not be able to detect credit by e-wallet or BNPL funding, however, without compliance tools or access to the funds involved. If a link between BNPL funding and a gambling account doesn't jump out, enforcement will not find it.

Consumer-Side Consequences

The Act establishes consequences for gambling on credit in Ireland.

The 2024 Act transitions Ireland's gambling regime. It establishes the Gambling Regulatory Authority under a ban on direct credit and related funding for gambling.

For Licenced operators, a mandate to close accounts when requested in writing by an account holder, or after 13 months of inactivity, is yet another regime-tightening rule introduced in the Act.

For consumers, a major change is the Act's tightening of accounts and limits, alongside account closures, if funds are held by the operator for 13 months of inactivity. Consumers hit with a suspicious-pattern limit are entitled to have winnings paid out, as long as the limit is unrelated to the duration of play or amount wagered.

The new law is a target on credit gambling in Ireland. When gambling funds are remitted from a credit or even a charge card, or if a credit card is used to load an e-wallet, the funds and the payment route overstep the new boundaries. Even e-wallets and credit-linked debit cards fed from credit or banking credit sources are caught by the statute.

In the long run, the new 2024 framework in Ireland will see the operator's duty of care reach more gambling credit refunds from e-wallets or BNPL. The line in section 165 (2) remains the yardstick, and with it, an embedded question of consumer responsibility for identifying when a payment is credit in nature.