ANJ Tightens Responsible Gambling Rules: What France’s New Operator Obligations Mean for Compliance Calendars

France’s online gambling regulator, the Autorité Nationale des Jeux (ANJ), has moved decisively in 2025 and into 2026 to convert its 2024, 2026 strategic plan into enforceable compliance obligations. The core message for licensed operators is unambiguous: reducing the proportion of excessive gamblers in your customer base is no longer an aspirational target but a directly supervised, sanctionable obligation. According to ANJ enforcement records, a €500,000 enforcement fine issued in July 2026, an algorithmic tool that has redrawn the scale of the problem, and a legislative pathway to mandatory youth loss limits together define a compliance environment that is materially more demanding than it was at the start of this regulatory cycle.

The Legal Architecture: What France Actually Requires

The statutory foundation for player protection in France is Article 34, IX, alinéa 3 of the Loi du 12 mai 2010 relative aux jeux d’argent et de hasard en ligne, as amended. The provision states that operators must identify persons whose gambling is excessive or pathological and accompany them to moderate their practice, in compliance with the reference framework (cadre de référence). The word “accompany” carries specific legal weight and is not satisfied by sending an automated warning email or removing a player from a promotion.

The binding reference framework is set by the Arrêté du 9 avril 2021, a ministerial order issued on the proposal of the ANJ. The arrêté defines the obligations in detail across two dimensions. The first is identification, using a multi-indicator scoring methodology applied to each player’s account data held in the secure coffre-fort (data vault). The second is accompaniment, a graduated set of interventions proportionate to the player’s assessed risk tier that escalates from targeted messaging to account restriction and, in the most serious cases, to suspension or closure. The ANJ’s sanctions commission confirmed in Decision 2026-031 that these two duties are distinct and independently enforceable. Failure on accompaniment is a separate sanctionable breach from failure on identification, even where an operator has partially identified a player.

What Does the ANJ’s Algorithm Change for Operators?

The ANJ deployed its problem-gambling detection algorithm in May 2025. The tool uses 23 indicators drawn from scientific literature and validated against the Canadian Problem Gambling Index (CPGI) under the supervision of a recognised scientific committee. The indicators cover four domains: financial transaction patterns (deposit frequency, loss levels, betting intensity), use of gambling moderation tools, frequency and intensity of play, and historical gambling behaviour.

Players are classified into four categories: recreational, moderate, excessive, and manifestly excessive. Applied to data from the second half of 2025, according to ANJ data, the algorithm identified approximately 600,000 players, representing 8.7% of all account-based players across licensed online operators, as probable problem gamblers. Of those, around 300,000 were classified as manifestly excessive, and the ANJ stated their identification by operators must be treated as imperative.

“The finalisation of the algorithm enables the objective identification of problem gamblers, an effort that operators must pursue without delay.”, Isabelle Falque-Pierrotin, President of the ANJ, May 2025

The compliance implication is direct. The algorithm functions as the ANJ’s evidentiary reference point, and the regulator has total visibility of operator data streams because licensed operators transmit account-level data continuously. Where an operator’s own detection system identifies significantly fewer at-risk players than the algorithm would predict across an equivalent population, that gap is a supervisory trigger. Operators cannot credibly argue that their detection methodology is adequate if it is systematically identifying a small fraction of the population that the ANJ’s own validated tool classifies as high-risk.

The €500,000 Enforcement Decision: What It Means in Practice

ANJ Decision 2026-031, published on 10 July 2026, is the clearest statement of what the regulator will now hold operators to. An investigation conducted between 1 October 2023 and 31 March 2024 examined account data held in an operator’s coffre-fort. The ANJ’s scoring methodology identified the 30 highest-risk player profiles. Of these, 29 were central to formal grievances. Six had been missed entirely by the operator’s detection system, 23 had been misclassified at a lower risk tier than the ANJ’s scoring indicated. Twenty-five players had not received sufficiently proportionate or graduated interventions to moderate their gambling.

The operator, referred to as Company X, raised several defences. It argued that French law provides no statutory definition of “excessive” or “pathological” gambling, rendering the obligations impermissibly vague. It disputed the counting of “completed bets” as an indicator and challenged the treatment of voluntary limits that players had set across multiple accounts, including reopened accounts. It also characterised automated warning emails and temporary fraud-related account suspensions as adequate graduated interventions. The sanctions commission rejected each of these arguments and imposed a €500,000 fine.

The commission also noted one specific operational failure that compliance teams should register: Company X had offered promotional bonuses to players who had already been identified as high-risk. The commission treated this as an aggravating factor. In France, offering a bonus to a player your system has flagged as at risk is not a marketing compliance failure in isolation. It is evidence of a breakdown in the accompaniment obligation.

The Mandatory Annual Action Plan Cycle

Every ANJ-licensed operator must submit two annual action plans to the regulator for review and approval. The responsible gambling action plan (plan d’actions en matière de prévention du jeu excessif ou pathologique et du jeu des mineurs) covers the operator’s approach to detecting and intervening with excessive and pathological players, and its measures for preventing underage play. The AML/CFT action plan addresses anti-money-laundering and counter-terrorist financing compliance in accordance with the Arrêté du 9 septembre 2021 and the national risk analysis published by the COLB (Conseil d’orientation de lutte contre le blanchiment).

The ANJ reviews these plans against its prescribed criteria and issues prescriptions, binding instructions, where the plan is deficient or where the prior year’s prescriptions have not been adequately implemented. The 2023 annual report made clear that prescriptions on identification and accompaniment of excessive players recurred because of persistently low implementation rates. Operators that receive prescriptions and do not implement them face escalation to the formal sanction procedure.

The annual technical certification is a separate requirement. Operators must undergo a unique certification of their archival hardware and an annual recurring certification covering all technical obligations relating to the integrity of gaming operations and information system security. Both are prerequisites for continued licensed operation.

Marketing Strategy Filings: The Six-Monthly Obligation

Since 2024, ANJ licensees have been required to file their marketing strategy with the regulator on a six-monthly cycle. The obligation reflects the ANJ’s assessment that marketing is a direct channel through which excessive gambling is normalised and that operator marketing spend disproportionately targets at-risk populations. France’s gambling advertising framework, developed in cooperation with the Advertising Regulatory Authority (ARPP), imposes strict controls on the use of athletes, celebrities, and influencers who appeal to audiences under 25. Under the Loi Influence of 9 June 2023, influencers who promote gambling without proper disclosure face personal criminal liability.

The marketing filing is not a simple notification. It is a substantive document through which the ANJ assesses whether the operator’s promotional strategy is consistent with its responsible gambling obligations. Operators whose marketing strategy is found to target at-risk demographics, to offer bonuses structured in ways that incentivise continued play by high-risk players, or to breach the under-25 audience restrictions will face prescription or sanction.

The Interdiction Volontaire and the Self-Exclusion Register

France operates the Interdiction Volontaire de jeu as its national voluntary self-exclusion register. As of the ANJ’s 2024 annual report, published June 2025, the register held 85,000 active self-exclusions, up from 40,000 in 2021, representing a 20% annual growth rate sustained over several years. All licensed operators must check players against the register at account opening and are prohibited from allowing persons on the register to access their services.

The register’s growth rate is itself a regulatory signal. The ANJ has drawn a direct line between the increasing volume of self-exclusions and the inadequacy of pre-emptive operator interventions. Players who reach the point of self-excluding have, in many cases, not received the graduated accompaniment that the reference framework requires at earlier stages of risk escalation. Operators should treat rising registration volumes not as evidence that the system is working but as a lagging indicator of missed intervention opportunities upstream.

For a full profile of the ANJ’s licensing framework, vertical scope, and fee structure, see our ANJ licence requirements reference. The player-protection obligations covered in this article operate alongside, and are enforced independently of, the core licence conditions.

Obligation	Legal basis	Frequency	Enforcement consequence (as of July 2026)
Identify and accompany excessive players	Art. 34 IX, Loi 12 mai 2010, Arrêté 9 avril 2021	Continuous	Up to €500,000 fine (Decision 2026-031)
Annual RG action plan submission	Arrêté 9 avril 2021, ANJ Annual Report 2023	Annual	Prescriptions, escalation to formal sanction
Annual AML/CFT action plan submission	Arrêté 9 septembre 2021, COLB national risk analysis	Annual	NSC referral, operating ban (Betsson France precedent)
Annual technical system certification	ANJ certification obligations (Annual Report 2023)	Annual + unique (hardware)	Licence non-renewal risk
Six-monthly marketing strategy filing	ANJ requirement effective 2024	Six-monthly	Prescription, advertising restriction
Interdiction Volontaire register check	Art. 34, Loi 12 mai 2010 (operator obligations)	At account opening and ongoing	Enforcement action, reputational sanction

Incoming: Youth Loss Limits for 18, 25 Year Olds

The French National Assembly approved amendments to the Professional Sports Bill in July 2026 authorising the government to impose mandatory loss limits on sportsbook licensees specifically for consumers aged 18 to 25. The precise monetary threshold has not yet been set, it will be determined by the government through secondary regulation in consultation with the ANJ. The legislative basis is now in place, and operators should anticipate system changes to enforce age-segmented betting limits within the next compliance cycle.

The measure reflects data the ANJ has consistently cited: two-thirds of French consumers under 25 have wagered on sports, and 15.3% of sports bettors overall meet the criteria for problem gambling. France is now one of a small number of regulated markets applying age-specific loss controls, alongside the Netherlands. The UK introduced a £2 maximum stake for online slots for players aged 18 to 24 from May 2025 under the Gambling Act Review White Paper, but France’s approach is broader, targeting losses across all sports betting rather than restricting stakes on a single vertical.

How Does ANJ’s Approach Compare to Peer Regulators?

The ANJ’s algorithm-based approach to identifying excessive players is, as of mid-2025, the first operational tool of its kind in Europe. Spain’s DGOJ and the Netherlands’ KSA are developing comparable mechanisms, but neither had deployed an equivalent live tool at that point. The structural difference in France is that the ANJ receives continuous account-level data from all licensed operators, a data architecture that gives it supervisory depth unavailable to regulators relying on periodic reporting submissions.

The UK Gambling Commission’s affordability-check framework under the LCCP operates through a different model, triggered by deposit thresholds and informed by credit reference data. It is reactive to individual financial circumstances rather than behavioural risk-scoring across the entire player base. Sweden’s Spelinspektionen focuses heavily on deposit limits and the Spelpaus national self-exclusion register but has not deployed behavioural risk algorithms at the same granularity. France’s model, combining continuous data transmission, algorithmic scoring against 23 validated indicators, mandatory action plans reviewed annually, and enforcement against the identification-accompaniment obligation, represents the most operationally intensive player-protection regime among the European competitive licensing markets.

AML Enforcement: A Separate but Parallel Track

The ANJ’s first referral of a licensed operator to France’s National Sanctions Commission (Commission Nationale des Sanctions, CNS) in 2025 resulted in a published decision against Betsson France and its executives. The CNS upheld breaches relating to asset-freezing obligations under EU and French rules, finding that the operator lacked adequate internal procedures to identify sanctioned individuals and freeze their assets. The CNS imposed a €20,000 fine and a suspended two-month operating prohibition on the operator. The former CEO and head of the parent company received a €20,000 fine and a suspended two-month management ban. The compliance officer received a €5,000 fine and the same suspended management ban.

The ANJ has since issued a formal warning to all licensed operators reaffirming their obligations under the AML/CFT framework and announcing enhanced inspection activity, revised alert procedures, and updated risk classification requirements. The warning is explicitly linked to the ANJ’s intensified supervisory posture across both RG and AML tracks simultaneously. Operators should not treat these as separate compliance programmes. The ANJ’s annual review process evaluates both action plans together and draws supervisory conclusions about overall governance quality.

Building the Compliance Calendar: What Operators Must Schedule

The French compliance calendar has several non-negotiable fixed points. Annual action plans on both RG and AML must be submitted and approved each year. Six-monthly marketing strategy filings must be submitted and aligned with the operator’s responsible gambling risk profile. Annual technical system certifications must be completed on schedule. The coffre-fort data vault must be available for ANJ inspection at any time, and the data it contains, covering all player account events, betting operations, and balance movements, must be current and accurate.

The algorithmic pressure adds a continuous dimension that does not map neatly onto fixed calendar dates. Operators whose internal detection tools produce materially lower risk counts than the ANJ’s algorithm would predict are in a supervisory gap that could materialise as a formal inquiry at any point. The appropriate response is to treat the algorithm’s 23 indicators not as the ANJ’s private benchmark but as the current standard against which the cadre de référence obligation will be assessed in enforcement proceedings. Operators should also audit their bonus allocation processes to ensure that players identified as excessive or manifestly excessive are excluded from promotional communications and incentive structures.

Those entering the French market or reviewing their existing compliance programmes should consult qualified French regulatory counsel on the application of these obligations to their specific licence categories and operational model, particularly given the ongoing legislative developments around youth loss limits and advertising controls.

Compliance professionals tracking player-protection obligations across multiple jurisdictions will find a comparative overview of self-exclusion register models, deposit limit frameworks, and customer interaction requirements in our Responsible Gambling Compliance hub, which covers all 17 regulated iGaming jurisdictions on this site including France’s Interdiction Volontaire alongside GAMSTOP, ROFUS, and Spelpaus.

Frequently Asked Questions

What is the ANJ’s legal basis for requiring operators to identify and accompany excessive players?

Article 34, IX, alinéa 3 of the Loi du 12 mai 2010, as amended, imposes the identification and accompaniment obligation on all licensed operators. The Arrêté du 9 avril 2021, the binding reference framework, defines how these duties must be discharged in practice. The ANJ’s sanctions commission confirmed in Decision 2026-031 that the two duties are independently enforceable and that a statutory definition of “excessive gambling” is not required for the obligation to apply.

Does ANJ’s new algorithm impose additional legal obligations on operators?

The algorithm does not itself create new statutory obligations, but it functions as the ANJ’s evidentiary reference point when assessing whether an operator has met its existing identification duties under the cadre de référence. An operator whose detection system systematically identifies far fewer high-risk players than the algorithm predicts faces a strong supervisory inference that its identification methodology is inadequate. Operators should treat the 23 indicators as the current minimum threshold for a defensible detection approach.

What must French operators submit to the ANJ annually?

Licensed operators must submit an annual action plan on responsible gambling, covering excessive player identification and accompaniment and underage play prevention, and a separate annual action plan on AML/CFT. Both are subject to ANJ review, and the regulator issues binding prescriptions where plans are deficient. Operators must also complete annual technical certifications and submit marketing strategies on a six-monthly cycle.

When will mandatory loss limits for 18, 25 year olds take effect in France?

The French National Assembly approved the legislative authorisation for age-specific loss limits for consumers aged 18 to 25 via amendments to the Professional Sports Bill in July 2026. The exact monetary threshold has not been set and will be determined by the government through secondary regulation in consultation with the ANJ. Operators should expect system changes to be required once the threshold is published within the current regulatory cycle.

What was the Betsson France AML sanction and what does it mean for compliance officers?

The French National Sanctions Commission upheld the ANJ’s 2025 referral against Betsson France for failure to comply with EU and French asset-freezing obligations. The operator received a €20,000 fine and a suspended two-month operating ban, its former CEO received a €20,000 fine and a suspended two-month management ban, the compliance officer received a €5,000 fine and the same suspended management ban. The case confirms that personal liability for compliance officers and senior executives is a live enforcement risk in France.

Key Resources

ANJ 2024, 2026 Strategic Plan, anj.fr

ANJ Decision 2026-031 (10 July 2026), €500,000 fine for failure to identify and accompany high-risk players, anj.fr

CNS Decision, Betsson France AML sanctions (July 2026), economie.gouv.fr

Arrêté du 9 avril 2021, Cadre de référence pour la prévention du jeu excessif ou pathologique et la protection des mineurs, anj.fr

Loi du 12 mai 2010 relative aux jeux d’argent et de hasard en ligne, Légifrance