Austria Plans 13 Casino Licences Amid Packaging Debate

Austria Plans 13 Casino Licences – Packaging Debate Raises Questions for New Market Entrants

Key Takeaways

• Austria plans to tender 13 land based casino licences under a draft gambling reform bill.
• Entrepreneur Niklas Sattler, through Alea Trust, is preparing a bid to compete with incumbent Casinos Austria.
• The draft law allows licences to be grouped into packages based on objective criteria.
• Past casino tenders were annulled by courts due to transparency failures in the award process.
• Urban casino concessions may be extended until the end of 2028, with a possible further extension of up to 24 months.

Draft Reform Sets Framework for 13 Casino Licences

Austria’s coalition government has presented a draft bill outlining sweeping gambling reforms. Among the proposed changes is a new structure for land based casino concessions. Instead of the 12 licences currently in operation, the draft provides for 13 licences that will be awarded through a forthcoming tender.

The Finance Ministry states that these licences may be grouped into objectively justified packages. Location decisions are to be based on an objective study that considers factors such as population coverage, tourism potential, socioeconomic and demographic conditions, and casino catchment areas. According to the ministry, any packaging must balance commercial viability and value while minimising competition to protect players and discourage aggressive marketing.

Applications will be open to all market participants. However, the final structure of the tender, including whether licences will be offered individually or bundled, has not yet been confirmed.

Alea Trust Prepares Challenge to Casinos Austria

Niklas Sattler, a former executive at Casinos Austria, has spent the past five years preparing a potential bid through his company Alea Trust. Since 2021, he has brought together at least 40 former managers from Casinos Austria and other international casino brands. According to Sattler, the group includes specialists in anti money laundering, responsible gambling, finance and casino operations.

Sattler’s stated objective is to compete directly with Casinos Austria, which currently operates under two 15 year licence packages covering six urban casinos and six in tourist regions. He argues that offering 13 single licences would create a fairer framework by allowing companies to apply for individual locations rather than entire portfolios.

In his view, bundling licences into large packages could limit opportunities for smaller or new entrants. He has indicated that his final decision to enter the tender will depend on how the government structures the concessions.

Incumbent Defends Package Model

Casinos Austria has publicly supported retaining a package system. The company argues that grouping licences ensures broad geographic coverage while taking economic conditions and tourism potential into account. It also states that limiting the number of packages reduces competitive pressure that could otherwise lead to aggressive marketing and excessive gambling.

According to spokesperson Patrick Minar, only a carefully designed package solution can guarantee these objectives. The operator maintains that awarding individual licences could encourage what it describes as cherry picking, where bidders focus only on the most profitable locations.

The draft law now explicitly authorises the packaging of licences and specifies factors that the authority must consider. Nicole Daniel, litigation and regulatory partner at DLA Piper in Vienna, notes that this provides a stronger legal basis than the previous regime. At the same time, she states that regulating package formation in statute does not eliminate the risk of favouring the incumbent, depending on how criteria such as geographical diversity and economic potential are applied.

Legal Risks and Past Tender Challenges

Austria’s previous casino tenders illustrate the legal sensitivity of the process. Following a 2010 revision of the gambling law, the Finance Ministry grouped 12 existing licences into two sets of six and offered three newly created concessions individually. Casinos Austria retained both six licence packages, while the three additional concessions were awarded to Plaza 3 and Novomatic subsidiary Admiral.

These individual awards were later annulled by the Federal Administrative Court, a decision upheld by the Supreme Administrative Court in 2016. The courts found that assessment criteria and their weighting had not been disclosed before bids were prepared, breaching transparency and equal treatment requirements. Although a new procedure was required, it was never launched, and the three additional concessions remained unawarded.

Arthur Stadler, a Vienna based gaming lawyer and founder of Stadler Partner, states that the upcoming tender must be meticulous and rigorously diligent. He notes that the wording of the draft law leaves room for interpretation, particularly regarding how licences are packaged. Based on Austria’s track record, he expects that unsuccessful applicants could challenge the outcome.

Possible Extensions of Existing Urban Licences

The draft reform also addresses the timeline for existing concessions. The six urban casino licences, currently due to expire at the end of 2027, are set to be extended until 31 December 2028. The text further allows for an additional extension of up to 24 months in cases of pending legal proceedings or if no replacement operator has been found.

Daniel states that while the one year extension appears more easily defensible, the additional continuation clause could in practice allow incumbent operations to continue until the end of 2030 without a fresh tender procedure. She expects that legal challenges may focus primarily on this continuation mechanism.

Casinos Austria argues that provisions allowing temporary continuation are not fundamentally new and that the existing framework already included clauses permitting extensions if a tender took longer than planned.

Our Assessment

Austria’s draft gambling reform introduces a new framework for 13 land based casino licences and explicitly allows them to be grouped into packages. The structure of these packages, together with planned extensions of existing urban concessions, will determine how open the market is to new entrants such as Alea Trust. Previous court rulings on casino tenders underline the importance of transparency and equal treatment in the upcoming process, which is likely to face close legal scrutiny from market participants.