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A low-profile announcement with immediate consequences
Why a technical legal issue is affecting bookmakers in bookstores
On 28 January 2026, the Belgian Gaming Commission (CJH) released a short communication that largely flew under the radar. Yet its implications are anything but minor for Belgian bookstores offering sports and horse-race betting.
Following a ruling by the Council of State, the CJH has confirmed that it is no longer legally able to process new applications or renewals for F2 licences, the specific licence category allowing betting activities in bookstores. The situation has created an immediate regulatory standstill.
A legal framework that depends on execution rules
What the law allows—and what is currently missing
Belgian law does allow bookstores to offer betting services. Article 43/4, §5, 1° of the Gambling Act explicitly authorises bookstores—registered as legal entities or individuals in the Crossroads Bank for Enterprises—to provide sports and horse betting as a strictly ancillary activity.
However, the law also contains a crucial condition: the practical rules governing this activity must be defined by Royal Decree. Without those execution rules, the legal provision cannot be applied in practice.
This dependency is at the heart of the current problem.
The 2022 Royal Decree has been annulled
Why the F2 licence framework suddenly collapsed
To operationalise the law, a Royal Decree was adopted on 17 February 2022. It defined:
- how betting could be organised in bookstores,
- which conditions had to be met,
- and how the CJH could issue and renew F2 licences.
On 22 January 2026, the Council of State annulled this Royal Decree. From a legal standpoint, this means the regulatory foundation of the F2 licensing system has retroactively disappeared.
The Gambling Act itself remains valid—but it can no longer be enforced in the absence of binding execution rules.
An immediate freeze on F2 licences
No new applications, no renewals
In its communication, the CJH leaves little room for interpretation. Until a new Royal Decree is adopted or the law itself is amended, the regulator cannot legally take decisions on F2 licences.
This affects:
- new licence applications, which can no longer be assessed;
- renewals of existing licences, which are equally blocked.
The CJH bases its position on a fundamental principle of administrative law: without a valid regulatory framework, any decision would be legally fragile and likely overturned.
Concrete uncertainty for bookstores
Projects paused, renewals in limbo
For bookstores on the ground, the impact is immediate. Those planning to introduce betting services are forced to suspend their projects. Others whose licences are nearing expiration now find themselves in a legal grey zone, dependent on how quickly the government intervenes.
Importantly, this situation does not reflect a policy shift by the CJH. The regulator has no authority to replace the executive or legislature by setting new rules on its own.
A clear signal to the political level
The CJH points to the government for a solution
The final part of the CJH’s communication carries a clear political message. By stating that it has urged the competent ministers to resolve the issue “as quickly as possible”, the Commission openly signals that responsibility lies elsewhere.
According to the CJH, only two solutions exist:
- the rapid adoption of a new Royal Decree that meets the Council of State’s requirements; or
- a legislative amendment that directly secures the F2 licence regime in law.
Until then, the regulator remains effectively sidelined.
A temporary situation with blocking effects
Why timing now matters
The update of 28 January 2026 should be read as an official warning. Since the annulment of the 2022 Royal Decree, the F2 licence framework for bookstores is legally frozen.
This is not a rejection of betting in bookstores as such, but the consequence of a missing regulatory instrument. How long this uncertainty lasts will depend entirely on the speed of political action—at a time when player monitoring tools such as EPIS are expected to play an even greater role in enforcement.
For bookmakers and retailers alike, regulatory clarity cannot come soon enough.
