The Hellenic Competition Commission (HCC) will convene in plenary sitting on Wednesday, 17 December 2025, to assess, pursuant to Article 8 of Law 3959/2011 the notified concentration concerning the acquisition by the company named “ALLWYN INTERNATIONAL AG” (hereinafter referred to as “ALLWYN”) of sole control over the company named “LOGFLEX MT HOLDING LIMITED” (hereinafter referred to as “NOVIBET”), following the relevant Statement of Objections (SO).

Allwyn is a wholly-owned subsidiary of Allwyn AG, parent company of Allwyn Group, which is an international gambling service provider.  In Greece, it operates through OPAP S.A., which in turn is active, inter alia, in the provision of land-based and online gambling services. In the context of the case under consideration, OPAP S.A. provides, directly or through subsidiaries, online betting and online casino services under “Pamestoixima” and “Stoiximan” brands. Novibet's main activity is the provision of online betting and online casino services under the same brand name. The parties to the transaction are competitors and operate in the following relevant markets:

1. a) the online betting market and its submarkets, namely:

a1) online betting on real sports events and

a2) online betting on virtual sports events, as well as

1. b) online casino games (excluding poker games)

According to the SO, the implementation of the concentration under review may significantly restrict effective competition in the horizontally affected markets of online betting and online casino-style games (excluding poker games) due to horizontal effects of non-coordinated behavior, by strengthening Allwyn's dominant position and, in any event, by removing the competitive pressures currently exerted in those oligopolistic markets, in particular due to the elimination of Novibet as a significant competitive force.

In particular, according to the SO, notably considering:

(a) Allwyn's high market share (>50%) prior to the transaction and the parties' very high combined market share in the horizontally affected markets;

b) the significant divergence between the market share of the next competitor and the market share of the new entity, with the other competitors having negligible market shares;

c) the closeness of competition between the two parties on all key competition parameters;

d) the fact that the new entity has a substantial customer base, overwhelmingly larger than that of its competitors;

e) the high barriers to entry for new competitors as well as to the growth of existing competitors due to regulatory requirements, market over-concentration and the parties’ established market position and reputation;

f) the lack of potential competition intensity, and

g) the lack of players’ countervailing power,

it is estimated that the proposed transaction would strengthen Allwyn's dominant position.

Moreover, according to the Report, the parties' brands meet all the conditions which, cumulatively and based on current demand conditions, are necessary for the successful operation of an entity in the affected markets, as:

• the parties have ensured, through high advertising expenditure, that their brands are visible and recognizable, enhancing their reputation and strengthening their perceived brand loyalty among the players,
• the parties offer much higher per capita rewards (bonuses) to the gaming public than their competitors, and
• the parties' platforms are among the most innovative, technologically advanced, and player-friendly, providing a gaming experience that is in line with domestic demand.

These factors are deemed to create a player base with strong loyalty to the parties' brand, and therefore it is estimated that the dominant position of the single entity will not only remain unthreatened in the future but will be further enhanced.

At the same time, and regardless of the expected strengthening of the dominant position found as described above, the SO provides an extensive analysis of Novibet's specific role in the functioning of the markets affected as a significant competitive force as, from 2021 onwards, only Novibet has been able to disrupt the equilibria of the otherwise well-established affected markets by capturing a large market share at the expense of its competitors, with no other operator identified as having similar dynamics and prospects. The following factors are believed to have contributed to its upswing, which no competitor has been able to halt, let alone seek to mirror:

• Novibet pursues an aggressive pricing policy, both in terms of total rake (odds and bonuses) and in terms of (individually considered) bonuses, making it the most advantageous choice for players.
• Its aggressive pricing policy is combined with high advertising costs, which only lag behind those of the market leader Allwyn.
• Novibet has its own modern, award-winning, innovative, Hellenocentric platform, which, due to its user-friendly characteristics and its unique algorithm aimed at personalizing player experience, sets it apart from its competitors, giving Novibet a significant competitive advantage at domestic level.

Therefore, according to the SO, Allwyn seeks, through the proposed transaction, to acquire sole control over a close competitor, namely the only operator that has proven capable of competing on equal terms (i.e. both in commercial and technological terms), while no other competitor can reasonably be expected to be in a position, after the completion of the concentration under review, to take over the role of Novibet, being able to exert substantial competitive pressure on Allwyn and other active providers.

In view of the above, the SO proposes the prohibition, by the HCC, of the concentration concerning the acquisition by Allwyn of sole control over Novibet.

In the above context, Allwyn has proposed to undertake certain commitments to address the serious concerns raised as to the compatibility of the concentration with competition rules in the relevant markets concerned.

It is noted that the Statement of Objections is not binding on the Hellenic Competition Commission, which will decide on the case taking into account all the evidence and the arguments of the parties concerned.