A dispute over online gambling losses may clarify an important point of EU law: whether bank accounts of a gambling operator can be frozen even if insolvency proceedings have been opened against the company outside the European Union. According to the opinion of Advocate General Rimvydas Norkus, delivered on 5 March 2026 in case C-716/24, the answer is yes.
The case involves a German player who obtained a Frankfurt court ruling ordering the reimbursement of about €57,000 in online gambling losses from a company based in Curaçao. After winning the case, the claimant asked German courts to identify and freeze the operator’s bank accounts in Cyprus using the European Account Preservation Order (EAPO) provided by EU Regulation No. 655/2014.
During the proceedings it emerged that insolvency proceedings had been opened against the company in Curaçao. This raised the question of whether bankruptcy initiated in a non-EU country, even if recognized under national law in a Member State, could prevent the use of the EU bank account freezing mechanism.
According to the Advocate General, the exclusion in the EU regulation applies only to insolvency proceedings governed by EU law and opened within EU Member States. It does not automatically extend to insolvency procedures started in third countries. Allowing national recognition of foreign insolvency proceedings to block the EU freezing order could lead to inconsistent application of the regulation across Member States.
The opinion therefore concludes that insolvency proceedings opened outside the EU should not prevent courts from issuing a European order to freeze bank accounts. The impact of the foreign insolvency procedure may instead be assessed later during the enforcement stage.
If confirmed by the Court of Justice, the ruling could have significant implications for the online gambling sector, where many operators are based in offshore jurisdictions but manage payments through bank accounts located in EU Member States.
