PORTUGAL Law and Practice Contributed by: Pedro Cortés and Luís Portela de Carvalho, Lektou
1. Introduction 1.1 Current Outlook and Recent Changes Portugal’s gambling industry in 2025 reflects a mature, rules-based framework with stabilising online perfor- mance and a steady – if structurally constrained – land-based recovery. Quantitatively, quarterly data from the Serviço de Reg- ulação e Inspeção de Jogos (SRIJ) show that after a record online gross gaming revenue (GGR) of approxi- mately EUR323 million in Q4 2024, Q1 2025 registered EUR284.7 million and Q2 2025 EUR287.0 million. Year on year, Q1 and Q2 still recorded positive growth of roughly 9–10%. Special Online Gaming Tax (IEJO) collections tracked this performance, totalling approx- imately EUR82.7 million in Q1 and EUR81.2 million in Q2 (circa EUR163.9 million in 1H 2025). Self-exclusions continued to grow at double-digit annual rates, with 309,100 registrations at end-Q1 2025 rising to 326,400 at end-Q2 2025 – quarterly increases of about 5–6% and annual growth in the high 20s. On the land-based side, casinos generated approxi- mately EUR64.5 million GGR in Q1 2025 and EUR65.4 million in Q2 2025 (circa +2.6% year-on-year), with slot machines structurally predominant at around 78–79% of revenue across both quarters. American roulette led the banked table segment, while blackjack posted strong year-on-year growth in Q2. Bingo outside casinos remained a smaller, more vol- atile segment, at roughly EUR6.9 million in Q1 and EUR6.3 million in Q2. The enforcement stance of theSRIJ remained asser- tive. In Q1 2025, the regulator issued several closure notices to illegal operators and notified ISPs to block over several domains; in Q2, both metrics remained at elevated levels, with continued referrals to the Public Prosecutor in the most serious cases. Administrative actions also targeted licensees for breaches of responsible gambling, technical and AML/ CFT obligations, with courts affirming that negligence
– such as failing to synchronise with the national self- exclusion list in real time – can be sufficient to estab- lish liability. On the policy front, 2025 has been notable for two converging developments. First, the Assembly of the Republic advanced to committee (September 2025) a consolidated bill proposing a more restricted approach to gambling advertising across broadcast, print and digital media. Second, Turismo de Portugal and the SRIJ launched international tenders for the Espinho, Algarve and Póvoa de Varzim casino zones. The tenders feature prescriptive evaluation weightings: 35% for the fixed annual consideration, 50% for the variable percentage of GGR offered, and 15% for the minimum guaranteed annual consideration. There are also strict financial intervals and increments, and a performance bond set as a percentage of the contract’s total economic value (2% in the current programmes). Tender eligibility criteria emphasise financial solidity, tax and social-security compliance, proven multi-year experience in casino operations, and robust commit- ments to AML/CFT, responsible gambling, sustainabil- ity and non-gaming tourism initiatives. Identified bidders include incumbents and interna- tional groups from Spain and France, with submis- sions made by early September 2025, evaluations slated until the end of the year and contract execution targeted for early/mid-2026. For Algarve, obligations include refurbishing the Monte Gordo and Vilamoura casinos and opening a third venue in the Barlavento Algarvio – should the successful bidder not be the incumbent Solverde – within defined timelines. The concessionaire will bear full capex and opex risk. These developments – alongside continued technical rule-making – position 2025 as an inflection point for Portugal’s model. The strategic questions now facing policymakers, particularly whether to retain the zonal concession paradigm or explore a licensing-based model for land-based operations, will shape market dynamics, channelisation and consumer protection over the next ten to 15 years.
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