PORTUGAL Law and Practice Contributed by: Pedro Cortés and Luís Portela de Carvalho, Lektou
Looking ahead, the evaluation and award of the Espinho, Algarve and Póvoa de Varzim concessions in 2026 will define the land-based model for the next 15 years – economically, operationally and in terms of ESG expectations. It will also test investor appetite for the concession paradigm, potentially informing any future pivot toward a licensing framework. On the online side, the market is maturing after the 2024 peak, with modest growth, stabilising registra- tions and greater utilisation of safer-gambling tools. A far-reaching advertising restrictive model – if enact- ed – would materially reshape acquisition and brand strategies, shifting emphasis toward compliant CRM, product differentiation and demonstrable safer-gam- bling credentials, while testing channelisation. Policymakers are simultaneously examining central- ised self-exclusion and broader modernisation meas- ures to align consumer protection with market com- petitiveness. Portugal’s high regulatory standards, predictable tax- ation, active enforcement against illegal operators and steady demand for online casino and football-centric betting sustain its position as a stable, EU-compliant jurisdiction. The policy choices made in late 2025 and 2026 – particularly on advertising and concessions – will determine whether Portugal consolidates a bal- anced model that protects the vulnerable, preserves channelisation and enables sustainable innovation across both online and land-based sectors. On the online front, there have been several techni- cal and reporting developments since the beginning of 2025. Specifically, SRIJ Instructions Nos 23/2025, 24/2025 and 25/2025 introduced detailed reporting standards for baccarat ( Ponto e Banca ) gameplay, financial transactions, and hourly financial summaries. Together, they establish harmonised XML schemas and uniform procedures for all licensed online gam- ing operators, enhancing consistency, auditability and real-time regulatory oversight. Their entry into effect reflects the regulator’s continued focus on traceabil- ity, system integrity and alignment with the technical requirements set out in Regulations Nos 903-B/2015, 379-A/2016 and 99/2018, further consolidating Por-
tugal’s structured and transparent supervisory frame- work for online gaming and sports betting. In mid-2025, the SRIJ added YoBingo (BingoSoft plc) to its list of licensed entities, marking the first new online bingo authorisation since the introduction of the Decree-Law No 66/2015 (RJO) framework. With this addition, 18 licensed operators now hold 31 licences (13 for fixed-odds betting and 18 for online casino gaming and bingo), evidencing a mature but still dynamic digital channel. Portugal regulates remote gambling and fixed-odds sports betting under the RJO, a comprehensive frame- work combining prescriptive technical standards with continuous regulatory oversight by the SRIJ. Licences are only granted to companies incorporated in Portugal or to branches of EU/European Economic Area (EEA)-incorporated entities duly registered in Portugal. Licence availability is formally uncapped, but effective market entry is restricted by stringent suitability, technical and fiscal requirements. Each licence is issued per vertical – casino-style games or fixed-odds betting – following certification and homologation of the operator’s technical system, ran- dom number generators (RNGs) and approved game types, together with the posting of statutory financial guarantees. 2. Jurisdictional Overview 2.1 Online Gambling Applicants must evidence financial capacity, robust internal controls and compliance governance, sup- ported by detailed technical documentation and sys- tem testing. Certification includes laboratory evalua- tion of platforms, secure data-transmission interfaces, and connectivity with the SRIJ’s real-time monitoring environment. The regulatory perimeter extends beyond authorisa- tion to continuous supervision of operational data, encompassing technical integrity, segregation of player funds, AML/CFT compliance, and responsible- gaming obligations. The SRIJ maintains direct access
385 CHAMBERS.COM
Powered by FlippingBook