PORTUGAL Law and Practice Contributed by: Pedro Cortés and Luís Portela de Carvalho, Lektou
to transaction and game-event data, enabling verifica- tion of payout ratios, stake flows and system reliability. Online casino games – including slots, roulette, black- jack, punto banco/baccarat, poker and bingo (where authorised) – constitute the bulk of activity, with slots accounting for the majority of stakes and GGR. Fixed-odds sports betting remains dominated by foot- ball, followed by tennis and other seasonal sports tied to international competitions. The market is mature yet competitive, with steady par- ticipation from established operators and occasional new entries. Growth in registered player accounts remains positive, though quarterly expansion has moderated since early 2025, indicating a stabilising customer-acquisition cycle. Enforcement against the unlicensed market remains active through ISP blocking, payment interdiction and cease-and-desist actions, with persistent breaches referred to the Public Prosecutor’s Office. Portugal’s online-gaming regime is widely regarded as one of the EU’s most rigorous and transparent, bal- ancing regulatory predictability with strong integrity, consumer-protection and fiscal-stability outcomes. 2.2 Land-Based Gambling Land-based gambling in Portugal operates under a state-concession model defined by Decree-Law No 422/89 (the “Gaming Law”). The right to operate games of chance is reserved to the State and granted through exclusive territorial concessions for defined gaming zones. Each concession is awarded by pub- lic tender for up to 20 years (renewable) and covers casino gaming, gaming machines, and authorised ancillary activities. As of late 2025, nine of the ten mainland and island zones are active, with new tenders launched in 2025 for Algarve, Espinho, and Póvoa de Varzim to replace expiring contracts. Casinos may offer approved games of fortune and chance – roulette, blackjack, baccarat, poker, and slot machines – subject to technical certification and
supervision by the SRIJ. Gaming machines dominate land-based GGR, representing about 70% of total casino revenue in 2024, according to SRIJ data. Bingo is also permitted but more restricted: halls operate under Decree-Law No 31/2011, either within casino premises or under separate municipal conces- sions. Gaming machines located outside casinos (so- called máquinas de diversão ) are regulated separately under Decree-Law No 310/2002 and are limited to amusement-only play with no cash prizes. Poker is lawful only when inside licensed casinos. Tournaments and cash games must be authorised individually and conducted under SRIJ-approved rules. Lotteries and mutual sports betting remain an exclu- sive monopoly of Santa Casa da Misericórdia de Lis- boa (SCML), which operates national draw-based and instant-win products (Totoloto, Raspadinhas, Euromillhões) and land-based sports pools (Totobola, Totogolo), as well as land-based fixed odds (Placard). Pari-mutuel horse-race betting has a statutory basis but is not currently operational, although it may be introduced in the near future. Other forms of prize contests, tombolas, and pro- motional draws are permissible only under municipal authorisation and when prizes are of low value. Overall, Portugal’s land-based framework remains highly centralised, with limited market entry and a close link between gaming policy and tourism pro- motion.
3. Legislative Framework 3.1 Key Legislation
Portugal’s gambling legislation is codified in primary laws and decree-laws complemented by extensive secondary regulations, regulator-issued instructions and technical standards. Core instruments include the following.
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