PORTUGAL Law and Practice Contributed by: Pedro Cortés and Luís Portela de Carvalho, Lektou
4.2 Regulatory Approach Portugal applies a prescriptive and risk-based regula- tory model that combines detailed technical standards with continuous oversight by the SRIJ. The framework emphasises technical integrity, player protection, and financial and operational transparency across all licen- sees. Each operator’s technical system must be certified and homologated against comprehensive regulatory requirements covering system architecture, RNGs, game mathematics and RTP disclosure, encryption and cybersecurity, data transmission and logging, and interoperability with the SRIJ’s monitoring systems. Certification is a prerequisite for obtaining and main- taining a licence and must be renewed or updated whenever material changes are made. Licensees are required to maintain robust responsible- gambling controls, including self-exclusion mecha- nisms, deposit and loss limits, reality checks, session and time limits, account activity statements, and man- datory information on risk awareness. Operators must also provide functionality for self-assessment and vol- untary timeouts, and promptly implement player self- exclusion requests registered in the national database. AML/CFT controls follow a full “know-your-customer” model, requiring verification at registration, identity validation prior to participation, ongoing monitoring, and trigger-based reviews of player activity. Enhanced due diligence applies to higher-risk transactions, pay- ment methods, or patterns indicating cross-border or unusual behaviour. Operators must ensure segregation of player funds and sufficient liquidity to cover player balances at all times. Financial and operational reporting is submitted according to formats and intervals prescribed by the SRIJ, enabling real-time supervision. Mandatory event reporting covers defined incidents such as system failures affecting responsible-gam- bling or AML controls, security breaches, downtime exceeding established thresholds, anomalies in RNG or RTP performance, and suspected irregularities in betting markets. The regulator may require corrective measures, enhanced monitoring, or temporary sus-
The SRIJ’s core competences include the licensing, authorisation and certification of gambling activities and operators, including responsibility for online gam- bling licences. It also homologates game types and technical systems, approves methodologies for RNG certification and RTP verification, validates operators’ technical environments, and maintains the national self-exclusion register. It also oversees the testing and certification of gaming equipment and monitors compliance with the applicable laws, regulations and concession contracts. It performs routine and ad hoc inspections of casi- nos and bingo halls, remote supervision of online platforms, and continuous monitoring of operators’ technical systems and data transmissions. Supervision covers technical integrity, segregation of player funds, responsible-gambling controls, AML/ CFT compliance, incident reporting, and record- keeping. The SRIJ may impose corrective measures, enhanced supervision, or temporary suspension of games, functionalities or systems in cases of non- compliance. In its enforcement capacity, the SRIJ is empowered to initiate administrative-offence proceedings, impose fines and ancillary sanctions, suspend or revoke licences, and order blocking of websites or payment interdictions targeting illegal operators. It may issue cease-and-desist orders, refer criminal matters to the Public Prosecutor’s Office, and co-ordinate with law- enforcement authorities for the seizure of illegal equip- ment. The SRIJ also co-operates with foreign regula- tors and international organisations on cross-border enforcement and best-practice exchange. Within the land-based framework, the SRIJ partici- pates in the preparation and evaluation of casino concession tenders, assesses the suitability and financial standing of bidders, monitors concession performance, and ensures compliance with public- interest obligations ‒ particularly in relation to AML/ CFT, responsible gambling, and investment com- mitments. It further oversees bingo operations and technical certification of gaming devices authorised for use in Portugal.
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