PORTUGAL Law and Practice Contributed by: Pedro Cortés and Luís Portela de Carvalho, Lektou
pension of affected systems or games where integrity or consumer protection may be compromised. 4.3 Types of Licences Online gambling and betting licences are issued on a renewable three-year basis for each vertical, with no statutory limit on the number of authorisations. Licences are granted subject to strict corporate, technical, and fiscal suitability requirements, includ- ing system certification and the posting of statutory guarantees. Land-based casino operations are conducted under exclusive concessions assigned to defined gaming zones. Each zone is operated by a single conces- sionaire, typically under a 15-year term, which incor- porates fiscal rates, investment and employment undertakings, and social and tourism-development obligations. Bingo halls located outside casinos are subject to separate concessions governed by their own regula- tory framework and licensing procedures. Land-based fixed-odds betting and state lotteries and social games remain reserved activities, oper- ated through designated public entities or authorised franchisees under the supervision of the State. 4.4 Availability of Licences Online gambling and betting licences are formally available without numerical restriction; however, entry into the Portuguese market remains selective and reg- ulated through demanding suitability, technical and fiscal criteria set out in the RJO. The SRIJ may issue licenses to Portuguese-incorpo- rated companies or to branches of EU/EEA entities meeting all statutory requirements. Each licence is specific to a vertical – such as casino games, fixed- odds sports betting, or bingo ‒ and remains valid for three years, renewable upon continued compliance. As of 2025, 18 licensed operators hold 31 licenses, reflecting a stable and consolidated market. Land-based concessions are limited in number and allocated through public tender for defined geograph- ic gaming zones, each operated by a single conces-
sionaire. Concession contracts typically run for 15 to 20 years, subject to renewal at the government’s discretion. In 2025, new tenders were launched for the Algarve, Espinho, and Póvoa de Varzim zones, signalling the first major concession cycle renewal in over two decades. Concession awards incorporate investment, employment, and tourism-promotion commitments alongside fiscal and social obligations. Bingo concessions are also granted by public tender under a distinct regulatory framework and are limited by municipal or regional planning considerations. The State’s social games and mutual or fixed-odds betting remain reserved activities operated under exclusive rights by the SCML and its network of authorised agents. 4.5 Duration of Licences Online gambling and betting licences are issued for a three-year term, renewable upon application and continued compliance with all statutory, technical, and fiscal obligations. Renewal is not automatic but gen- erally granted where the operator maintains suitabil- ity, meets reporting and taxation requirements, and ensures the integrity of its technical systems. Amend- ments to licence scope – such as the addition of new game types or system upgrades – require prior SRIJ approval but do not interrupt the validity period. Land-based casino concessions are typically awarded for 15- to 20-year terms, as defined in the respective concession contracts. Renewal or extension is discre- tionary and subject to government approval, taking into account the concessionaire’s compliance record, fulfilment of investment and employment commit- ments, and alignment with public-interest objectives. The same duration and renewal logic apply to bingo concessions, which operate under shorter, contractu- ally defined periods depending on the tender terms. Reserved activities, including state lotteries and mutu- al or fixed-odds betting operated by the SCML, are not subject to fixed-term concessions; their continuity derives from public-service mandates and ministerial oversight rather than time-limited authorisations.
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