PORTUGAL Law and Practice Contributed by: Pedro Cortés and Luís Portela de Carvalho, Lektou
4.6 Application Requirements For online licences, applicants must demonstrate corporate suitability, financial capacity and techni- cal compliance, supported by certified system docu- mentation, shareholder and management disclosures, and proof of tax and AML/CFT compliance. A finan- cial guarantee is required to secure fiscal and play- er-protection obligations. Applications are filed with the SRIJ, which reviews legal, financial and technical documentation and may request testing or clarifica- tion before approval. Land-based casino concessions are awarded by pub- lic tender, with one concession per defined gaming zone. Bidders must evidence financial stability, tech- nical expertise and investment capacity, and submit a proposal covering the operation plan, investment commitments and social or tourism benefits. Bingo concessions follow a similar process under separate legislation. 4.7 Application Timing For online licences, the evaluation period varies depending on the complexity of the application and completeness of documentation. In practice, pro- cessing by the SRIJ typically ranges from six months to one year from submission to approval, including technical certification and testing. Renewals gener- ally follow a shorter timeframe where compliance and reporting have been maintained. For land-based casino and bingo concessions, timing is determined by the public tender schedule set by the government. The full procedure – from publication of tender documents to the award decision – can extend over six to 12 months, depending on the number of bidders and evaluation complexity. 4.8 Application Fees Online operators must pay application and certifica- tion fees to the SRIJ covering the review of docu- mentation, system testing and product homologation. Ongoing supervisory fees apply annually. In addition, licensees must post statutory guarantees, typically comprising a general performance bond securing compliance with legal obligations and player protec-
tion; and a separate guarantee securing payment of the IEJO. For land-based casino and bingo concessions, the public tender documentation defines all financial charges and guarantees. Bidders are required to sub- mit a performance bond – usually a percentage of the concession’s total economic value – to secure invest- ment and social obligations under the contract. Addi- tional fees may apply for participation in the tender and the formalisation of the concession agreement. 4.9 Ongoing Annual Fees Portugal does not impose fixed annual administra- tive or supervisory fees on licensed operators beyond the initial application and certification charges. After a licence or concession is granted, no recurring regula- tory fees are payable to the SRIJ unless the operator introduces new game verticals, additional platforms, or material changes to its certified technical system, each of which requires prior approval and the payment of associated homologation or inspection costs. The same applies for license renewals. 4.10 Personal Licensing Portugal does not operate a separate personal licens- ing regime for individual gaming employees. Suitability and integrity are assessed within the broader licens- ing or concession framework for both land-based and online operations. For land-based casinos and bingo halls, specific posi- tions ‒ such as casino directors, gaming-floor man- agers and dealers ‒ must meet suitability and integ- rity standards defined under Decree-Law No 422/89 and secondary regulations state that individuals with criminal convictions for offences involving dishonesty, fraud, money laundering or related crimes are disqual- ified from holding such positions. Concessionaires are responsible for verifying that all personnel engaged in gaming operations satisfy these criteria and for report- ing relevant changes to the SRIJ. For online operators, suitability is assessed at the cor- porate level as part of the licensing process under the RJO. The SRIJ reviews the fitness and propriety of directors, controlling shareholders, senior managers and key function-holders, alongside the applicant’s
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