PORTUGAL Law and Practice Contributed by: Pedro Cortés and Luís Portela de Carvalho, Lektou
ments for system architecture, security, RNG integ- rity, game mathematics, RTP publication, logging and interoperability with the regulator’s control system. Only components and games validated through an SRIJ-recognised laboratory may be deployed in Por- tugal by licensed operators. B2B suppliers are not subject to direct authorisation or registration with the SRIJ, but their co-operation is often required during system homologation and post- certification testing. Any substantial modification to certified software, game parameters or platform com- ponents must undergo renewed testing and approval before being placed in production. 6.3 Affiliates Portugal has no stand-alone licensing regime for affili- ates. Their activity is regulated indirectly through the advertising and marketing rules that apply to SRIJ- licensed operators. Licensees remain fully responsi- ble for all promotional content and for ensuring that affiliates comply with national advertising law and SRIJ restrictions, including prohibitions on misleading claims and targeting of minors or vulnerable persons. Promotion of unlicensed gambling is strictly prohib- ited and may result in enforcement or blocking meas- ures by the regulator. 6.4 White Labels Please see 6.1 B2C Licences and 6.2 B2B Licences The SRIJ employs a suite of technical and regulatory measures to safeguard consumers and restrict access to unlicensed gambling. These include IP (internet protocol) and domain blocking and other measures against unlicensed sites, breaches and in order to protect payments. The SRIJ co-ordinates with ISPs to enforce these restrictions. Licensed operators must host their games on SRIJ- certified systems that connect in real time to the regulator’s monitoring platform, ensuring transpar- ency of play, integrity of random-number generation, traceability of transactions and segregation of player funds. Technical standards further mandate encryp- (Suppliers, Software, Etc) . 6.5 Technical Measures
tion, secure authentication, and automated logging to detect fraud or suspicious activity. Player protection is reinforced through a centralised registry, which allows individuals to voluntarily self- exclude themselves from all licensed gambling sites in Portugal. Operators are required to consult the reg- istry before allowing registration or play and to imple- ment account-based tools for deposit limits, reality checks, timeouts and self-assessment. 7. Responsible Gambling (RG), Also Known as Safer Gambling (SG) 7.1 RG Requirements Responsible gambling principles are embedded in both the Gaming Law and the RJO. Operators – whether land-based concessionaires or online licen- sees – must promote safe play, prevent underage and excessive gambling, and ensure access to support mechanisms for problem players. The SRIJ supervises compliance through manda- tory RG policies and real-time data reporting. Online operators must implement a responsible-gaming plan approved by the SRIJ, designate a responsible-gam- ing officer, display clear warnings and probability infor- mation, and link to help services. Land-based casinos and bingo halls must enforce entry controls, visibly display responsible-gaming messages, and provide access to counselling and self-exclusion channel. 7.2 Gambling Management Tools Portugal operates a multi-layered prevention system centred on the centralised registry managed by SRIJ, which applies to all licensed online platforms and land-based casinos. Self-excluded players are auto- matically blocked from registration, login or entry into gaming venues. Operators must implement tools enabling players to set financial and time limits, self-exclude, and access responsible-gaming information. While the law does not expressly require behavioural monitoring, the SRIJ encourages licensees to analyse play patterns and adopt internal procedures to identify and assist play- ers showing signs of problematic gambling.
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