PORTUGAL Trends and Developments Contributed by: Pedro Cortés and Luís Portela de Carvalho, Lektou
fixed annual fee, 50% for the GGR-percentage share, and 15% for the minimum guaranteed annual fee. Although bidder details remain confidential, sources confirm participation by the three domestic incum- bents and several international groups (notably, from Spain and France). The Algarve attracted the greatest interest (four bidders, including Solverde). Bidding closed in early September 2025; evaluation will continue through year-end, with contract execu- tion expected in early-to-mid 2026. The new concession framework maintains the three- tier financial model ‒ minimum guaranteed annual fee, annual fixed fee and variable GGR contribution ‒ resulting, depending on zone and performance band, in an effective fiscal load approaching 50% of GGR. Importantly, the 2025 tenders also integrate non-gam- ing obligations, tourism and ESG commitments, and community-impact criteria, aligning with the economic Lotteries remain a core pillar of Portugal’s regulated gaming system. The SCML reported gross lottery sales of EUR3.14 billion in 2024, the second-highest in its history, with prizes exceeding EUR2.07 billion. The State’s take amounted to EUR895.5 million, compris- ing EUR673 million in direct revenue and EUR211.6 million in stamp duty. objectives of Portuguese casinos. State Lotteries – A Stable Pillar Early 2025 data confirm sustained growth driven by digital lottery channels and retail-network expansion. The segment’s stability continues to underpin SCML’s broader social-solidarity mission, which distinguishes Portugal from many EU peers. Regulatory Oversight and Enforcement Trends The SRIJ has maintained a rigorous enforcement pos- ture. In H1 2025, it requested the blocking of multiple unlicensed domains and referred several cases to the Public Prosecutor’s Office for investigation of illegal operations. Administrative actions targeted licensed operators for breaches of technical, AML/CFT and responsible-gambling obligations. Recent jurisprudence reaffirmed that failure to update self-exclusion registers in real time may constitute
negligence, which can possibly give rise to civil or administrative liability. On the technical side, SRIJ Instructions Nos 23–25/2025 further institutionalise a data-driven supervisory model, requiring real-time monitoring, hourly financial summaries and uniform XML sche- mas. AML/CFT compliance and responsible-gambling continue to dominate supervisory priorities, with regu- lators emphasising deposit and time limits, “reality- check” notifications and the national self-exclusion register. Advertising Reform and Social Responsibility A defining policy theme in 2025 is gambling-advertis- ing reform, arising from several legislative initiatives introduced by the political party, Livre. In September 2025, the Assembly of the Republic advanced a proposal to committee, aiming to intro- duce stricter broadcast-hour restrictions, prohibi- tions on athlete and influencer endorsements, tighter limits on bonuses and promotional incentives, and enhanced oversight of digital and social-media chan- nels. The initiative has a social-responsibility objective, seeking to shield minors and vulnerable groups while aligning Portugal with emerging European marketing standards. Industry reaction has been mixed. The Portuguese Association of Online Betting and Gambling (APAJO) cautioned that overly restrictive measures risk driving consumers to unlicensed platforms, already estimated at approximately 40% of online play. Operators are therefore re-balancing marketing strate- gies ‒ emphasising customer retention, CRM-based engagement and responsible-gambling visibility rather than mass-advertising. If the bill(s) advances substan- tially, channelisation and player-trust will become criti- cal determinants of market sustainability.
402 CHAMBERS.COM
Powered by FlippingBook