PORTUGAL Trends and Developments Contributed by: Pedro Cortés and Luís Portela de Carvalho, Lektou
Structural Considerations: Concession Model Versus Licensing Portugal’s land-based model, built on exclusive zonal concessions, remains distinctive but is likely to face increasing debate. While it ensures regulatory control and fiscal predict- ability, the model’s high entry thresholds and heavy fixed-cost structure may inhibit competition and deter reinvestment. Critics advocate a gradual transition toward a licensing regime, promoting greater trans- parency, broader participation and lower operational risk, akin to models in other EU jurisdictions. The 2025 tender cycle acts as a litmus test for this debate. Although the tendering process introduces modern evaluation metrics ‒ such as tourism develop- ment, ESG, community benefits ‒ it remains anchored in the concession framework. Given the land-based sector’s modest year-on-year growth of approximately 2.6% and effective fiscal burdens approaching 50% of GGR, policymakers will soon need to decide whether incremental adjustments suffice or a systemic shift toward licensing is required to sustain long-term competitiveness. Outlook for 2026 and Beyond The coming year will be important. The award of the three new concessions (five casinos total), coupled with the parliamentary review of the advertising bill, will define Portugal’s gaming trajectory for the next decade. The online market is maturing with growth stabilising, acquisition rates levelling, and focus shifting toward safer-gambling optimisation, retention, and operation- al efficiency. Online bingo is expected to grow further as a socially inclusive vertical complementing casino operations.
Land-based casinos and bingo halls, meanwhile, face significant fiscal pressure and must seek closer inte- gration with tourism, cultural and entertainment eco- systems to remain viable. In parallel, Portugal’s position as a regional and global dialogue hub has been reinforced. The SBC Summit continues to take place in Lisbon, bringing togeth- er regulators, industry leaders and policymakers to discuss responsible innovation and regulatory con- vergence. In 2025, the International Masters of Gam- ing Law (IMGL) Autumn Conference was also held in Lisbon, marking a milestone for the international gaming-law community and highlighting Portugal’s emergence as a focal point for thought leadership in gaming regulation. Portugal’s regulatory model continues to serve as a benchmark for integrity and transparency, supported by strong consumer-protection frameworks and a predictable tax environment. The policy challenge for 2026–27 is to continue balancing social responsibility, fiscal yield and market dynamism. Decisions taken in late 2025 and 2026 ‒ particularly on advertising, bingo and licensing reform ‒ will deter- mine whether Portugal consolidates as a forward- looking, socially responsible jurisdiction, capable of protecting the vulnerable while supporting sustainable innovation.
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