Gaming Law 2025

SPAIN Law and Practice Contributed by: Alla Serebrianskaia, Marta de Francisco, Sara Lao and Laura Llorca, Asensi Abogados

• accessible customer service for player complaints; and • the facilitation of a customer support hotline by online operators at the federal level. Operators are also obliged to inform players about the General Register of Gambling Access Bans (RGIAJ) and to offer self-exclusion options. Responsible gam- bling tests are also mandatory to detect potential gambling issues. In this sense, the regulation of gambling activities requires the following. • Identification of participants – operators must establish systems and mechanisms that allow the identification of the participants in the games. This is a measure applicable to online and land-based operators. • Deposit amount limits by default – this is a preven- tative measure and a mandatory requirement for online operators licensed at the federal level. It also applies to land-based businesses such as casinos. However, “default limits” can be reduced by the participant at any time and can be directly applica- ble; they can also be increased or removed (when fulfilling certain conditions). The limits by default in online gambling are: (a) EUR600 daily; (b) EUR1,500 weekly; and (c) EUR3,000 monthly. • Particular requirements for slot games – these include a minimum duration approved for the slot spin on land-based terminals (eg, five seconds in Madrid but three in the Basque Country and online). • The regulation applicable to online gambling at a federal level establishes specific responsible gam- bling requirements for the games grouped under the category of “other games session”. Players are required to configure their session before it begins, setting limits on both the duration of play and the amount of money they intend to spend. Addition- ally, for in-play betting products, a special rule applies concerning the amounts that may be bet. • The regulation applicable to online gambling at the federal level also sets forth the obligation for operators to establish mechanisms and protocols

that make it possible to detect risky behaviours in registered players. This obligation is further developed through the Draft Resolution published by the DGOJ in August 2025, which establishes a standardised mechanism for detecting risky gam- bling behaviour among users. As discussed in 1.1 Current Outlook and Recent Changes , this system will introduce common criteria and thresholds to ensure consistency in the identification and early intervention of at-risk players across all licensed operators. 7.2 Gambling Management Tools As detailed throughout 7. Responsible Gambling (RG), Also Known as Safer Gambling (SG) , the Span- ish authorities have created different tools for opera- tors and citizens in order to promote responsible gam- bling. RGIAJ Through an inscription in the RGIAJ, an individual is fully prohibited from accessing gambling activity (applicable to online and land-based gambling). The register is formed of the data of citizens who voluntar- ily do not wish to exercise their rights to gamble and of those who are declared incapacitated by a legal ruling. Player Verification Service The DGOJ offers online operators a tool to proceed with the ID verification of their customers resident in Spain. Operators can also check whether the cus- tomer is registered with the RGIAJ with this tool, and whether the data provided by the customer corre- sponds to a minor or to individuals included in the Civil Registry as deceased. Phishing Alert The DGOJ has launched a service addressed to all citizens in order for the operator to detect and com- municate an attempt of activation of a user registra- tion when the identity data provided matches the data of an individual who is registered with this service. Mechanism for Detecting Risky User Behaviour As previously mentioned in 1.1 Current Outlook and Recent Changes , the DGOJ has developed a Draft Resolution introducing a unified mechanism for detecting risky gambling behaviour among users. This

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