SPAIN Trends and Developments Contributed by: Alla Serebrianskaia, Marta de Francisco, Sara Lao and Laura Llorca, Asensi Abogados
Asensi Abogados Avenida Jaime III 1 Primera Planta 07012 Palma de Mallorca Islas Baleares Spain
Tel: +34 971 909 219 Fax: +34 871 954 347 Email: info@asensi.es Web: www.asensi.es
Overview of Spain 2025 has been a transitional year marked by the announcement of significant developments and the implementation of some measures published in pre- vious years. Alongside regulatory changes and forth- coming updates, we will examine and analyse recent trends in the Spanish online gambling market, high- lighting its main novelties. Hot Topics in 2025 As anticipated, several recent and upcoming devel- opments in Spain are noteworthy, as outlined below. The regulator’s fight against fraud In 2025, both the gambling and AML authorities have placed significant emphasis on combating fraud. From the gambling perspective, it is worth mention- ing the PACS (picture archiving and communication system) Protocol developed in collaboration with the Spanish Tax Agency and State Security Forces to address cases of identity theft on gambling platforms, where individuals use personal data of third parties to open gaming accounts. The need for this protocol arose from a significant increase in complaints from individuals whose identities were misused to evade tax liabilities on potential winnings. After the first year of the protocol, in April 2025, and coinciding with the start of the income tax campaign, a players’ portal was launched, providing real-time information on the PACS Protocol and allowing users to download a transaction report after authenticating themselves with an electronic certificate.
Also related to the fight against fraud, Commission for the Prevention of Money Laundering and Mon- etary Offences (SEPBLAC), the Spanish AML author- ity, has stated that the identification methods histori- cally used to verify players’ identities can no longer be considered sufficient. As a result, operators are now required to strengthen and reinforce their verifica- tion procedures by implementing video identification of customers, which SEPBLAC considers a manda- tory verification method based on the Authorisation Of Video Identification Procedures issued by SEPBLAC in 2016. Operators have expressed their concern and initiated discussions with SEPBLAC regarding more efficient and less outdated methods for managing the identity verification of new users, given that conduct- ing a videoconference with an employee for each user would entail significant material and financial costs. Responsible gambling requirements In the field of responsible gambling, the main devel- opment worth highlighting this year is the announce- ment by the General Directorate for Gambling Regula- tion ( Dirección General de Ordenación del Juego , or DGOJ) of a new Resolution that will develop a mecha- nism, mandatory for all gaming operators and which will replace the measures implemented individually by each operator to date, to detect risky behaviour among users. The much-heralded measure finally took shape in the publication of a draft Resolution on the 28 August 2025. This initiative derives from the obligations set out in Law 13/2011 of 27 May 2011 on the regulation of gambling, and further developed by Royal Decree
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