Gaming Law 2025 Comparisons

Portugal’s gambling industry in 2025 reflects a mature, rules-based framework with stabilising online performance and a steady – if structurally constrained – land-based recovery.

Quantitatively, quarterly data from the Serviço de Regulação e Inspeção de Jogos (SRIJ) show that after a record online gross gaming revenue (GGR) of approximately EUR323 million in Q4 2024, Q1 2025 registered EUR284.7 million and Q2 2025 EUR287.0 million.

Year on year, Q1 and Q2 still recorded positive growth of roughly 9–10%. Special Online Gaming Tax (IEJO) collections tracked this performance, totalling approximately EUR82.7 million in Q1 and EUR81.2 million in Q2 (circa EUR163.9 million in 1H 2025).

Self-exclusions continued to grow at double-digit annual rates, with 309,100 registrations at end-Q1 2025 rising to 326,400 at end-Q2 2025 – quarterly increases of about 5–6% and annual growth in the high 20s.

On the land-based side, casinos generated approximately EUR64.5 million GGR in Q1 2025 and EUR65.4 million in Q2 2025 (circa +2.6% year-on-year), with slot machines structurally predominant at around 78–79% of revenue across both quarters. American roulette led the banked table segment, while blackjack posted strong year-on-year growth in Q2.

Bingo outside casinos remained a smaller, more volatile segment, at roughly EUR6.9 million in Q1 and EUR6.3 million in Q2.

The enforcement stance of theSRIJ remained assertive. In Q1 2025, the regulator issued several closure notices to illegal operators and notified ISPs to block over several domains; in Q2, both metrics remained at elevated levels, with continued referrals to the Public Prosecutor in the most serious cases.

Administrative actions also targeted licensees for breaches of responsible gambling, technical and AML/CFT obligations, with courts affirming that negligence – such as failing to synchronise with the national self-exclusion list in real time – can be sufficient to establish liability.

On the policy front, 2025 has been notable for two converging developments. First, the Assembly of the Republic advanced to committee (September 2025) a consolidated bill proposing a more restricted approach to gambling advertising across broadcast, print and digital media.

Second, Turismo de Portugal and the SRIJ launched international tenders for the Espinho, Algarve and Póvoa de Varzim casino zones. The tenders feature prescriptive evaluation weightings: 35% for the fixed annual consideration, 50% for the variable percentage of GGR offered, and 15% for the minimum guaranteed annual consideration. There are also strict financial intervals and increments, and a performance bond set as a percentage of the contract’s total economic value (2% in the current programmes).

Tender eligibility criteria emphasise financial solidity, tax and social-security compliance, proven multi-year experience in casino operations, and robust commitments to AML/CFT, responsible gambling, sustainability and non-gaming tourism initiatives.

Identified bidders include incumbents and international groups from Spain and France, with submissions made by early September 2025, evaluations slated until the end of the year and contract execution targeted for early/mid-2026. For Algarve, obligations include refurbishing the Monte Gordo and Vilamoura casinos and opening a third venue in the Barlavento Algarvio – should the successful bidder not be the incumbent Solverde – within defined timelines. The concessionaire will bear full capex and opex risk.

These developments – alongside continued technical rule-making – position 2025 as an inflection point for Portugal’s model. The strategic questions now facing policymakers, particularly whether to retain the zonal concession paradigm or explore a licensing-based model for land-based operations, will shape market dynamics, channelisation and consumer protection over the next ten to 15 years.

Looking ahead, the evaluation and award of the Espinho, Algarve and Póvoa de Varzim concessions in 2026 will define the land-based model for the next 15 years – economically, operationally and in terms of ESG expectations. It will also test investor appetite for the concession paradigm, potentially informing any future pivot toward a licensing framework.

On the online side, the market is maturing after the 2024 peak, with modest growth, stabilising registrations and greater utilisation of safer-gambling tools. A far-reaching advertising restrictive model – if enacted – would materially reshape acquisition and brand strategies, shifting emphasis toward compliant CRM, product differentiation and demonstrable safer-gambling credentials, while testing channelisation.

Policymakers are simultaneously examining centralised self-exclusion and broader modernisation measures to align consumer protection with market competitiveness.

Portugal’s high regulatory standards, predictable taxation, active enforcement against illegal operators and steady demand for online casino and football-centric betting sustain its position as a stable, EU-compliant jurisdiction. The policy choices made in late 2025 and 2026 – particularly on advertising and concessions – will determine whether Portugal consolidates a balanced model that protects the vulnerable, preserves channelisation and enables sustainable innovation across both online and land-based sectors.

On the online front, there have been several technical and reporting developments since the beginning of 2025. Specifically, SRIJ Instructions Nos 23/2025, 24/2025 and 25/2025 introduced detailed reporting standards for baccarat (Ponto e Banca) gameplay, financial transactions, and hourly financial summaries. Together, they establish harmonised XML schemas and uniform procedures for all licensed online gaming operators, enhancing consistency, auditability and real-time regulatory oversight. Their entry into effect reflects the regulator’s continued focus on traceability, system integrity and alignment with the technical requirements set out in Regulations Nos 903-B/2015, 379-A/2016 and 99/2018, further consolidating Portugal’s structured and transparent supervisory framework for online gaming and sports betting.

In mid-2025, the SRIJ added YoBingo (BingoSoft plc) to its list of licensed entities, marking the first new online bingo authorisation since the introduction of the Decree-Law No 66/2015 (RJO) framework. With this addition, 18 licensed operators now hold 31 licences (13 for fixed-odds betting and 18 for online casino gaming and bingo), evidencing a mature but still dynamic digital channel.

Portugal regulates remote gambling and fixed-odds sports betting under the RJO, a comprehensive framework combining prescriptive technical standards with continuous regulatory oversight by the SRIJ.

Licences are only granted to companies incorporated in Portugal or to branches of EU/European Economic Area (EEA)-incorporated entities duly registered in Portugal. Licence availability is formally uncapped, but effective market entry is restricted by stringent suitability, technical and fiscal requirements. Each licence is issued per vertical – casino-style games or fixed-odds betting – following certification and homologation of the operator’s technical system, random number generators (RNGs) and approved game types, together with the posting of statutory financial guarantees.

Applicants must evidence financial capacity, robust internal controls and compliance governance, supported by detailed technical documentation and system testing. Certification includes laboratory evaluation of platforms, secure data-transmission interfaces, and connectivity with the SRIJ’s real-time monitoring environment.

The regulatory perimeter extends beyond authorisation to continuous supervision of operational data, encompassing technical integrity, segregation of player funds, AML/CFT compliance, and responsible-gaming obligations. The SRIJ maintains direct access to transaction and game-event data, enabling verification of payout ratios, stake flows and system reliability.

Online casino games – including slots, roulette, blackjack, punto banco/baccarat, poker and bingo (where authorised) – constitute the bulk of activity, with slots accounting for the majority of stakes and GGR. 

Fixed-odds sports betting remains dominated by football, followed by tennis and other seasonal sports tied to international competitions.

The market is mature yet competitive, with steady participation from established operators and occasional new entries. Growth in registered player accounts remains positive, though quarterly expansion has moderated since early 2025, indicating a stabilising customer-acquisition cycle.

Enforcement against the unlicensed market remains active through ISP blocking, payment interdiction and cease-and-desist actions, with persistent breaches referred to the Public Prosecutor’s Office.

Portugal’s online-gaming regime is widely regarded as one of the EU’s most rigorous and transparent, balancing regulatory predictability with strong integrity, consumer-protection and fiscal-stability outcomes.

Land-based gambling in Portugal operates under a state-concession model defined by Decree-Law No 422/89 (the “Gaming Law”). The right to operate games of chance is reserved to the State and granted through exclusive territorial concessions for defined gaming zones. Each concession is awarded by public tender for up to 20 years (renewable) and covers casino gaming, gaming machines, and authorised ancillary activities. 

As of late 2025, nine of the ten mainland and island zones are active, with new tenders launched in 2025 for Algarve, Espinho, and Póvoa de Varzim to replace expiring contracts.

Casinos may offer approved games of fortune and chance – roulette, blackjack, baccarat, poker, and slot machines – subject to technical certification and supervision by the SRIJ. Gaming machines dominate land-based GGR, representing about 70% of total casino revenue in 2024, according to SRIJ data.

Bingo is also permitted but more restricted: halls operate under Decree-Law No 31/2011, either within casino premises or under separate municipal concessions. Gaming machines located outside casinos (so-called máquinas de diversão) are regulated separately under Decree-Law No 310/2002 and are limited to amusement-only play with no cash prizes.

Poker is lawful only when inside licensed casinos. Tournaments and cash games must be authorised individually and conducted under SRIJ-approved rules.

Lotteries and mutual sports betting remain an exclusive monopoly of Santa Casa da Misericórdia de Lisboa (SCML), which operates national draw-based and instant-win products (Totoloto, Raspadinhas, Euromillhões) and land-based sports pools (Totobola, Totogolo), as well as land-based fixed odds (Placard).

Pari-mutuel horse-race betting has a statutory basis but is not currently operational, although it may be introduced in the near future.

Other forms of prize contests, tombolas, and promotional draws are permissible only under municipal authorisation and when prizes are of low value.

Overall, Portugal’s land-based framework remains highly centralised, with limited market entry and a close link between gaming policy and tourism promotion. 

Portugal’s gambling legislation is codified in primary laws and decree-laws complemented by extensive secondary regulations, regulator-issued instructions and technical standards. Core instruments include the following.

• Decree-Law No 422/89 (Gaming Law, as amended) – establishes the State-reserved nature of land-based casino gaming, creates and qualifies geographic gaming zones, and sets the concession model, catalogue of authorised games, supervisory powers, sanctions, and rules for bingo and slot halls.
• Decree-Law No 66/2015 (Regime Jurídico dos Jogos e Apostas Online, or RJO, as amended) – framework for online gambling and fixed-odds betting, covering licensing entities, technical system certification/homologation, authorised product catalogue, responsible gambling and AML/CFT obligations, reporting and event-notification, oversight and sanctions.
• Decree-Law No 67/2015 (Land-Based Fixed-Odds Sports Betting, as amended) – governs fixed-odds sports betting offered on land-based channels, including the role of designated public operators/franchisees and interfaces with lottery/state social games.
• Decree-Law No 68/2015 (Horse Racing – pari-mutuel and fixed-odds) – sets the legal framework for mutual and fixed-odds horse race betting, including the allocation of rights to designated public entities in retail channels and coordination with the online regime.
• Law No 83/2017 and Law No 89/2017 (AML/CFT, as amended) – sector-wide AML/CFT regime applicable to gambling “obliged entities”, including risk-based customer due diligience (CDD), beneficial ownership verification, PEP screening, ongoing monitoring, suspicious transaction report (STR) filing to the FIU, internal controls and training.
• EU GDPR and Law No 58/2019 (national implementation) – data-protection framework governing lawful processing, transparency, minimisation, security, retention and data-subject rights; with particular relevance to self-exclusion, markers of harm and identity verification data.
• Decree-Law No 330/90 (Advertising Code, as amended) and SRIJ guidelines on gambling advertising – set content, placement and targeting standards for gambling advertising and promotions. 2025 legislative proposals envisage a more restrictive regulatory outlook.
• Portaria 211/2015 (online fees and homologation costs) – establishes application, certification/homologation and supervisory fee schedules under the RJO for online operators and products.
• Product-level RJO regulations (2015 onwards) – SRIJ regulations specifying the technical and game rules for each authorised vertical (eg, fixed-odds sports betting, bingo, poker variants, slot machines, American/French roulette, blackjack), including RNG and return-to-player (RTP) standards, logging, reporting formats and event-reporting triggers.

There are two definitions of gambling under the Gaming Law and the RJO.

The Gaming Law defines games of fortune or chance as “[g]ames whose outcome is contingent, depending exclusively or mainly on luck”, adding that “any other games in which gain and loss are determined exclusively by chance are also considered games of fortune or chance”.

The RJO defines online games of fortune or chance as “a game that involves the payment of a monetary amount and whose outcome is contingent, depending exclusively or mainly on luck.”

“Online gambling and betting” are also defined therein as games of fortune or chance, fixed-odds sports betting and mutual or fixed-odds horse race betting conducted remotely by electronic, computerised, telematic or interactive means.

Portugal’s regulated catalogue includes banked table games (American and French roulette, blackjack/21, punto banco/baccarat), non-banked games (certain poker formats, bingo), slot machines, crash-type games where authorised, and fixed-odds betting.

The definition excludes instruments and contracts where the activity’s economic purpose and risk allocation reflect financial services or insurance rather than gaming, consistent with long-standing doctrinal distinctions.

The Gaming Law defines games of fortune or chance as “[g]ames whose outcome is contingent, depending exclusively or mainly on luck”, adding that “any other games in which gain and loss are determined exclusively by chance are also considered games of fortune or chance”.

The RJO defines online games of fortune or chance as “a game that involves the payment of a monetary amount and whose outcome is contingent, depending exclusively or mainly on luck”.

“Online gambling and betting” are also defined therein as games of fortune or chance, fixed-odds sports betting and mutual or fixed-odds horse race betting conducted remotely by electronic, computerised, telematic or interactive means.

Land-Based

The operation of land-based gambling in Portugal is reserved to the State and may only be carried out under a valid concession. Activities conducted outside the concession framework are criminally prohibited.

The principal offences include the following.

• Unauthorised operation of games of fortune or chance ‒ organise, manage or operate games of fortune or chance without a concession or outside authorised casino or bingo premises. Liability extends to anyone controlling the venue or equipment used for the games.
• Participation in unlawful gambling ‒ players who knowingly take part in unlicensed gambling may be subject to fines and forfeiture of winnings.
• Use of premises for illegal gambling ‒ allowing or tolerating the use of premises for unauthorised gaming, particularly in hospitality or entertainment venues.
• Advertising or promotion of unauthorised gambling ‒ promoting or publicising unlicensed games, including distribution of gaming materials or information that directs the public to illegal venues.
• Manufacture or distribution of unauthorised gaming equipment ‒ production, importation or supply of gaming devices without approval.
• Breach of concession terms and conditions ‒ concessionaires or bingo operators who introduce unauthorised games, fail to comply with accounting or AML obligations, or otherwise breach their contracts may be committing administrative offences that may result in suspension or revocation of their licence.

Online

The RJO establishes a closed licensing system under which only operators duly authorised by the SRIJ may offer remote gambling and betting to players located in Portugal.

Any operation, promotion or facilitation of online gambling outside this framework is unlawful and may trigger criminal or administrative liability.

The principal offences include the following.

• Operation of unlicensed online gambling or betting ‒ offering, organising or providing online games of fortune or chance, fixed-odds sports betting or horse race betting without a licence is a criminal offence. The prohibition applies both to domestic and offshore operators that target Portuguese players through language, currency, or marketing.
• Promotion or facilitation of unauthorised gambling ‒ advertising, marketing, or otherwise promoting access to unlicensed websites ‒ including through affiliate links, sponsorships, or payment processing ‒ is prohibited. The restriction extends to intermediaries that knowingly enable or support such activity.
• Participation in unlawful online gambling ‒ players who intentionally use unlicensed gambling services may be fined and are subject to forfeiture of any winnings derived from such activity.
• Manipulation or fraudulent conduct ‒ interfering with gambling software, manipulating bets, or using insider information to obtain an unfair advantage constitutes a criminal offence and may fall within the general provisions on fraud or cybercrime.
• Non-compliance by licensed operators ‒ licensees that fail to comply with their technical, AML/CTF, reporting or responsible-gaming obligations commit administrative offences, which may be subject to fines and, in serious or repeated cases, suspension or revocation of the licence.

Land-Based

The unlawful operation of games of fortune or chance constitutes a criminal offence, punishable by imprisonment of up to two years or by a fine, with heavier penalties for repeated or professional offenders.

Players who knowingly participate in illegal gambling may also be fined and have their winnings confiscated.

Advertising or facilitating unauthorised gambling can result in imprisonment or fines, and the closure of premises or seizure of gaming equipment may be ordered.

Licensed casino and bingo operators that breach concession conditions are subject to administrative penalties, including fines, suspension, or revocation of the concession.

Online

Operating or promoting online gambling or betting without an SRIJ licence is a criminal offence punishable by imprisonment of up to five years or by substantial fines up to EUR500,000 for individuals and EUR1 million for companies.

Promotion or facilitation of unlicensed gambling may also attract significant fines, while players who intentionally participate in unauthorised games risk financial penalties and forfeiture of winnings.

Licensed operators that breach technical, AML, or responsible-gaming obligations face administrative fines up to EUR1 million and may have their licence suspended or revoked.

The SRIJ may additionally order blocking of websites, interruption of payment channels, and publication of sanction decisions.

Gaming Commission

The Comissão de Jogos (the “Gaming Commission”) operates within Turismo de Portugal and serves primarily as an advisory and deliberative body supporting the SRIJ in the exercise of its regulatory and supervisory functions.

The Commission’s role is to advise on strategic and policy matters related to gambling regulation, provide opinions and recommendations on draft legislation, and issue non-binding guidance concerning the interpretation and application of gaming laws. It also reviews certain regulatory proposals prepared by the SRIJ and may give opinions on matters such as concession frameworks, tender procedures, and the approval of new types of games or gaming equipment.

While the SRIJ (see below) is the executive and operational authority ‒ responsible for licensing, supervision, inspection, and enforcement ‒ the Gaming Commission functions as a consultative collegiate body, ensuring that regulatory decisions align with the broader public-interest objectives of transparency, integrity, and responsible gambling.

The Commission is chaired by the President of Turismo de Portugal and includes representatives from various ministries, the SRIJ, and other public bodies with competence in financial regulation, consumer protection, and law enforcement. It convenes periodically to discuss regulatory developments, assess market trends, and contribute to policy co-ordination between the government and the gambling sector.

The SRIJ

The SRIJ is the national gambling regulator, operating as a specialised department within Turismo de Portugal under the joint supervision of the Ministry of Economy and directly by the Secretary of State for Tourism. 

It is vested with administrative, regulatory, supervisory, and enforcement powers across both the land-based and online gambling sectors.

The SRIJ’s core competences include the licensing, authorisation and certification of gambling activities and operators, including responsibility for online gambling licences. It also homologates game types and technical systems, approves methodologies for RNG certification and RTP verification, validates operators’ technical environments, and maintains the national self-exclusion register. It also oversees the testing and certification of gaming equipment and monitors compliance with the applicable laws, regulations and concession contracts.

It performs routine and ad hoc inspections of casinos and bingo halls, remote supervision of online platforms, and continuous monitoring of operators’ technical systems and data transmissions. 

Supervision covers technical integrity, segregation of player funds, responsible-gambling controls, AML/CFT compliance, incident reporting, and record-keeping. The SRIJ may impose corrective measures, enhanced supervision, or temporary suspension of games, functionalities or systems in cases of non-compliance.

In its enforcement capacity, the SRIJ is empowered to initiate administrative-offence proceedings, impose fines and ancillary sanctions, suspend or revoke licences, and order blocking of websites or payment interdictions targeting illegal operators. It may issue cease-and-desist orders, refer criminal matters to the Public Prosecutor’s Office, and co-ordinate with law-enforcement authorities for the seizure of illegal equipment. The SRIJ also co-operates with foreign regulators and international organisations on cross-border enforcement and best-practice exchange.

Within the land-based framework, the SRIJ participates in the preparation and evaluation of casino concession tenders, assesses the suitability and financial standing of bidders, monitors concession performance, and ensures compliance with public-interest obligations ‒ particularly in relation to AML/CFT, responsible gambling, and investment commitments. It further oversees bingo operations and technical certification of gaming devices authorised for use in Portugal.

Portugal applies a prescriptive and risk-based regulatory model that combines detailed technical standards with continuous oversight by the SRIJ. The framework emphasises technical integrity, player protection, and financial and operational transparency across all licensees.

Each operator’s technical system must be certified and homologated against comprehensive regulatory requirements covering system architecture, RNGs, game mathematics and RTP disclosure, encryption and cybersecurity, data transmission and logging, and interoperability with the SRIJ’s monitoring systems. Certification is a prerequisite for obtaining and maintaining a licence and must be renewed or updated whenever material changes are made.

Licensees are required to maintain robust responsible-gambling controls, including self-exclusion mechanisms, deposit and loss limits, reality checks, session and time limits, account activity statements, and mandatory information on risk awareness. Operators must also provide functionality for self-assessment and voluntary timeouts, and promptly implement player self-exclusion requests registered in the national database.

AML/CFT controls follow a full “know-your-customer” model, requiring verification at registration, identity validation prior to participation, ongoing monitoring, and trigger-based reviews of player activity. Enhanced due diligence applies to higher-risk transactions, payment methods, or patterns indicating cross-border or unusual behaviour.

Operators must ensure segregation of player funds and sufficient liquidity to cover player balances at all times. Financial and operational reporting is submitted according to formats and intervals prescribed by the SRIJ, enabling real-time supervision.

Mandatory event reporting covers defined incidents such as system failures affecting responsible-gambling or AML controls, security breaches, downtime exceeding established thresholds, anomalies in RNG or RTP performance, and suspected irregularities in betting markets. The regulator may require corrective measures, enhanced monitoring, or temporary suspension of affected systems or games where integrity or consumer protection may be compromised.

Online gambling and betting licences are issued on a renewable three-year basis for each vertical, with no statutory limit on the number of authorisations. Licences are granted subject to strict corporate, technical, and fiscal suitability requirements, including system certification and the posting of statutory guarantees.

Land-based casino operations are conducted under exclusive concessions assigned to defined gaming zones. Each zone is operated by a single concessionaire, typically under a 15-year term, which incorporates fiscal rates, investment and employment undertakings, and social and tourism-development obligations.

Bingo halls located outside casinos are subject to separate concessions governed by their own regulatory framework and licensing procedures.

Land-based fixed-odds betting and state lotteries and social games remain reserved activities, operated through designated public entities or authorised franchisees under the supervision of the State.

Online gambling and betting licences are formally available without numerical restriction; however, entry into the Portuguese market remains selective and regulated through demanding suitability, technical and fiscal criteria set out in the RJO. 

The SRIJ may issue licenses to Portuguese-incorporated companies or to branches of EU/EEA entities meeting all statutory requirements. Each licence is specific to a vertical – such as casino games, fixed-odds sports betting, or bingo ‒ and remains valid for three years, renewable upon continued compliance. As of 2025, 18 licensed operators hold 31 licenses, reflecting a stable and consolidated market.

Land-based concessions are limited in number and allocated through public tender for defined geographic gaming zones, each operated by a single concessionaire. Concession contracts typically run for 15 to 20 years, subject to renewal at the government’s discretion. In 2025, new tenders were launched for the Algarve, Espinho, and Póvoa de Varzim zones, signalling the first major concession cycle renewal in over two decades. Concession awards incorporate investment, employment, and tourism-promotion commitments alongside fiscal and social obligations.

Bingo concessions are also granted by public tender under a distinct regulatory framework and are limited by municipal or regional planning considerations. The State’s social games and mutual or fixed-odds betting remain reserved activities operated under exclusive rights by the SCML and its network of authorised agents.

Online gambling and betting licences are issued for a three-year term, renewable upon application and continued compliance with all statutory, technical, and fiscal obligations. Renewal is not automatic but generally granted where the operator maintains suitability, meets reporting and taxation requirements, and ensures the integrity of its technical systems. Amendments to licence scope – such as the addition of new game types or system upgrades – require prior SRIJ approval but do not interrupt the validity period.

Land-based casino concessions are typically awarded for 15- to 20-year terms, as defined in the respective concession contracts. Renewal or extension is discretionary and subject to government approval, taking into account the concessionaire’s compliance record, fulfilment of investment and employment commitments, and alignment with public-interest objectives. The same duration and renewal logic apply to bingo concessions, which operate under shorter, contractually defined periods depending on the tender terms.

Reserved activities, including state lotteries and mutual or fixed-odds betting operated by the SCML, are not subject to fixed-term concessions; their continuity derives from public-service mandates and ministerial oversight rather than time-limited authorisations.

For online licences, applicants must demonstrate corporate suitability, financial capacity and technical compliance, supported by certified system documentation, shareholder and management disclosures, and proof of tax and AML/CFT compliance. A financial guarantee is required to secure fiscal and player-protection obligations. Applications are filed with the SRIJ, which reviews legal, financial and technical documentation and may request testing or clarification before approval.

Land-based casino concessions are awarded by public tender, with one concession per defined gaming zone. Bidders must evidence financial stability, technical expertise and investment capacity, and submit a proposal covering the operation plan, investment commitments and social or tourism benefits. 

Bingo concessions follow a similar process under separate legislation.

For online licences, the evaluation period varies depending on the complexity of the application and completeness of documentation. In practice, processing by the SRIJ typically ranges from six months to one year from submission to approval, including technical certification and testing. Renewals generally follow a shorter timeframe where compliance and reporting have been maintained.

For land-based casino and bingo concessions, timing is determined by the public tender schedule set by the government. The full procedure – from publication of tender documents to the award decision – can extend over six to 12 months, depending on the number of bidders and evaluation complexity.

Online operators must pay application and certification fees to the SRIJ covering the review of documentation, system testing and product homologation. Ongoing supervisory fees apply annually. In addition, licensees must post statutory guarantees, typically comprising a general performance bond securing compliance with legal obligations and player protection; and a separate guarantee securing payment of the IEJO.

For land-based casino and bingo concessions, the public tender documentation defines all financial charges and guarantees. Bidders are required to submit a performance bond – usually a percentage of the concession’s total economic value – to secure investment and social obligations under the contract. Additional fees may apply for participation in the tender and the formalisation of the concession agreement.

Portugal does not impose fixed annual administrative or supervisory fees on licensed operators beyond the initial application and certification charges. After a licence or concession is granted, no recurring regulatory fees are payable to the SRIJ unless the operator introduces new game verticals, additional platforms, or material changes to its certified technical system, each of which requires prior approval and the payment of associated homologation or inspection costs. The same applies for license renewals.

Portugal does not operate a separate personal licensing regime for individual gaming employees. Suitability and integrity are assessed within the broader licensing or concession framework for both land-based and online operations.

For land-based casinos and bingo halls, specific positions ‒ such as casino directors, gaming-floor managers and dealers ‒ must meet suitability and integrity standards defined under Decree-Law No 422/89 and secondary regulations state that individuals with criminal convictions for offences involving dishonesty, fraud, money laundering or related crimes are disqualified from holding such positions. Concessionaires are responsible for verifying that all personnel engaged in gaming operations satisfy these criteria and for reporting relevant changes to the SRIJ.

For online operators, suitability is assessed at the corporate level as part of the licensing process under the RJO. The SRIJ reviews the fitness and propriety of directors, controlling shareholders, senior managers and key function-holders, alongside the applicant’s organisational, technical and financial capacity. While Portuguese law does not prescribe a fixed list of individually licensed roles, applicants must designate responsible persons for certain roles (compliance, technical-system management, etc) in the official application form (pedido de licença/prorrogação). The SRIJ may request evidence of relevant professional experience or qualifications for these functions during licensing or subsequent supervision.

Land-based casino operations in Portugal may only be carried out within the geographic gaming zones established by the State under the Gaming Law and are subject to an exclusive concession awarded by public tender. Each concession authorises the construction, fitting-out and operation of a casino complex within the defined zone, together with the provision of hospitality, entertainment and tourism facilities required under the concession contract.

Casino premises must be approved by the government through the SRIJ, which verifies compliance with technical, architectural and security standards before any gaming activities may commence. Any substantial alteration, expansion or relocation of gaming areas requires prior authorisation. Only the concessionaire may operate the licensed premises, and sub-concessions or transfers are not permitted.

Bingo halls located outside casinos are subject to separate premises licensing, typically granted by the SRIJ under the oversight of local authorities. Authorisations specify the venue, maximum capacity, operating conditions and technical layout of the gaming floor, and are non-transferable without prior regulatory approval.

The operation of gaming premises outside the authorised zones or without a valid concession constitutes a criminal offence under the Portuguese Gaming Law (see 3.6 Penalties for Unlawful Gambling).

Portugal applies a B2C licensing model for all forms of remote gambling and betting regulated under the RJO. Only operators holding a valid licence issued by the SRIJ may offer gambling or betting services to players located in Portuguese territory.

Licences are granted per game vertical – such as games of fortune and chance (casino), fixed-odds sports betting, or bingo – and are valid for three years, renewable upon continued compliance. Applicants must be companies incorporated in Portugal or branches of EU/EEA-incorporated entities registered locally. Each licence authorises the operator to offer games directly to consumers via approved digital platforms and domains connected to an SRIJ-certified technical system.

B2C licensees are responsible for all aspects of the gaming offer, including player registration and verification, AML/KYC compliance, responsible-gambling controls, and data and transaction reporting to the SRIJ. They must also ensure segregation of player funds, transparency of rules and RTPs, and real-time integration with the regulator’s monitoring environment. Bonuses, marketing and advertising must comply with national advertising law and cannot target minors or vulnerable persons.

Operating or promoting B2C gambling services without an SRIJ licence is a criminal offence, subject to fines, licence blocking and other enforcement measures under the RJO.

Portugal does not operate a stand-alone B2B licensing regime for gaming suppliers, aggregators or software providers. However, suppliers providing gaming platforms, RNGs, game content, or related technology to the B2C licensed operators must ensure that their products are certified by testing laboratories recognised by the SRIJ.

Certification is conducted in accordance with the Technical Regulation for Remote Gambling Systems (Regulamento no 903-B/2015), which sets out requirements for system architecture, security, RNG integrity, 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 Portugal 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 components must undergo renewed testing and approval before being placed in production.

Portugal has no stand-alone licensing regime for affiliates. Their activity is regulated indirectly through the advertising and marketing rules that apply to SRIJ-licensed operators. Licensees remain fully responsible 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 prohibited and may result in enforcement or blocking measures by the regulator.

Please see 6.1 B2C Licences and 6.2 B2B Licences (Suppliers, Software, Etc).

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 transparency of play, integrity of random-number generation, traceability of transactions and segregation of player funds. Technical standards further mandate encryption, 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 registry before allowing registration or play and to implement account-based tools for deposit limits, reality checks, timeouts and self-assessment.

Responsible gambling principles are embedded in both the Gaming Law and the RJO. Operators – whether land-based concessionaires or online licensees – must promote safe play, prevent underage and excessive gambling, and ensure access to support mechanisms for problem players.

The SRIJ supervises compliance through mandatory RG policies and real-time data reporting. Online operators must implement a responsible-gaming plan approved by the SRIJ, designate a responsible-gaming officer, display clear warnings and probability information, 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.

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 automatically 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 players showing signs of problematic gambling.

Portugal’s AML regime applicable to gambling is primarily governed by Law No 83/2017, as amended by Law No 99-A/2021 and Law No 58/2020, which transposes the EU’s Fourth and Fifth AML Directives. The Law applies to both land-based and online gambling operators, which are expressly listed as obliged entities under Article 4.

Sector-specific implementation is ensured by the SRIJ, under the oversight of Turismo de Portugal and by the Financial Intelligence Unit (UIF) of the Judicial Police, which receives STRs. Additional provisions in the RJO and Decree-Law No 422/89 complement the AML framework for gaming operators, establishing record-keeping, reporting and customer-identification obligations.

The SRIJ also issues sectoral guidance and circulars setting out practical AML measures for casinos, bingo halls and online operators, covering player verification, internal controls, and STR submission protocols.

Both land-based and online operators must implement a comprehensive AML/CFT compliance programme consistent with Law No 83/2017. Core obligations include:

• CDD – verification of player identity upon registration or entry, before any transaction amounting EUR2,000 or more, or when suspicious circumstances arise;
• enhanced due diligence (EDD) – applied to higher-risk situations, including politically exposed persons (PEPs), cross-border transactions, or atypical betting or gaming patterns;
• ongoing monitoring – review of player activity and payment flows to detect suspicious or inconsistent transactions;
• record-keeping – retention of identification and transaction data for at least seven years;
• internal controls – designation of a compliance officer, staff training, written procedures, and independent audit or review mechanisms; and
• STR – immediate reporting to the UIF/Judicial Police when evidence or suspicion of money laundering or terrorist financing arises.

Operators must integrate these controls into their approved technical and financial systems, enabling the SRIJ to conduct real-time or remote supervision. The regulator may impose administrative sanctions, suspend operations, or revoke licences for serious or repeated breaches.

In practice, Portugal maintains a high-compliance, risk-based AML regime that mirrors the EU framework while adapting to the specificities of casino and online gaming environments.

The advertising of gambling and betting activities in Portugal is overseen by the SRIJ in co-ordination with the Direção-Geral do Consumidor (DGC) and the Regulatory Authority for the Media (ERC). The SRIJ supervises advertising practices of licensed gambling operators and ensures compliance with sector-specific restrictions under the RJO and the Advertising Code.

Under the Advertising Code, advertising is defined as “any form of communication made in connection with a commercial, industrial, craft or professional activity, with the purpose of promoting the supply of goods or services”.

In the gambling context, this encompasses all direct and indirect communications that promote participation in games of fortune or chance, betting or other gambling activities, including digital marketing, sponsorship, and affiliate advertising.

An amendment to the regime is currently under discussion at the Assembly of the Republic (see 1.1 Current Outlook and Recent Changes).

The key legislation governing gambling advertising includes the following.

• Decree-Law No 66/2015 (RJO) – this establishes that only licensed operators may advertise or promote gambling activities in Portugal and prohibits (and criminalises) promotion of unlicensed or foreign operators.
• Decree-Law No 330/90 (Advertising Code) – Article 21 establishes social-responsibility standards and spatial restrictions for gambling advertising.
• Code of Conduct for Advertising of Games and Bets (SRIJ/APAN, 2019) – this constitutes a self-regulatory framework detailing good-practice principles for responsible, transparent and socially acceptable marketing of licensed gambling products.
• Decree-Law No 57/2008 – this addresses unfair commercial practices.
• Law No 37/2007 – this restricts advertising of activities linked to addictive behaviour.

The SRIJ may issue circulars or guidance on permissible advertising content, including responsible-gambling messaging and mandatory disclosures.

Advertising of gambling and betting is restricted to SRIJ-licensed operators and must comply with national advertising and industry-specific standards. Advertising must be truthful, responsible and socially appropriate. Key restrictions include:

• a prohibition on promoting unlicensed gambling, including indirect or affiliate promotion;
• a ban on targeting or featuring minors, and restrictions on advertising within 250 metres of schools or youth facilities, except of games (eg, lotteries) operated by the SCML;
• content limits prohibiting references to gambling as a source of income, success or prestige, or encouragement of excessive play;
• a prohibition on associating gambling operators with loan or credit advertising;
• mandatory display of RG messages and links to the National Self-Exclusion Register (RESP); and
• sponsorships and influencer marketing must comply with the Code of Conduct’s transparency and moderation standards, ensuring that commercial intent is clearly identifiable and messages do not trivialise gambling.

Draft law proposals under discussion aim to tighten advertising restrictions further, extending the ban to digital influencers, indirect references, and contextual marketing perceived as promoting gambling behaviour.

Infringements may lead to administrative or criminal liability. The penalties are as follows.

• Under the Advertising Code, fines range from EUR1,750 to EUR2,500 for natural persons and from to EUR3,500 to EUR45,000 for legal entities.
• The RJO criminalises the illegal promotion of gambling by unlicensed operators, punishable by imprisonment of up to five years or a fine, applying to anyone who promotes unlicensed gambling in Portugal.
• The SRIJ may issue cease-and-desist orders, suspend advertising campaigns or licences, and request blocking of websites or payment channels involved in unlawful promotion.

There are different regimes for the land-based and online gambling, as follows.

Land-Based

Casino and bingo concessions cannot, in principle, be transferred. In addition, the Gaming Law mandates that, at least 60% of the share capital must be in registered shares, allowing identification of all shareholders (with the change of the regime on bearer shares, now effectively all shares must be nominal). Concessionaires must notify the SRIJ of any act or transaction involving the acquisition, transfer or encumbrance of those shares within 30 days of becoming aware of it. Any acquisition of more than 10% of the capital, or any operation that directly or indirectly changes control, requires prior authorisation by the Minister for Tourism. Without such approval, the acquirer cannot exercise voting or economic rights attached to those shares. 

Online

Under Article 21 of the RJO, an online gambling or betting licence may be transferred only with prior authorisation from the SRIJ. 

It is considered, for this purpose, that a transfer of licence occurs whenever, in the case of a restructuring, there is:

• corporate restructuring (merger, demerger, asset contribution or any equivalent transaction) resulting in the licence moving to another entity; or
• any direct or indirect share transfer granting another person a majority of the share capital, more than half of the voting rights, or the ability to appoint most directors.

There are two different regimes for land-based and online gambling.

Land-Based

Under Article 17 of Decree-Law No 422/89, a change of control in a casino or bingo concessionaire occurs whenever there is:

• the acquisition of more than 10% of the share capital or voting rights;
• any direct or indirect transaction resulting in another person or entity obtaining dominant influence or effective control over the concessionaire; or
• the appointment of new directors or managers materially altering the composition of the governing bodies.

All such transactions require prior authorisation from the Minister for Tourism, acting in consultation with the SRIJ. Without prior approval, the acquirer cannot exercise shareholder or voting rights, and the concession may be subject to suspension or termination.

Online

Under Article 21 of the RJO, a change of corporate control constitutes a “transfer of licence” and requires prior authorisation by the SRIJ.

This includes:

• any corporate restructuring (such as a merger, demerger or asset contribution) that results in the transfer of the licence to another entity; or
• any transfer of shareholding, direct or indirect, that grants another person or entity, such as (i) a majority of the share capital, (ii) more than half of the voting rights, or (iii) the power to appoint most members of the board of directors.

Such transactions are treated as equivalent to a transfer of the licence itself. Authorisation must be obtained before completion of the transaction, and the SRIJ may reassess the suitability, integrity and financial capacity of the new controlling shareholders or directors. Unauthorised changes of control are ineffective vis-à-vis the regulator and may result in licence suspension or revocation.

Passive or minority investors are not automatically subject to authorisation provided their participation does not reach the control thresholds (see 10.1 Disclosure Requirements and 10.2 Change of Corporate Control Triggers).

For land-based concessionaires, holdings of up to 10% that do not confer influence generally fall outside prior-approval requirements, though the government or the SRIJ may request disclosure of ownership or funding sources if reputational or compliance concerns arise.

For online operators, the SRIJ may similarly request information on beneficial owners or financing structures whenever a stake, even below control level, could affect the licensee’s suitability, integrity or financial stability.

Any subsequent increase that grants effective control, voting influence or board representation requires prior authorisation before completion, and both regimes allow regulators to reassess the fitness of new shareholders whenever necessary.

The SRIJ exercises comprehensive licensing, supervisory and enforcement powers across both land-based and online gambling.

For online gambling and betting, the SRIJ holds exclusive competence under the RJO to grant, renew, amend, suspend and revoke licences. It homologates technical systems and game types, certifies random-number generators, verifies return-to-player calculations, and conducts both onsite and remote inspections. The SRIJ may also suspend games, functionalities or systems, impose corrective measures, and initiate administrative offence proceedings.

For land-based operations, including casinos and bingo halls, the SRIJ supervises concession performance and ensures compliance with the legal and contractual framework under the Gaming Law. Sanctioning powers are exercised in co-ordination with the Minister of Finance and the Minister for Tourism, who formally authorise or terminate concessions.

Criminal enforcement of gambling-related offences – such as unlicensed operation, illegal promotion or fraudulent manipulation – falls under the jurisdiction of the Ministério Público, with investigation conducted by the Polícia Judiciária, which maintains specialised units for gaming and cybercrime. The SRIJ reports or refers suspected criminal conduct for prosecutorial action.

Decisions of the SRIJ are subject to judicial appeal before the Administrative Courts.

The SRIJ co-operates closely with the Ministério Público, Polícia Judiciária, the Tax and Customs Authority, and the Bank of Portugal, particularly on AML/CFT enforcement and cross-border payment monitoring. It also exchanges information with EU and EEA regulators under mutual-assistance arrangements, and participates in regional and international working groups on responsible gambling and illegal-operator deterrence.

Portugal’s enforcement system combines administrative, contractual, and criminal sanctions.

For administrative breaches, the SRIJ may impose warnings, fines, suspension, revocation, or mandatory remedial actions.

Under the Gaming Law, concessionaires may face suspension or termination for violations of legal, contractual, AML or responsible-gambling obligations.

Under the RJO, the SRIJ may suspend individual games or entire platforms, revoke or suspend licences, or impose corrective measures for repeated or serious non-compliance.

Criminal offences, prosecuted by the Ministério Público, include:

• the operation or promotion of unlicensed gambling (punishable by imprisonment of up to five years or fine);
• fraudulent manipulation of games or bets; and
• participation or facilitation of unauthorised gambling activities.

Convictions may lead to confiscation of proceeds, closure of facilities, and disqualification from future licensing.

The SRIJ regularly publishes enforcement summaries detailing illegal-site blocking, unauthorised advertising, and compliance penalties, reflecting a consistent supervisory record.

Administrative fines are determined in accordance with the General Regime of Administrative Offences (Decree-Law No 433/82), taking into account the gravity, recurrence, culpability, and economic benefit derived from the infringement.

• Under the Gaming Law (Decree-Law No 422/89), fines range from EUR2,500 to EUR100,000, depending on the seriousness of the offence.
• Under the RJO, fines for very serious breaches may reach EUR1 million, and may be accompanied by suspension or revocation of the licence.

Administrative penalties are enforceable through administrative execution procedures, and failure to pay may result in non-renewal or suspension of the authorisation.

Criminal fines (in lieu of imprisonment) are applied through the Penal Procedure Code and enforced judicially following conviction.

Portugal applies distinct fiscal regimes to land-based concessions and online operators, combining special gaming taxes with corporate and social-fund obligations.

Land-Based

Casino operations function under a concession-specific fiscal model comprising:

• an upfront entry contribution, payable at the signing or renewal of the concession;
• an annual fixed contribution, representing a base fee linked to zone, property scale, and minimum investment commitments; and
• an annual variable contribution, calculated as a percentage of GGR generated during the concession year.

The precise structure is defined in each concession contract and varies across gaming zones (Estoril, Espinho, Póvoa de Varzim, Algarve, Figueira da Foz, Tróia, etc).

Depending on zone and revenue tier, the effective burden (fixed + variable) may range from 20% up to approximately 50% of GGR.

The 2025 tenders for the Espinho, Algarve and Póvoa de Varzim zones confirmed the continuation of this model, adjusting fixed and variable components to reflect tourism-investment, employment and social-development commitments.

Concessionaires may also make annual social and tourism contributions, channelled to local cultural and tourism projects.

Under the concession system, the government may authorise partial deductions or reductions of the variable component where operators invest directly in approved non-gaming facilities or community programmes.

These adjustments are verified by SRIJ. Certain tourism-fund payments may likewise be offset against qualifying cultural or infrastructure expenditures.

Bingo concessionaires are subject to stamp duty of 25% on each card sold.

Online

Under the RJO, licensed operators are liable for the IEJO, distinct from corporate taxation. The IEJO applies as follows:

• games of fortune and chance (eg, slots, roulette, blackjack, poker) ‒ 25% of GGR;
• fixed-odds sports and horse betting ‒ 8% on turnover;
• pari-mutuel horse betting ‒ 25% of GGR; and
• peer-to-peer poker and bingo tournaments ‒ 25% on rake or entry fees.

The IEJO is reported and remitted monthly through the SRIJ’s real-time monitoring system.