Spain’s gambling regulator is weighing a reform that would extend legal obligations beyond licensed operators to the software firms, aggregators and compliance vendors that sit behind them. The Dirección General de Ordenación del Juego (DGOJ) opened a public consultation on modifying Law 13/2011 on 18 May 2026, and among the measures under study is bringing technology providers inside the regulated perimeter for the first time in the law’s 15-year history.
The consultation closed on 22 June and drew more than 50 submissions. On 21 July the DGOJ began a round of meetings with the entities that responded, starting with digital gambling association Jdigital, followed by land-based associations on 23 July and LaLiga on 28 July. The regulator has said the dialogue will continue through September before it drafts an articulated text, which then goes to a further public information and hearing phase.
What the reform would change
Under the current framework, the obligated party is the licence holder. The reform being studied would extend part of that responsibility to the technical layer: game developers who build and certify the titles, platform aggregators that connect a single operator to dozens of content catalogues and payment providers through one integration, and compliance vendors supplying identity verification, deposit-limit enforcement and regulatory reporting.
The reasoning is a supply-chain one. Unlicensed operators reaching Spanish users are typically incorporated outside the European Union and difficult to pursue directly. The firms supplying their software and integrations are often based in cooperating jurisdictions, hold licences elsewhere, and have commercial relationships they cannot afford to lose. Making them accountable gives the DGOJ enforcement reach it does not currently have. Spain has applied similar logic before, most recently when it moved against prediction-market platforms, and the same approach has been used in payments and digital advertising.
A market that outgrew its law
The figures behind the reform are substantial. Spanish licensed online gambling produced €1,700.55 million in gross gaming revenue (GGR) in 2025, up 16.99% year on year, according to the DGOJ’s annual report. Active users reached 2,157,514, with the monthly active account base close to 1.73 million.
Online casino accounted for €893 million, or 52.51% of total GGR, ahead of sports betting at €698.13 million (41.05%). Poker contributed €95.48 million and bingo €13.94 million. Deposits reached €4.32246 billion against withdrawals of €3.01363 billion. Marketing spend rose 25.84% to €664.40 million, a number that helps explain why advertising sits high on the reform agenda. The casino-led composition of the market has been consistent through recent quarters, as Q3 2025 data showed.
Spain’s Online Gambling Market Hits €405M GGR in Q3 2025 as Casino Dominance Grows
The rest of the package
Technology providers are one item among several. The DGOJ has said the reform will address the use of celebrities and influencers in gambling advertising, promotional offers used to acquire customers, and organic search advertising, with the stated aim that operator advertising pages surface only where a search relates directly to betting.
Other measures include strengthening identity verification and payment controls to prevent identity fraud and access by minors, and expanding the tools available against illegal gambling. A joint deposit limits system, designed to stop players evading restrictions by moving between platforms, was approved by the government in June and drew immediate concern from Jdigital.
Separately, the Ministry of Social Rights, Consumption and Agenda 2030 has developed an algorithm for early detection of problem gambling, built on real microdata and mandatory for all licensed operators. The DGOJ estimates it could raise current detection rates by 10 percentage points. Gambling advertising will also carry risk warnings formatted in the style of tobacco packaging, including the statement that the probability of being a player who loses money is 75%.
Why offshore licensing is part of the picture
Compliance costs in Spain are already high relative to alternatives. Licensed operators pay 20% of GGR in gambling tax, plus licence fees, mandatory technical reports and external audits, alongside obligations under Law 10/2010 on money laundering prevention, which lists online operators as obligated subjects.
Against that, offshore jurisdictions compete on speed and cost. The Anjouan licence, issued by the Anjouan Offshore Finance Authority in the Union of the Comoros, covers casino, sportsbook, poker and B2B activity under a single permit, applies no GGR tax, and is typically granted in four to six weeks for a regulator fee of roughly €17,000. Its terms exclude a defined list of territories, and Spain is on that list, alongside the UK, France, Germany, the Netherlands, Austria, Australia and the United States. An Anjouan licence therefore confers no right to serve Spanish players. The DGOJ’s proposal would give it a way to act against the firms supplying platforms that do. The jurisdiction’s reputational weight has already been tested in Europe, as FDJ found when its subsidiary Relax Gaming obtained a Comoros licence.
What happens next
No draft text exists yet. The DGOJ has to finish its stakeholder meetings, publish an articulated bill, run a second consultation, and then take the text through parliament, a process that will run well beyond 2026. B2B suppliers serving the Spanish market have that window to shape the definition of what counts as a regulated provider and what reporting it triggers. Spain is not alone: Greece opened its own consultation on a reform bill targeting the black market in June. If Spain’s version passes with the scope currently under discussion, it would be one of the first European frameworks to hold the technical supply chain to the same standard as the licence holder.
Source: Dirección General de Ordenación del Juego
