Master, Adjust, Prevail:The Proposed Amendments to the Regulatory Framework for Online Gambling Advertising

All available data indicates the online gambling market continues to grow exponentially. According to Turismo de Portugal, I.P., between April and June 2025, online gambling generated €287 million in gross revenue for the 17 entities licensed to operate in this sector in Portugal. This amount represents a growth of 9.6% compared to the same quarter last year. The highest growth among new user registrations was verified in the 18-24 age group (young adults).

Some of this turnover has been linked to advertising on digital platforms and online gaming applications. On September 16^th, 2025, however, five bills were submitted to the Portuguese national Parliament for consideration, associating this activity with risks of addiction and prodigality (Bill 222/XVII/1). These propose profound changes to the regulatory ecosystem of the gaming sector – specifically, advertising for online gambling.

Online gambling is regulated by Decree-Law No. 66/2015 of April 29, which sets out the procedure and requirements for licensing the provision of online gambling platforms, in conjunction with the Advertising Code, which has specific rules on advertising gambling. Amendments have been proposed to these two pieces of legislation, containing measures aimed at professionals in the sector and the Government itself, who is expected to create a National Program for Non-Substance Addictive Behaviors (Bill 223/XVII/1).

Among the more numerous measures aimed at professionals in the sector, the following stand out:

• The creation of an obligation to strengthen self-exclusion mechanisms on all licensed online gaming and betting platforms (Bill 218/XVII/1), and
• The introduction of the following advertising restrictions:
  • Gambling and betting (newly proposed concept covering all games where the result is wholly or fundamentally dependent on luck) may not be advertised outside of the physical establishments and/or digital websites, platforms or pages where gambling is licensed to occur;
  • Advertising of gambling featuring public figures and digital influencers (Bill 219/XVII/1) is to be restricted, and
  • Sponsorship of events and competitions by entities that operate gambling platforms is likewise to be restricted (Bill 220/XVII/1).

These obligations will be accompanied by the mandatory inclusion of warnings about the potential development of addiction in all gambling advertising (Bill 222/XVII/1).

Although the legislative process is still in its early stages, it is already clear that, if the amendments contained in these Bills are approved, online gambling platform operators will face greater risks when they seek to use well-known public figures, whether from television or digital media, to convey their advertising messages or sponsor events, teams, or other forms of entertainment. Although there is still no certainty about the scope of the practices that these proposals seek to prohibit, the possibility of administrative offenses should be considered.

Given the above risks, it is advisable to consider these upcoming changes in advertising projects.