posted 2 months ago
Last updated: 27 May 2026
Portugal’s online gambling advertising rules have shifted materially in 2026, driven by amendments to Article 21 of the Advertising Code, an active parliamentary debate on the proposed Article 21‑B near-ban, and the launch of the SRIJ’s centralised self-exclusion portal on 8 April 2026. For licensed operators, affiliates and their counsel, these changes create immediate compliance obligations across ad copy, bonus promotions, sponsorship agreements and influencer campaigns. This guide sets out the current legal framework under the Regime Jurídico do Jogo Online (RJO), established by Decree-Law No. 66/2015, and translates each rule into an actionable operator checklist.
Yes. Online gambling and sports betting are fully legal and regulated in Portugal. The RJO, enacted through Decree-Law No. 66/2015 and subsequently amended, provides the licensing framework administered by the Serviço de Regulação e Inspeção de Jogos (SRIJ), a department of Turismo de Portugal. Only operators holding a valid SRIJ licence may lawfully offer online gambling or betting services to consumers located in Portuguese territory. Gambling advertising in Portugal is permitted but strictly conditioned: all promotional activity must comply with Article 21 of the Advertising Code (Decreto-Lei No. 330/90, as amended) and with any additional guidance issued by SRIJ.
Operators considering how to get a gaming licence in Portugal should treat advertising compliance as integral to the licensing process itself, because SRIJ evaluates marketing plans as part of the application and ongoing supervision cycle.
The Advertising Code’s Article 21 has long governed gambling advertising in Portugal, but 2025–2026 brought the most significant tightening since the RJO’s original enactment. The Portuguese parliament debated a draft Article 21‑B that would establish a general prohibition on “all forms of advertising” for gambling and betting, explicitly capturing hidden, indirect and digital promotional activity. While the full near-ban under Article 21‑B remained under parliamentary consideration as of May 2026, the debate itself prompted SRIJ to intensify enforcement of the existing Article 21 framework and to issue supplementary guidance ahead of any final legislative vote.
| Date | Instrument | Practical Effect for Operators |
|---|---|---|
| September 2015 | Decree-Law No. 66/2015 (RJO enacted) | Established legal framework for online gambling licensing, including advertising provisions via amended Advertising Code. |
| October 2025 | Parliamentary debate on Article 21‑B draft | Proposed general prohibition on all forms of gambling advertising; triggered industry-wide compliance reviews. |
| Q1 2026 | Article 21 amendments effective | Tightened responsible-gambling messaging requirements, restricted bonus promotion language and expanded disclosure obligations. |
| 8 April 2026 | SRIJ centralised self-exclusion portal goes live | Operators required to integrate portal queries into registration, deposit and ad-targeting workflows. |
| Rule Area | 2025 Position | 2026 Position (Operator Impact) |
|---|---|---|
| Responsible-gambling messaging | Required in advertisements; format at operator discretion | Prescribed wording, minimum font size and screen-time percentage mandated by SRIJ guidance |
| Bonus and promotion language | Wagering requirements must be disclosed; limited restrictions on creative phrasing | Prohibition on language implying “risk-free” play; all material terms must appear in the primary ad unit, not solely in T&Cs |
| Influencer and hidden advertising | General Advertising Code transparency rules applied | Explicit capture of influencer posts and affiliate content under Article 21 scope; operator held primarily liable |
| Self-exclusion cross-referencing | Operator-level self-exclusion register | Mandatory integration with SRIJ centralised portal; ads must not be served to self-excluded individuals where technically feasible |
Industry observers expect that if Article 21‑B is enacted in its draft form, the likely practical effect will be to restrict gambling advertising to operator-owned channels and eliminate most third-party promotional activity, a model similar to measures already adopted in Italy and Belgium.
A critical feature of the Portuguese framework is that SRIJ holds the licensed operator, not the affiliate, influencer or media buyer, primarily responsible for any non-compliant advertising delivered to Portuguese consumers. This principle, confirmed in SRIJ supervisory practice and reflected in the RJO’s licensing conditions, means operators must build compliance into every stage of their marketing supply chain.
| Entity | Obligations (Advertising & Compliance) | Typical SRIJ Exposure |
|---|---|---|
| Licensed operator | Ensure all ads (direct and via affiliates) comply with Article 21 and SRIJ guidance; integrate self-exclusion portal checks; maintain records of targeting parameters and creatives for SRIJ audit | High, primary liability for all advertising to Portuguese consumers |
| Affiliate / publisher | Implement geo-blocking to exclude non-licensed jurisdictions; display operator-mandated responsible-gambling messaging; pass through self-exclusion status where technically feasible | Medium, secondary liability; SRIJ enforcement targets the operator first, but affiliates face contractual exposure and potential sanctions |
| Sponsor / influencer | Clear disclosure of paid promotion; age gating on social platforms; provide contractual compliance assurances to the operator | Medium, potential administrative sanctions plus significant reputational risk |
Operators entering the Portuguese market via white-label arrangements should note that the white-label provider’s advertising conduct is equally attributable to the licence-holder. Comparative licensing obligations in other jurisdictions are explored in our overview of the top 10 jurisdictions to launch a licensed gambling business.
SRIJ’s regulatory posture has moved decisively from principles-based oversight to prescriptive controls. The centrepiece of this shift is the centralised self-exclusion portal for online gambling in Portugal, which went live on 8 April 2026. All licensed operators are required to query this portal in real time and to suppress advertising delivery, account registration and deposit functionality for any individual who appears on the register.
Operators must address the following integration points to meet responsible gambling requirements in Portugal:
Every advertisement for online gambling or online sports betting in Portugal must include a responsible-gambling message. Under the 2026 guidance, the message must:
The practical application of Portugal’s online gambling advertising rules to bonus promotions and campaign targeting is where most operators face compliance gaps. The 2026 amendments to Article 21 impose clear guardrails on what can be promoted and how.
Every bonus or promotional offer advertised to Portuguese consumers must include the following elements within the primary ad unit itself, not solely behind a click-through to terms and conditions:
Operators running paid campaigns on Google or Meta platforms face a dual compliance layer: the platform’s own restricted-advertising policies (which require proof of a valid local licence before gambling ads are approved for the Portuguese market) and the overlay of Article 21 requirements. Key considerations include:
Note on taxation: gambling winnings in Portugal are subject to a special gambling tax (Imposto Especial de Jogo) levied on the operator, not the player. However, advertising must not use simplified “tax-free” claims without accurate qualification, see FAQ below for detail.
Sponsorship deals, particularly in football and other professional sports, represent a significant channel for gambling brand visibility in Portugal. The 2026 tightening of the online gambling advertising rules in Portugal applies to in-venue signage, broadcast overlay graphics, influencer posts and affiliate websites equally.
Operators engaging influencers for Portuguese-facing campaigns should ensure every contract includes provisions addressing:
Sample clause: “The Influencer shall include in every Promotional Item: (a) the Prescribed Responsible-Gambling Message in Portuguese; (b) a direct hyperlink to the SRIJ self-exclusion portal; (c) clear disclosure of the commercial relationship using #ad or equivalent; and (d) the statement ’18+ only.’ The Operator reserves the right to require removal of any Promotional Item within 2 hours of notice.”
For online sports betting in Portugal, sponsorship signage at stadiums, on kits and during broadcasts must comply with Article 21 in the same way as digital advertising. The responsible-gambling message must appear alongside the brand name wherever technically feasible. Early indications suggest SRIJ is paying particular attention to broadcast-overlay graphics during live football transmissions, where gambling brand logos frequently appear without any accompanying responsible-gambling text. Operators considering the costs of market entry should review our guide on how to start your own online casino for a broader cost framework.
SRIJ enforces the advertising provisions of the RJO and the Advertising Code through administrative proceedings that can result in substantial fines, licence conditions, public warnings and, in severe cases, licence suspension or revocation. The RJO empowers SRIJ to order the immediate removal of non-compliant advertising and to instruct internet service providers to block access to unlicensed gambling websites.
| Breach Type | Possible SRIJ Sanction | Practical Remediation Steps |
|---|---|---|
| Missing or inadequate responsible-gambling messaging | Administrative fine; formal warning; order to amend or withdraw ad | Audit all active creatives; insert prescribed messaging; re-submit to platforms |
| Advertising to minors or failure to age-gate | Substantial fine; potential licence conditions; public notice | Implement 18+ audience targeting across all channels; add age-verification interstitial |
| Failure to integrate self-exclusion portal | Compliance order; escalating fines; potential licence suspension | Complete technical integration; run test queries; document compliance for SRIJ audit |
| Misleading bonus claims (“risk-free,” undisclosed wagering terms) | Administrative fine; order to withdraw promotion; public warning | Revise ad copy to include all material terms; retrain marketing team on disclosure rules |
| Unlicensed advertising (ads by operators without SRIJ licence) | ISP blocking order; criminal referral possible; substantial fines | Cease all Portugal-facing advertising immediately; apply for SRIJ licence or withdraw from market |
Operators who receive a formal SRIJ notice should follow a structured remediation playbook:
For broader context on licensing enforcement across jurisdictions, operators may find our guides to crypto casino licenses and Curaçao gambling licences useful comparisons.
Operators active in the Portuguese market, or planning market entry, should take the following steps without delay:
The 2026 changes to Portugal’s online gambling advertising rules demand immediate action from every licensed operator, affiliate and marketing partner active in the market. Audit live campaigns now, integrate the SRIJ self-exclusion portal, revise influencer and sponsorship contracts, and ensure every ad unit carries the prescribed responsible-gambling messaging. Operators seeking tailored compliance support should consult experienced Portuguese regulatory counsel.
This article was produced by Global Law Experts. For specialist advice on this topic, contact Luis Portela De Carvalho at LEKTOU, a member of the Global Law Experts network.
posted 2 weeks ago
Find the right Legal Expert for your business
Sign up for the latest advisor briefings and news within Global Advisory Experts’ community, as well as a whole host of features, editorial and conference updates direct to your email inbox.
Naturally you can unsubscribe at any time.
Global Advisory Experts is dedicated to providing exceptional advisory services to clients around the world. With a vast network of highly skilled and experienced advisors, we are committed to delivering innovative and tailored solutions to meet the diverse needs of our clients in various jurisdictions.
