4H AGENCY
This market overview was prepared by Ivan Kurochkin, Head of Eastern Europe Desk, Partner and one of the founders of 4H Agency.
After 10+ years’ experience in consulting every type of clients from the testing laboratories to global operators and B2B providers on a variety of matters related to the gambling operations, Ivan has proven himself to be a business- oriented
2018; no new application window has been opened since.
Main regulatory costs include: u
u u u u u
US$11,200 – application fee for each General or Specific License
US$ 2,800 – registration in the General Gambling License Register
Minimum ~USD 42,500 – technical conformity assessment
Minimum ~USD 5,600 – mandatory inspection / technical verification
0.075% of gross operating revenue – annual regulatory fee
u
US$ 112 – occasional-game authorisation
During the initial period of operation, operators must also provide a guarantee of US$2,2M per General License, reduced to US$560,000 for contests. After the initial period, the minimum guarantee is generally US$1,1M, or US$280,000 where the operator holds only a contest license.
KEY ADVERTISING RESTRICTIONS
Gambling advertising in Spain is subject to strict channel, timing and content restrictions. Key rules include:
u u
Advertising is permitted only for licensed gambling activities
Ads must be clearly identifiable, non- misleading and must not present
u u u
gambling as a solution to financial or personal problems or encourage excessive play
Audiovisual gambling advertising is generally restricted to 01:00–05:00
Sponsorship cannot target minors, be used in team or competition names, or appear on sports shirts and playing kits
Direct marketing by email or similar channels requires prior consent; postal gambling advertising is prohibited
u
Social media advertising must include safeguards against exposure to minors and allow users to block or hide ads
Promotions must clearly disclose material conditions and must not target self-excluded or otherwise prohibited players
u
Operators remain responsible for compliance when using affiliates, agencies and other advertising intermediaries
Several broader restrictions, including certain rules on bonuses, targeting and celebrity advertising, were annulled by the Supreme Court in 2024 and are no longer generally applicable.
LOCAL MARKET SPECIFICS
Spain remains effectively closed to new B2C licensees outside a formal licensing call. General online gambling licenses are
issued only during application windows opened by the DGOJ. Te latest call was launched in 2017 and closed in December 2018, and no new window has been opened since.
Tis means that a new operator cannot enter the market simply by satisfying the licensing requirements and submitting an application. Market access depends on a separate decision by the regulator to open a new licensing procedure, which significantly limits the number of potential new entrants.
At the same time, new brands can still enter Spain through the existing licensed market structure. Te main routes include:
u Acquisition of a licensed company u
Launch of a new brand under an existing licensed operator
u Partnership with an existing licensee u
Corporate restructuring involving an existing license
For an international operator, M&A or partnership with an existing licensee is therefore generally more realistic than waiting for a new licensing window. However, licenses cannot be freely sold or transferred independently from the licensed business, and material changes to the corporate structure or operating model remain subject to DGOJ oversight.
multi-jurisdictional advisor for entering new markets across the globe. His background helps him to choose the best and most efficient scenarios for expansion to new market or for bringing existing operations of the Agency’s clients to a significantly new level.
If you are considering venturing into the markets of CIS countries or seeking expert advice on navigating the complexities of the gambling industry, Ivan is the go-to person. Take action now and reach out to Ivan to explore how 4H Agency can support your endeavours in the vibrant and evolving landscape of the CIS region.
4H Agency is a global gambling advisory. We provide expert guidance to B2C operators and B2B providers, spanning market insights, payments, product localisation, regulations, licensing, public affairs, and more.
ik@4h.agency
t.me/Ivan_Kurochkin https://4h.agency
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