APAJO urges Portugal to reform online gambling rules and expand offerings

The Portuguese Association of Online Betting and Gaming (APAJO) has submitted a package of legislative proposals to Portugal's Gaming Regulation and Inspection Service (SRIJ) and the Government, calling for targeted changes to the country's online gambling framework. The proposals focus on strengthening the regulated market while addressing enforcement challenges and responsible gambling priorities.

APAJO represents companies operating within Portugal's licensed online betting and gaming sector. According to the association, its proposals are structured around four broad areas: combating illegal operators, reviewing and expanding the products that can be offered legally, improving licensing and operating conditions and reinforcing responsible gambling measures.

The submission comes as Portuguese authorities consider further changes to the rules governing digital gambling. The timing is significant because the Government has already indicated that it intends to introduce new legislation affecting online gambling in Portugal.

Four areas form the basis of the proposal

A central element of the APAJO package is a stronger response to illegal online gambling. The association has argued that licensed operators face a competitive disadvantage when consumers can access unauthorized platforms that are outside the Portuguese regulatory framework.

The proposed measures therefore seek greater cooperation between the authorities and digital intermediaries. APAJO has highlighted cooperation with telecommunications operators and search engines as one potential way to improve the identification and disruption of illegal gambling activity.

The association's position places market enforcement alongside consumer protection. The underlying objective is to increase the attractiveness and competitiveness of the regulated market while limiting access to services that do not operate under Portugal's licensing requirements.

APAJO also wants the legal product framework to evolve in response to changes in consumer demand and developments elsewhere in regulated gambling markets.

Regulated live casino among key priorities

One of the most notable proposals concerns the introduction of regulated live casino in Portugal. Live casino products combine online betting interfaces with live dealer games and have become an established part of regulated markets in several jurisdictions.

APAJO's proposal seeks to bring this form of gaming within Portugal's licensed framework. The association has also called for the expansion of betting options available to licensed operators, arguing that a broader regulated product range could help improve the ability of the legal market to compete for consumers.

Any such changes would remain subject to legislative and regulatory approval. The proposal itself does not alter Portugal's existing rules and should therefore be viewed as part of an industry submission to policymakers rather than as a change to the law.

The distinction is important because the introduction of additional products would require appropriate safeguards covering licensing, technical standards, player protection, monitoring and compliance.

Operators could receive broader intervention powers

Another area highlighted by APAJO concerns the ability of licensed operators to intervene when they identify potentially problematic activity.

The proposals refer to situations involving money laundering, fraud, match-fixing, collusion and problem gambling. APAJO is seeking a framework that would provide operators with greater ability to take action when indicators of such activity are identified.

The issue raises both regulatory and practical considerations. Operators already operate under compliance obligations, but an expanded intervention framework would need to establish clear responsibilities, appropriate thresholds and safeguards for customers.

A rules-based approach could also help establish greater consistency across the regulated market. From a legal and regulatory perspective, the effectiveness of any new powers would depend on clearly defined procedures and appropriate oversight by the competent authorities.

Illegal gambling remains a major concern

The issue of unauthorized gambling has become an increasingly important part of Portugal's regulatory debate.

Recent enforcement data indicate that SRIJ has issued 1,834 closure notices concerning illegal online gambling operations since the country's online gambling licensing framework was introduced in 2015. The figures, covering more than a decade of enforcement activity, illustrate the continuing scale of the challenge.

The same cumulative enforcement record includes 77 notifications to the Public Prosecutor's Office. These figures indicate that Portugal's approach to illegal gambling involves both regulatory intervention and referrals where matters may warrant further attention under the applicable legal framework.

The continued focus on illegal operators is also linked to the competitiveness of the regulated market. Licensed businesses operate under taxation, compliance, technical and consumer protection requirements. Unauthorized services do not operate under the same domestic licensing conditions.

APAJO's proposal to improve cooperation with telecommunications companies and search engines is therefore aimed at strengthening the mechanisms available to authorities when dealing with unlicensed gambling services.

Government prepares wider legislative review

The proposals arrive after Economy Minister Manuel Castro Almeida indicated that the Portuguese Government would introduce new online gambling legislation during the summer.

Castro Almeida has described the size of the sector as a reason for updating the framework. He said Portugal's online gambling market is worth around €24 billion annually and suggested that the illegal market could potentially be of a comparable scale.

These figures should be understood as estimates cited by the Minister rather than as equivalent measures of regulated gambling revenue. Portugal's official regulatory statistics track licensed market activity using specific measures such as stakes, gross gaming revenue and taxation.

The Government has also emphasized the need for stronger prevention measures and greater public awareness surrounding the risks associated with illegal gambling. That approach overlaps with APAJO's stated objectives around responsible gambling and the protection of consumers using regulated services.

Responsible gambling remains part of the proposed reforms

While enforcement and product expansion are prominent elements of the package, APAJO has also included responsible gambling among its four main policy pillars.

The association has previously promoted responsible gambling initiatives aimed at encouraging consumers to use licensed services and make use of available protection tools. Its proposals for legislative reform therefore seek to place market development alongside player safeguards.

This balance could become particularly important if the range of regulated products is expanded. New forms of gaming would require an appropriate regulatory structure covering player identification, limits, monitoring and intervention procedures.

Portugal already maintains a regulated framework under which licensed operators are overseen by SRIJ. Any legislative update will need to consider how new products and enforcement mechanisms can be incorporated without weakening existing consumer protections.

What the proposals could mean for Portugal

The APAJO submission does not itself change Portugal's gambling laws. Instead, it puts forward a set of recommendations for consideration by SRIJ and the Government as policymakers assess possible reforms.

The next stage will depend on the Government's legislative process and any subsequent regulatory measures adopted by the competent authorities. Proposals relating to live casino, expanded betting options and stronger enforcement powers would require detailed rules before they could become operational.

For licensed operators, however, the direction of the debate is already significant. A broader product framework could create additional commercial opportunities while stronger enforcement against unauthorized services could help improve the position of regulated businesses.

For consumers, the principal issue is whether changes to the framework can combine greater choice with effective safeguards. A market that offers products aligned with consumer expectations while maintaining strong licensing and responsible gambling requirements could potentially improve channelisation towards regulated services.

Conclusion

APAJO's legislative package places Portugal's online gambling framework at the centre of a broader discussion about regulation, enforcement and market development. Its proposals seek to address several issues simultaneously, from the expansion of regulated products to stronger action against unauthorized gambling and enhanced responsible gambling protections.

The proposed introduction of regulated live casino is particularly notable, but the wider package is broader than any single product. APAJO is also calling for improved operating conditions and clearer mechanisms for intervention when operators identify risks linked to fraud, money laundering, match-fixing, collusion or problem gambling.

With the Portuguese Government already considering new legislation, the industry's recommendations could form part of an important policy debate. Ultimately, any reform will need to reconcile consumer demand, regulatory oversight, market competitiveness and public protection.

The priority will be ensuring that any modernization of the framework is accompanied by clear legal standards and effective enforcement. That combination will be crucial if Portugal is to strengthen its regulated online gambling market while continuing to limit the influence of unauthorized operators.

FAQs

What is APAJO?
APAJO is the Portuguese Association of Online Betting and Gaming, a non-profit organization representing companies operating legally in Portugal's online betting and gaming sector.

What has APAJO submitted to the Portuguese authorities?
APAJO has submitted a package of legislative proposals to SRIJ and the Government covering illegal gambling, product expansion, licensing and operating conditions as well as responsible gambling.

What is APAJO proposing for live casino?
APAJO is advocating for the introduction of regulated live casino within Portugal's licensed online gambling framework.

Does APAJO want more betting options?
Yes. The proposals include expanding the range of betting options that licensed operators can offer within the Portuguese market.

What does APAJO propose regarding illegal gambling?
APAJO wants stronger measures to combat illegal operators, including greater cooperation between authorities, telecommunications companies and search engines.

Could operators receive greater intervention powers?
APAJO is proposing greater ability for operators to intervene when they identify concerns involving areas such as money laundering, fraud, match-fixing, collusion or problem gambling.

How many closure notices has SRIJ issued?
SRIJ has issued 1,834 closure notices concerning illegal online gambling operations since Portugal established its online gambling licensing framework in 2015.

How many cases were notified to the Public Prosecutor's Office?
The enforcement data cited in connection with the latest report record 77 notifications to the Public Prosecutor's Office during the period covered.

Who regulates online gambling in Portugal?
The Gaming Regulation and Inspection Service, known as SRIJ, is responsible for regulating and inspecting online gambling and betting in Portugal.

Will APAJO's proposals automatically become law?
No. The proposals are recommendations submitted for consideration by the Portuguese authorities. Any changes to the legal framework would require the appropriate legislative and regulatory process.