Spain Gambling License

Can you apply for a Spanish gambling licence today?

No. Spain grants General Licences only through a convocatoria, a public tender opened by the ministry that oversees gambling. Three tenders have ever run. The last closed at 13:00 on 17 December 2018, and the DGOJ still describes it as the most recent one held. No new tender has been announced.

The legal basis is Article 10(1) of Ley 13/2011, the Spanish Gambling Act. That article reserves General Licences to a competitive procedure. The procedure runs on a pliego de bases, the tender rules that a ministerial order approves and the Boletín Oficial del Estado publishes.

Three orders have opened that procedure: Orden EHA/3124/2011, Orden HAP/1995/2014 of 29 October, and Orden HFP/1227/2017, de 5 de diciembre. Across all three the DGOJ granted 172 General Licences. The 2017 order was published on 16 December 2017 and gave applicants one year, so the window closed on 17 December 2018.

Note the dates carefully. 17 December 2018 is the closing date of the last tender, not the date it opened.

Can an operator ask the DGOJ to open a new tender?

Yes, and the mechanism sits in the regulation. Article 15 of Real Decreto 1614/2011 lets any interested party request a new tender for a specific game modality, the statutory term for a vertical. The condition is timing: at least 18 months must have passed since the previous tender for that same modality.

The DGOJ then has six months to promote the tender. A refusal has to be reasoned, and only three grounds count: protection of minors, prevention of gambling addiction, and protection of players. A refusal restarts the 18-month clock from the date of that decision.

If the regulator does promote the tender, it sends a reasoned proposal and draft tender rules to the ministry. The ministry has three months to reject the proposal or publish the tender. Silence counts as acceptance, and the tender must then be published within a further three months.

The mechanism has worked in practice. The preamble to Orden HFP/1227/2017 records that the 2017 tender followed "diversas solicitudes formales de apertura del mercado de juego online" received from different entities.

So the door exists. It opens on a regulator's decision rather than on an application, and it has not opened since 2018.

What is a Spanish gambling licence?

A Spanish gambling licence is state authorisation to offer online betting or gaming to players in Spain. The authorisation comes in two tiers. A licencia general covers a whole category of games and runs for ten years. A licencia singular covers one vertical inside that category. An operator needs both before accepting a single wager.

Ley 13/2011 de regulación del juego is the statute. Real Decreto 1613/2011 sets the technical requirements for gaming systems. Real Decreto 1614/2011 governs licences, authorisations and registries, and it is the act the 2026 reform amends.

Two Spanish terms recur through the process. A convocatoria is the tender that opens General Licences. A pliego de bases is the set of rules governing that tender.

Who is the DGOJ and what does it regulate?

The Dirección General de Ordenación del Juego (DGOJ) is Spain's national online gambling regulator. The regulator now sits inside the Ministry of Social Rights, Consumer Affairs and the 2030 Agenda, after earlier spells under two other ministries. The DGOJ grants both licence tiers, homologates gaming systems, keeps the public registers and imposes sanctions.

Mikel Arana Etxezarreta is the DGOJ director general. The minister responsible is Pablo Bustinduy, who heads the Ministry of Social Rights, Consumer Affairs and the 2030 Agenda.

Four other bodies touch a Spanish gambling operation, and they are easy to confuse with the regulator.

• The Agencia Tributaria collects the gambling tax.

• SEPBLAC supervises anti-money-laundering compliance.

• Audiovisual media services, which carry a share of gambling advertising, fall to the CNMC.

• The autonomous communities license land-based gambling. Online gambling is a state matter, so an online licence comes from the DGOJ and never from a regional government.

Two DGOJ registers matter to a buyer. The Registro Público de Operadores Autorizados lists every authorised operator. The Registro General de Interdicciones de Acceso al Juego (RGIAJ) lists every banned and self-excluded player, and operators must check it.

What licences do you acquire in a Spanish deal?

You acquire the company, and both licence tiers stay with it. A licencia general runs for ten years and renews for another ten. Each licencia singular runs between one and five years and renews for equal periods. Lose the General Licence and every Singular Licence attached to it falls with it.

The term lengths matter when you price a target. Betting and slots carry five-year titles. A licensee whose slots title was granted recently therefore has a longer runway than one whose roulette title expires next year. Check every expiry date during due diligence.

A vertical the target lacks does not require a new tender.

The DGOJ grants Singular Licences on ordinary application under an existing General Licence. They arrive provisionally, and the title becomes definitive once the DGOJ homologates, or certifies, the gaming system. The regulator expects that within six months. In June 2026 the DGOJ granted eight such provisional titles, to Iberix Gaming and Winamax.

What financial guarantee does a Spanish licence require?

A Spanish General Licence requires a €2,000,000 financial guarantee during its initial period. Real Decreto 520/2026 raises that to €2,600,000 on 1 January 2027. After the initial period the amount falls to €1,000,000 across every General Licence an operator holds, rising to €1,300,000 under the same decree.

The initial period runs from the date the General Licence application is filed to 31 December of the year after the licence is granted. Amounts attached to Singular Licences stay outside that calculation, under Anexo I of Real Decreto 1614/2011.

Contests are the one cheaper category. A General Licence for concursos carries €500,000 in the initial period, rising to €650,000 in 2027, then €250,000, rising to €325,000.

The admissible form of the guarantee changed on 26 June 2026. Cash, bank guarantees and insurance bonds still qualify. A mortgage over Spanish property no longer does, because Real Decreto 520/2026 removed it from Article 43.1 of Real Decreto 1614/2011. A target whose guarantee sits in a mortgage has to refinance it, and the seller will want you to carry that cost.

How long does entry into Spain take?

Plan 6 to 18 months for a Spanish acquisition end to end. Inside that, allow a minimum of two to four months for the DGOJ to approve the new shareholder structure. Keep the two clocks apart: the deal timetable is commercial, and the clearance timetable is regulatory and outside your control.

No statutory review period applies to a change of control, which is why the range is wide. The Singular Licence route does have a clock: a provisional title becomes definitive once the DGOJ homologates the gaming system, and the regulator works to a six-month window.

Sanction procedures resolve within six months of the decision to open them. If the target sits inside one, that is a date you can plan around.

What taxes apply to Spanish licensed operators?

Spanish licensed operators pay 20% of gross gaming revenue as the Impuesto sobre Actividades de Juego (IAJ), filed quarterly. Corporate income tax of 25% then applies to profit. A regulatory levy of 0.075% of gross gaming revenue runs alongside. Online gambling is exempt from VAT, so input VAT cannot be recovered.

Three points decide whether the model works.

The Ceuta and Melilla rate is 10%, half the mainland rate. Article 48.7 of Ley 13/2011 grants it only to operators with fiscal residence there that are genuinely established there. Spain's tax authority has issued binding rulings on what that means, so treat it as a substance test rather than a registered address.

Autonomous communities may raise the IAJ by up to 20% of the statutory rate under Article 48.7.3, so the top rate reaches 24%. The increase applies only to the share of the base from players resident in that community.

Stack the levies on a casino at a 96% return to player and the combined take reaches about 41% of GGR, but only in the extreme case where operating costs are zero. Real costs shrink the corporate tax base, so the real figure sits below that. Treat 41% as a ceiling, not a run rate.

No gambling-specific rate change has been announced for 2026. The Safe Gambling Programme for 2026 to 2030 targets player protection, not tax.

What are the technical and operational requirements?

Four technical requirements bind every Spanish licensee. The commercial offer runs on a .es domain. The gaming system needs DGOJ homologation. The operator checks every registration and deposit against the RGIAJ. An operator without a Spanish domicile must appoint a permanent representative in Spain.

The .es domain. Article 10.4(d) of Ley 13/2011 requires a dedicated website under a .es domain. Article 10.4(e) requires the operator to redirect Spanish traffic and Spanish user accounts away from any other domain that the operator, its parent or its subsidiaries control. Breaching either is a very serious infringement under Article 39.

Gaming system homologation. A DGOJ-accredited laboratory certifies the Sistema Técnico de Juego against Real Decreto 1613/2011. The scope covers the random number generator, game fairness, security, and real-time reporting into DGOJ systems.

Self-exclusion checks. The operator checks the RGIAJ at registration and at every deposit, and blocks a listed player across every product immediately.

Permanent representative. Since 26 June 2026 an operator without a Spanish domicile must appoint a representative in Spain to receive notifications.

Joint deposit platform. From 25 March 2027 the operator queries the central DGOJ deposit system in real time before accepting a deposit.

For a buyer none of this is abstract. Homologation status and technical compliance are things you verify in the target, and a gap in either is a repair cost you inherit.

What ongoing compliance obligations apply?

The compliance load is heavy and rising. Real Decreto 176/2023 de entornos más seguros de juego governs safer gambling. Real Decreto 520/2026 introduces deposit limits counted jointly across all operators. Anti-money-laundering duties sit under Ley 10/2010 with SEPBLAC as supervisor. Technical audits run on a two-year cycle.

Joint deposit limits, in force 25 March 2027. The Council of Ministers approved Real Decreto 520/2026, de 24 de junio, on 23 June 2026. The Boletín Oficial del Estado published it on 25 June 2026. The joint-limit system takes effect nine months after publication. Until then the old per-operator defaults still apply.

The new ceilings. Default ceilings become €700 per day, €1,750 per week and €3,300 per four-week period, counted jointly and globally per person across every operator. Money deposited with one operator reduces the room available at every other. The previous defaults were €600 per day, €1,500 per week and €3,000 per month, applied per operator.

The central platform. The DGOJ will run it that aggregates deposits and checks compliance in real time. The operator queries it before accepting a deposit and rejects the deposit once a limit is reached. The regulator has said operators will get a test version ahead of go-live.

The target group. Around a third of active Spanish players hold accounts with more than one operator, and the reform targets that segment.

Guarantee amounts, in force 1 January 2027. Same decree, different date, covered above.

Permanent representative and guarantee form, in force since 26 June 2026. Both already apply.

Self-exclusion. RGIAJ checks at registration and at deposit, with immediate blocking across all products.

Risk detection. Real Decreto 176/2023, de 14 de marzo, has applied since March 2023 and requires a standardised DGOJ-approved algorithm for detecting risky play. Operators running their own model migrate to the standard one.

Anti-money laundering. Ley 10/2010 makes licensed operators obliged entities under SEPBLAC supervision. The operator formally identifies every player, and prize payments of €2,500 or more trigger verified identification. SEPBLAC has allowed identification by videoconference for remote onboarding since 1 March 2016. The operator keeps records for at least ten years.

Audits. A technical platform audit runs every two years through a DGOJ-accredited laboratory, statutory accounts are filed annually, and SEPBLAC can inspect the anti-money-laundering programme at any time. A DGOJ inspection carries a statutory fee of €5,000.

What are the advertising rules in Spain?

Spanish gambling advertising sits under Real Decreto 958/2020, and part of it no longer stands. Supreme Court judgment 527/2024 of 2 April 2024 annulled several articles on an appeal by JDigital. A reform is in progress but not in force, so the safe course is to market conservatively.

What the Supreme Court struck down. Four provisions fell, and the court held that each lacked the statutory backing the regulation needed.

• Articles 13.1 and 13.3, on promotions aimed at new customers

• Article 15, on public figures appearing in gambling advertising

• Article 23.1, banning commercial communications through information society services

• Article 25.3, on advertising via video-sharing platforms

What still stands. The rest of Real Decreto 958/2020, including the broadcast window for audiovisual advertising and the limits on sponsorship.

What is coming. The Ministry of Social Rights, Consumer Affairs and the 2030 Agenda opened a prior public consultation on amending Ley 13/2011 itself, and the consultation closed on 22 June 2026. The proposals cover limits on celebrities and influencers, rules on customer-acquisition promotions, stronger risk warnings, and rules on organic search advertising. None of it is law yet.

Who supervises. The DGOJ enforces the advertising rules against operators. The CNMC regulates audiovisual media services, which carry a share of gambling advertising.

How strictly does the DGOJ enforce?

Very strictly, and licensed operators are not exempt. Spain imposed €142.7 million in gambling fines during 2024 and around €111 million across 58 sanctions in 2025. Since publication became mandatory in 2021, 212 sanctions totalling roughly €496 million have been published.

Read the headline totals with one caveat. They blend fines on unlicensed operators, much of which is never collected, with fines on licensed ones.

The second half of 2024 shows the pattern. Of €77.4 million across 26 operators, 14 unlicensed foreign operators took very serious fines of €5 million each, plus €10 million for one repeat offender. Eleven serious fines on licensed operators came to €2.4 million in total.

November 2025 followed the same shape. The ministry sanctioned 32 operators for a combined €33.5 million. Six very serious fines of €5 million each hit unlicensed operators. The other 26 were serious fines on licensed operators, Betfair, 888 and Codere among them, under Article 40 of Ley 13/2011.

The statutory scale is wider than most pages report. Under Article 42 of Ley 13/2011 a serious infringement carries €100,000 to €1,000,000 and suspension in Spain for up to six months. A very serious infringement carries €1,000,000 to €50,000,000, plus possible loss of the licence, disqualification for up to four years, or closure of the services carrying the activity.

Practice sits well below the statutory ceiling. The DGOJ has settled on €5 million for a first very serious breach and €10 million on repeat, with portal closure and a two-year ban.

Pending fines, open investigations, a half-funded guarantee or a lapsed Singular Licence all pass to the buyer, and closing before DGOJ clearance is itself a violation.

How does Spain compare to Malta, the UK and Italy?

Spain is the only tier-1 regulated market in Europe you cannot enter by application. Malta and the United Kingdom take direct applications. Italy sells nine-year concessions. Spain grants General Licences by tender only, and no tender has opened since 2018, so acquisition is the route.

Two of these numbers moved recently and are easy to get wrong.

The United Kingdom raised Remote Gaming Duty from 21% to 40% with effect from 1 April 2026. Its remote sports betting rate goes to 25% in April 2027. Remote betting on UK horse racing stays at 15%.

Malta consolidated its gaming tax and device levy on 1 October 2026. Type 1 services move to 15% and Types 2 to 4 to 10%. The base does not change: Malta taxes only revenue from players resident in Malta, on a residence test rather than where the player sits at the moment of play. Revenue from players elsewhere falls outside Malta's gaming tax, which is why the headline rate reads so low.

That table also leaves out two Malta charges that belong in any real comparison. The compliance contribution runs on worldwide gaming revenue, not Malta-player revenue, and it scales into six figures a year. Corporate tax is 35% headline, reduced to roughly 5% effective through Malta's 6/7 shareholder refund, against Spain's flat 25%.

At 20% of GGR Spain sits in the middle on tax. Spain's problem is not the rate. Spain's problem is the door.

No national licence in this table gives access to another country's players. A Malta licence does not passport into Spain or Italy, and on 23 April 2026 Advocate General Emiliou restated that EU law contains no mutual recognition of gaming licences. If Spanish players are the target, a Spanish licensee is what you buy. If speed and low cost matter more than one specific regulated market, an offshore route is a different conversation.

What are the advantages of the Spanish market?

Spain is an EU tier-1 market with a 20% gaming tax. Gross gaming revenue reached €1,700.55 million in 2025, up 16.99% on 2024. Casino is both the largest vertical and the fastest growing.

Market size and growth. The DGOJ reported €1,700.55 million of GGR for 2025 against €1,454.59 million in 2024. In the third quarter of 2025 alone GGR was €405.36 million, up 16.49% year on year, with the casino segment up 22.93% and slots up 27.78%.

Tier-1 EU standing. A Spanish General Licence puts an operator in the same regulatory tier as Malta, the United Kingdom and Italy. That standing is what banks and payment providers price when they onboard a merchant.

Tax below the United Kingdom. At 20% of GGR, Spain costs half the United Kingdom's 40% Remote Gaming Duty on remote gaming.

A lawful, routine entry route. The DGOJ approves share acquisitions of licensed operators as ordinary business. In June 2026 the regulator granted new Singular Licences to Iberix Gaming, the rebranded former Sisal España licence holder.

Verticals expand by application. Once you hold the company and its General Licence, adding a vertical is a Singular Licence application to the DGOJ rather than a wait for the next tender.

What are the disadvantages and risks?

The main risk in Spain is not the regulator. The risk is the company you buy. Entry by application is closed with no reopening date. Price is opaque. Every obligation of the target transfers to you, and the regulatory load rises through 2027.

No application route. General Licences come by tender, and the DGOJ decides whether to call one. There is no queue to join.

No price benchmark. Nothing public tells you what a licensed Spanish operator is worth, so valuation rests on the target's own numbers.

Inherited liability. Open sanction proceedings, unpaid fines, an underfunded guarantee, an expired Singular Licence, and the target's SEPBLAC and tax position all pass with the shares. The DGOJ can still act on a very serious infringement for four years.

Rising capital requirement. The guarantee goes from €2,000,000 to €2,600,000 on 1 January 2027, and a mortgage no longer counts.

Rising compliance load. Real Decreto 176/2023, then Real Decreto 520/2026, then the central deposit platform from 25 March 2027 with a real-time check before every deposit.

Operational dependency on the regulator. Once deposits require a live query to a DGOJ platform, an outage or a sync failure on the regulator's side stops the operator taking deposits. Put that in the risk register.

Advertising in limbo. Part of Real Decreto 958/2020 has been annulled, the replacement is not in force, and the rules could tighten again.

Enforcement reaches licensees. In November 2025 the ministry fined 26 licensed operators, three of them among the largest names in the market.

Why MGL

MGL Solutions runs the regulatory due diligence that decides whether a Spanish licensee is worth buying, then handles the change of control with the DGOJ. Spain is the one European market where the product is a company rather than an application, so the work that protects you happens before the money moves.

Before you commit capital, we check the target the way the regulator would. That means open sanction proceedings, the status and expiry of every Singular Licence, and homologation of the gaming system. It also means whether the €2,000,000 guarantee is fully funded and held in an admissible form, and where the company stands with SEPBLAC and the Agencia Tributaria.

After signing, we handle the DGOJ change-of-control notification, the permanent representative in Spain, policy and anti-money-laundering alignment, and the compliance work that keeps the licence alive.

MGL has delivered 300+ licences. For Spain, the work starts with a target assessment.

The Spanish regime described here is the position in August 2026, and none of it is legal advice. Run any acquisition with Spanish gambling counsel alongside it.