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online gambling advertising rules portugal

Online Gambling Advertising Rules Portugal 2026: SRIJ, Article 21, Sponsorships & Bonuses

By Global Law Experts
– posted 59 minutes 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.

Quick Legal Status: Is Online Gambling Legal in Portugal?

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.

Key Definitions

  • Licensed operator. An entity holding a valid SRIJ online gambling or betting licence under the RJO.
  • Affiliate / publisher. A third party that promotes a licensed operator’s services in exchange for commission, typically through websites, social media or comparison platforms.
  • Sponsor. A party (operator or brand) that provides financial or in-kind support to a sports club, event or media property in exchange for brand visibility.
  • Advertising. Any form of commercial communication, including digital display, search ads, social media posts, broadcast spots, influencer content and in-venue signage, that promotes gambling or betting services to the public.

What Changed in 2026: Online Gambling Advertising Rules Portugal, Article 21 and Article 21‑B

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.

Timeline of Key Legislative and Regulatory Dates

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.

Article 21: 2025 vs 2026 Position

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.

Who Is Regulated: Operator, Affiliate and Sponsor Obligations Under Online Gambling Advertising Rules Portugal

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.

Reporting Obligations by Entity Type

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 Portugal Guidance and Expectations: Self-Exclusion and Mandatory Messaging

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.

Self-Exclusion Portal: Technical and Operational Checklist

Operators must address the following integration points to meet responsible gambling requirements in Portugal:

  • Registration gate. Query the SRIJ portal at the point of new-account creation. Block registration if the individual is on the self-exclusion register.
  • Login and session checks. Verify self-exclusion status at each login session, not only at registration.
  • Deposit and play block. Prevent deposits and wager placement for any matched individual, even if an existing account was created before the portal launch.
  • Cross-channel ad suppression. Where technically feasible, use CRM and ad-platform audience-exclusion tools to prevent promotional emails, push notifications, retargeting ads and SMS from reaching self-excluded players.
  • Record keeping. Log all portal queries and their results for a minimum period consistent with SRIJ audit expectations.

Mandatory Messaging and Positioning

Every advertisement for online gambling or online sports betting in Portugal must include a responsible-gambling message. Under the 2026 guidance, the message must:

  • Use prescribed wording, typically referencing the SRIJ self-exclusion portal URL and a national helpline number.
  • Occupy a minimum percentage of screen or print area, industry observers expect SRIJ to finalise this at approximately 20 % of the ad unit, consistent with the approach used for tobacco and alcohol warnings.
  • Appear in Portuguese, irrespective of the language of the primary creative.
  • Be legible and prominent, not obscured by animation, colour contrast or small font.

Advertising Mechanics: Bonuses, Promotions, Targeting and Thresholds

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.

Bonus Promotion Checklist

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:

  • Wagering requirements. State the turnover multiple clearly (e.g., “35× wagering requirement applies”).
  • Minimum age. Display the minimum legal gambling age (18+) prominently.
  • Self-exclusion link. Include a direct link or reference to the SRIJ self-exclusion portal.
  • Responsible-gambling message. Use the prescribed wording described above.
  • Material restrictions. Disclose game eligibility, maximum bet limits during wagering, time limits and withdrawal caps.

Platform Ad Approval and Programmatic Compliance

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:

  • Google Ads. Operators must apply for gambling-ad certification and provide their SRIJ licence number. Ads must target only users aged 18+ in Portugal.
  • Meta (Facebook / Instagram). Written authorisation from Meta is required. Audience targeting must exclude minors, and creatives must include responsible-gambling text.
  • Programmatic / DSP. Implement geo-fencing to ensure ads serve only within Portuguese territory (or only to verified Portuguese IP addresses) and apply age-exclusion segments.

Compliant vs Non-Compliant Ad Copy: Examples

  • Non-compliant: “Get €50 FREE, no risk, guaranteed wins!”, Implies risk-free play; omits wagering requirements; uses “guaranteed wins.”
  • Compliant: “€50 welcome bonus. 35× wagering applies. 18+. Play responsibly. Self-exclusion: [SRIJ portal URL]. Helpline: [number].”
  • Non-compliant: “Bet now and win big, tax-free winnings!”, Misleading taxation claim without qualification; no responsible-gambling message.
  • Compliant: “Place your bet on Liga Portugal. T&Cs apply. 18+. Gamble responsibly. [SRIJ portal URL].”
  • Non-compliant: An influencer Instagram Story showing a betting app with no disclosure, no age gate and no responsible-gambling message.
  • Compliant: An influencer post tagged #ad #PaidPartnership, stating “18+ only,” displaying the SRIJ self-exclusion URL and including the prescribed responsible-gambling text in Portuguese.

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.

Sponsorships, Influencer Marketing and Affiliates: Contracts and Disclosures

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.

Influencer Checklist and Sample Contract Clause

Operators engaging influencers for Portuguese-facing campaigns should ensure every contract includes provisions addressing:

  • Disclosure. The influencer must clearly identify the content as a paid promotion (e.g., #ad, #PaidPartnership) in compliance with the Advertising Code.
  • Age gating. Content must only be published on platforms or channels where audience-age controls restrict visibility to users aged 18+.
  • Prescribed messaging. The responsible-gambling message and SRIJ self-exclusion portal link must appear in every post.
  • Geo-targeting exclusion. If the operator’s licence is Portugal-specific, the influencer must not target audiences in jurisdictions where the operator is unlicensed.
  • Content approval. The operator retains pre-publication approval rights to verify compliance before content goes live.
  • Indemnification. The influencer indemnifies the operator for regulatory sanctions arising from non-compliant content published without approval.

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.”

Sponsor Signage at Events and Broadcast Rules

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.

Enforcement, Penalties and Practical Compliance Checklist

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.

Penalty Matrix

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

What to Do on Receiving an SRIJ Notice

Operators who receive a formal SRIJ notice should follow a structured remediation playbook:

  • Acknowledge receipt immediately and engage Portuguese regulatory counsel within 24 hours.
  • Suspend the identified advertising pending internal review, do not wait for a formal takedown order.
  • Conduct an internal audit of all active campaigns across digital, broadcast, sponsorship and affiliate channels.
  • Prepare and submit a remediation plan to SRIJ within the timeframe specified in the notice, demonstrating corrective action and future compliance controls.
  • Document everything, SRIJ may request evidence of compliance at any subsequent audit or licence renewal.

For broader context on licensing enforcement across jurisdictions, operators may find our guides to crypto casino licenses and Curaçao gambling licences useful comparisons.

Next Steps: Templates, Reporting and Remediation

Operators active in the Portuguese market, or planning market entry, should take the following steps without delay:

  • Audit every active campaign (paid search, display, social, affiliate, sponsorship and influencer) against the 2026 Article 21 requirements.
  • Integrate the SRIJ self-exclusion portal into registration, login, deposit and ad-suppression workflows.
  • Update all influencer and affiliate contracts with the prescribed-messaging, age-gating and content-approval clauses outlined above.
  • Train marketing and compliance teams on the updated rules, including the specific compliant-copy examples in this guide.
  • Engage Portuguese regulatory counsel for a bespoke compliance audit, find experienced practitioners through the Global Law Experts lawyer directory.

Conclusion

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.

Need Legal Advice?

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.

Sources

  1. SRIJ, Legal Framework for Online Gambling and Betting (RJO English PDF)
  2. ICLG, Gambling Laws and Regulations Report 2026 Portugal
  3. Lexology, Portuguese Parliament Discusses Near-Ban on Gambling Advertising
  4. Chambers Global Practice Guides, Gaming Law 2025 Portugal
  5. IMGL, Gambling Advertising in Portugal
  6. Global Law Experts, How To Get A Gaming Licence In Portugal Online

FAQs

Is online gambling legal in Portugal?
Yes. Online gambling and betting are legal and regulated under the RJO (Decree-Law No. 66/2015). Operators must hold a valid SRIJ licence to offer services to consumers in Portugal.
Licensed operators may advertise gambling services in Portugal, but all advertising must comply with Article 21 of the Advertising Code (Decreto-Lei No. 330/90, as amended) and SRIJ guidance. Unlicensed operators are prohibited from advertising entirely.
Portugal levies a special gambling tax (Imposto Especial de Jogo) on the operator rather than on individual player winnings for online gambling. However, specific tax treatment can vary depending on the type and amount of gambling activity. Operators should not use unqualified “tax-free” claims in advertising without accurate context.
Yes. Online sports betting is legal for operators holding the appropriate SRIJ licence category. Advertising of sports-betting products must comply with the same Article 21 rules and responsible-gambling messaging requirements as other online gambling advertising.
Operators must query the SRIJ centralised self-exclusion portal (live since 8 April 2026) at registration, login and deposit stages. They must block account creation, deposits and play for matched individuals and, where technically feasible, suppress marketing communications to self-excluded players.
Influencer content promoting gambling must include clear paid-promotion disclosure, the prescribed responsible-gambling message in Portuguese, a link to the SRIJ self-exclusion portal, and an 18+ age restriction notice. The licensed operator bears primary regulatory liability for influencer content.
SRIJ may impose administrative fines, issue compliance orders, require immediate ad withdrawal, attach conditions to the operator’s licence, or, in serious or repeated cases, suspend or revoke the licence. Unlicensed advertising may also trigger ISP blocking orders.

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Online Gambling Advertising Rules Portugal 2026: SRIJ, Article 21, Sponsorships & Bonuses

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