Spain Gambling Reform Frozen as Snap Election Looms

Key Points

• The snap election cancels a bill on restrictions for access of minors to loot boxes, and halts the process of revising Law 13/2011.
• However, the default deposit limits of €700 per day will be applied starting from 25 March 2027; they may be lowered, increased, or cancelled by players.
• Jdigital challenged these deposit limits in the Supreme Court, where previously in 2024 the gambling decree regulation had been cancelled.

Spanish Gambling Reform Frozen by Snap Election, but Deposit Limits Remain Relevant

One election has stopped the first revision of Spain’s 15-year-old gambling law, however, the new deposit limits will remain relevant. Spanish Prime Minister Pedro Sanchez announced the early election for 29 November, just after Congress cancelled his housing decree-laws on 2 October.

Then what exactly will the snap election stop, and what not? It all depends on whether each regulation was a law, a bill, or a decree.

A Child Protection Rule Goes Down With Parliament

When a Spanish parliament gets dissolved, all the bills in Congress get tossed, except those the government figured were too important to just get scrapped. And one of them that was in the process was a rule about protecting kids from stuff in video games that lets you pay for random goodies. The bill would have stopped kids under 18 from playing games with ‘loot boxes’ you know, those features that let you pay for a random prize that might be pretty cool or utterly useless. According to iGaming Times, the bill stalled after 18 months of being stuck at the report stage, even though it was supposed to get pushed through as an urgent one. Looks like a new government will have to start the whole process all over again from scratch.

A Wider Reform that Was Never Even a Bill

The bigger picture here is that a major reform of Spain’s gambling laws never even got off the ground. The country’s gambling regulator, the DGOJ, put out a public consultation on what amendments they wanted to make from the end of May to early June last year. This covered things like how footballers can push gambling and how adverts get placed on search engines. They then spent the summer hammering out details with industry groups, but nothing ever made it to the Council of Ministers.

Cristina Romero de Alba, a partner at Loyra Abogados, reckons the election is a bit of a setback, and a potential change in direction for things. When she spoke to NEXT.io she added that “any changes to Law 13/2011 are going to need a whole new bit of legislation.”

Spain’s had a whiff of this kind of thing before, actually. Back in late 2025, the government tried to sneak some gambling rule changes into a law about customer service. Then, just before Christmas 2025, the Partido Popular used their majority in the Senate to rip them out. Romero de Alba reckons the PP’s objection was mainly about following procedure, rather than the actual rules around player protection.

Deposit Limits Remain On Track One Thing to Keep an Eye On

The rules that will probably make the most difference to operators were actually decided by royal decree anyway, which is why they won’t get derailed by the election. Royal Decree 520/2026 sets out joint deposit limits of €700 a day, €1,750 a week and €3,300 over four weeks. These limits combine all the deposits a player makes across all the different operators they use, and they kick in on March 25, 2027.

Loads of reports call these limits a hard cap, but technically according to the decree itself they aren’t. Players can actually go in and set their own deposit limits lower, or if they want even ask to increase them. Any of those changes will take three working days to come into effect, and the operator has to make sure the player gets some information about the potential risks first.

“An election on its own doesn’t affect that timeline,” Romero de Alba pointed out. Of course, the courts or a future government might well decide to change the decree later down the line, but for now it’s business as usual.

The Technical Work Has Already Got Underway

It’s a bit further along than a lot of the headlines are letting on. The DGOJ has published its tech specs for the joint limits system, dated September 2026 and now operators can go ask for the access keys they need to get into its test environment. They’re also going to need a test version six months before the launch, so the countdown is already ticking away.

Jdigital Takes the Limits All the Way to the Supreme Court

The online gambling folks at Jdigital are now taking the limits to the Supreme Court, where they’re arguing the limits are totally out of proportion and asking whether they even fit with Spain’s legal framework.

They’ve had a bit of success like this before. On April 2nd 2024, the Supreme Court ended up scrapping a few bits of Royal Decree 958/2020’s rules on gambling advertising; these included rules on new customer promos, celebrity ads, video platforms and social media. According to Cuatrecasas, the judges decided these rules just weren’t based on Law 13/2011 strongly enough. But the court threw out most of the rest of Jdigital’s challenge, and that doesn’t necessarily mean this new case is going to turn out the same.

Romero de Alba is urging caution on this one “This doesn’t mean the challenge to the deposit limits will automatically succeed,” she said. She still reckons the limits of regulatory power are ” a genuine legal grey area, not just some industry fancy talk.”

The Industry Thought a Delay Was on the Cards

Jdigital had this coming a couple of weeks before Sánchez actually pulled the trigger. They wrote an open letter on September 21st saying no one thought such a big change was going to get through in this legislative term, and now they’re planning to come up with a joint proposal early next year, whoever ends up leading the next government.

PP and Vox Still Haven’t Shown Their Hand

It looks like there might be a change of government on the cards. Sigma Dos did a bit of fieldwork for El Mundo and came out with some pretty interesting numbers: 140 seats for the PP, 63 for Vox, and 103 for the Socialists. The Socialists need 176 seats to get a majority, so it looks like PP leader Alberto Núñez Feijóo would probably need to get some support from Vox.

NEXT.io reported that people on the Polymarket traders think there’s an 80% chance Feijóo will be PM. The DGOJ actually blocked Polymarket back in May because they’ve got a case against them. So the odds are from a platform that Spanish users can no longer even get to.

According to Romero de Alba, neither PP nor Vox have actually put out a detailed plan for how they’d handle gambling. “The PP were saying in their 2019 manifesto that they’d regulate gambling advertising and get some cash set aside for fighting gambling addiction,” she said. And she added that “Vox don’t really have a clear public position on the actual regulatory framework for this stuff. Lovely to see PP senator Elena Castillo had a bit of a go in February though, saying “carrying a casino in your pocket is no laughing matter.”

The Housing Question Will Probably Dominate the Campaign

It is unlikely that gambling will play a prominent role in this campaign. Anger has flared up following the eviction of Maricarmen Abascal, an 87-year-old woman, from her apartment in Madrid. A 40dB poll showed that 68% of Spaniards favour rent control measures, according to Reuters. According to Romero de Alba, there is little indication that “gambling will become a significant electoral dividing line.”

Expert Opinion: The €700 Limit Is Less Complicated than Meets the Eye

In our opinion, the loudest aspect of the story is also the least understood one. The limit of €700 is not an upper ceiling but a starting setting that every adult player can easily remove after waiting three days. In our estimation, it makes the Jdigital statement about disproportionate limits meaningless – the decree provides for a flexible regulation of the issue already.

This very point also works against the government though. If players in danger can remove their limits, then how much protection do they get? The Ministry of Consumer Affairs seems to have created the provision, which is too strict to please the industry but not strict enough to satisfy the health activists.

The bigger issue is somewhere else. The Law 13/2011 consultation covered such areas as the advertisement of celebrities and promotional sign-ups, which are exactly the same aspects addressed by the 2024 Supreme Court’s decision. In our view, it was the attempt of Madrid to codify the regulations the judges abolished. This means that the annulled limitations will remain out of the law even longer due to the upcoming election.

Finally, the loot boxes case remains unexplainable. The bill regarding the urgent procedure cannot be kept in the committee for 18 months, and children currently have no specific statutory protection from the payments made for a chance to win some prize.

Some readers may interpret this case as the work of the regulator business as usual. In our view, two clocks tick in parallel: voters elect the future lawmakers while the judges decide about the validity of the decree. But only one clock stops ticking on 29 November.