BULGARIA PROPOSES NEAR-TOTAL GAMBLING ADVERTISING BAN AND 22% ONLINE FEE WITH €100,000 MONTHLY MINIMUM

Bulgaria has notified the European Commission of proposed amendments to its Gambling Act that would introduce a near-total ban on gambling advertising, end affiliate licences and significantly increase fees for online gambling operators.

The European Commission registered the draft on 2 October under notification 2026/0536/BG. The proposal remains under public consultation, which runs until 23 October, and has not yet been submitted to the National Assembly for approval.

The planned changes would prohibit most forms of gambling advertising while retaining limited exceptions for sports sponsorship and certain information provided by licensed operators. They would also introduce new enforcement powers, higher online gambling fees and additional requirements for operators serving the Bulgarian market.

The government intends for the legislation to take effect on 1 January 2027, subject to the parliamentary process.

Draft legislation notified to Brussels

The notification follows a government announcement on 23 September outlining plans to tighten Bulgaria’s gambling advertising rules.

Submitting the draft to the European Commission is an important procedural step before the legislation progresses through parliament. It also addresses questions raised during the consultation about compliance with EU notification requirements.

In March 2025, the Court of Justice of the European Union ruled in the Unigames case that Lithuania’s restrictions on encouraging online gambling constituted a technical regulation under Directive (EU) 2015/1535. Because the relevant measure had not been notified, it could not be enforced against private parties.

The ruling prompted consultation participants to question whether Bulgaria’s proposed legislation had followed the required procedure.

The Ministry of Finance opened its consultation on 23 September. Once it closes, the Council of Ministers can consider approving the draft and submitting it to the National Assembly. Two separate opposition proposals to amend the Gambling Act had already been registered in parliament in early September.

What the advertising ban would cover

The draft would prohibit advertising for gambling games, gambling operators and their trademarks, regardless of the form or channel of distribution.

Limited exceptions would remain. Licensed operators could provide information necessary for customers to participate in gambling on their websites and premises. Broadcasts of draws conducted by the state-owned Bulgarian Sports Totalizator would also be permitted.

Licensed gambling venues could display signs on their facades, subject to restrictions on size. Such signs would be limited to 20% of the facade and a maximum of 50 square metres, with part of the display required to carry a warning about the risk of gambling addiction. Illuminated and moving panels would not be allowed.

Sports sponsorship would remain possible for licensed sports clubs, federations and associations. Sponsorship would also be permitted for certain events supporting culture, health and education, with branding restricted to a registered trademark or company name.

However, gambling branding would be prohibited on sports kit for minors. Broadcasters would also be prevented from adding digital sponsor branding to televised or streamed events beyond signage physically present at the venue.

The result would be a broad advertising restriction with exceptions for selected forms of sponsorship and limited operator information.

Affiliate licences to end in 2027

The proposal would terminate all licences issued to affiliate operators from 1 January 2027, significantly changing how licensed gambling businesses could promote their products.

The National Revenue Agency (NRA), which assumed responsibility for gambling regulation after the State Commission on Gambling was abolished in 2020, would also receive powers to order the blocking of websites, applications, social media profiles and streaming platforms carrying gambling advertising.

Individuals publishing prohibited gambling advertisements could face fines of €10,000 to €20,000. For companies, the proposed penalties would range from €20,000 to €50,000, with higher fines for repeat offences.

The wider enforcement framework is intended to restrict the promotion of gambling across both conventional advertising channels and digital platforms.

Online fees to rise to 22%

The proposed amendments would increase the variable fee paid by online gambling operators from 20% of stakes less winnings to 21% in 2027 and 22% in 2028.

A minimum monthly payment of €100,000 would also apply to each operator, equivalent to €1.2 million annually regardless of the operator’s revenue.

The one-off online licence fee would rise to €400,000. The draft also proposes allowing operators to retain part of their variable fee if the money is directed towards eligible sports organisations. The permitted share would be 1% in 2027 and 2% from 2028, provided the funds support licensed Olympic sports federations and professional football clubs through sponsorship, advertising or donations.

Payment providers would face a separate obligation to transfer to the state any portion of their fees on gambling deposits or payouts exceeding 1.5% of the transaction value.

Additional requirements would apply to foreign online licensees, which would need to establish a registered place of business in Bulgaria by 30 June 2027 or risk losing their licences. Casinos and gaming halls would also be required to connect their gaming machines to the NRA’s systems by that date.

Opposition and industry concerns

The proposals have attracted criticism from opposition politicians and participants in the public consultation.

Assen Vassilev, leader of the We Continue the Change party, has questioned whether the draft goes far enough in addressing gambling promotion, pointing to exceptions for betting shop facades, the scope of the trademark provisions and the proposed penalties.

His party submitted its own Gambling Act amendment in September, followed by a separate proposal from Democratic Bulgaria MPs.

Consultation participants have raised concerns about the potential effects on affiliates, media businesses and advertising companies. Some argue that eliminating licensed affiliate marketing could direct consumers towards unlicensed gambling websites. Others have questioned the breadth of the advertising restrictions and requirements concerning the location of central systems in Bulgaria.

These concerns reflect wider questions about how a substantial reduction in the visibility of licensed operators might affect competition with unlicensed businesses.

EU compliance and the sponsorship exception

The notification to the European Commission addresses the procedural issue highlighted by the Unigames ruling. However, it does not settle the broader questions that may arise over the substance of the proposed rules.

EU member states have considerable discretion in regulating gambling, but requirements affecting where businesses establish themselves or locate their systems can raise questions about the freedom to provide services across the bloc.

The proposed sponsorship exemptions also create a distinction between gambling advertising and financial support for sport. Although most advertising channels would be restricted, operators could continue sponsoring eligible clubs and federations.

The mechanism allowing operators to retain part of their fees for sports funding would connect that exception directly to the proposed increase in the online gambling rate.

The final scope of these provisions will depend on the legislation approved by parliament and any changes made during the consultation and legislative process.

Impact on the licensed market

The proposed €100,000 monthly minimum fee could place significant pressure on smaller online operators, particularly when combined with the higher variable rate, increased licence fee and restrictions on affiliate marketing.

The effect on the regulated market will depend on how operators respond to the additional costs and whether the advertising restrictions influence consumers’ choice of gambling services.

The government is proposing stronger website-blocking powers as part of its approach to enforcement. Critics, however, argue that restrictions on licensed operators’ visibility could make it more difficult for consumers to distinguish regulated businesses from unlicensed alternatives.

The consultation provides an opportunity for operators, media companies and other stakeholders to raise these concerns before the legislation advances.

Bulgaria has now completed the EU notification step for its proposed reforms. The next stages will determine whether the advertising restrictions, new fee structure and enforcement measures remain unchanged or are revised before the bill reaches parliament.