The Portuguese Centralised Self-exclusion Portal for online gambling and the challenges faced by operators in enforcing gambling prohibitions

Introduction

On 8 April 2026, the Portuguese Gambling Regulation and Inspection Authority (Serviço de Regulação e Inspeção de Jogos – SRIJ) introduced a new online gambling self-exclusion form, made available through a centralised portal.

The existence of such a form is not novel within the Portuguese legal framework; what is new is its redesign and improvement.

According to the SRIJ, the new form features a simpler and more intuitive interface, enabling users to submit self-exclusion requests quickly and efficiently. Navigation has been streamlined to ensure a more straightforward and accessible process at every stage. The form has also been optimised for mobile devices, allowing requests to be accessed and submitted conveniently via smartphones and tablets. With this updated form, the regulator aims to improve the quality of its digital services and the effectiveness of the gambling control mechanisms made available to players, thereby reinforcing its commitment to responsible gambling.

The announcement of this new form on the regulator’s portal provides a starting point for a brief overview of the various self-exclusion mechanisms in the context of online gambling in Portugal, as well as an opportunity to reflect on what remains to be done in the field of gambling prohibitions.

 

Responsible gambling at the core of the Portuguese regulator’s priorities

Responsible gambling is a key concern for the Portuguese regulator. First, responsible gambling principles are often relied upon by the regulator when analysing and interpreting the applicable laws and regulations. In addition, many of the regulator’s supervisory and enforcement activities are driven by responsible gambling considerations, and several of the guidelines and instructions it issues reflect those same concerns. The creation of a centralised self-exclusion portal further demonstrates the regulator’s commitment to responsible gambling.

 

Self-Exclusion in Online Gambling

The possibility of self-exclusion from online gambling is one of the measures provided for under Portuguese law within the framework of promoting responsible gambling.

One of the more distinctive aspects of the Portuguese legal and technical approach is that self-exclusion may be requested not only by players but also by non-players. In other words, self-exclusion may be requested not only by individuals who hold a player account with a licensed online gambling operator, but also by those who do not hold such an account and wish to do so on a preventive basis.

Self-Exclusion on the Operator’s Website

The Online Gambling Legal Framework (Regime do Jogo Online – RJO), approved by Decree-Law No. 66/2015 of 29 April, as amended, provides that a player may self-exclude directly on the operator’s website. In such cases, the player is prevented from gambling on that website for the duration of the exclusion period but is not prevented from gambling on the websites of other operators. Where a player has self-excluded via an operator’s website, the revocation of that self-exclusion must also be carried out on the same website.

For this purpose, operators are required to make available, on their websites, mechanisms enabling players to self-exclude from online gambling activities. In addition, the responsible gambling policy – which is mandatory for licensed operators – must include a reference to the self-exclusion mechanisms, the way they are made available on the website, and how players may access them. Furthermore, the granting of a licence to operate online gambling is conditional upon the applicant’s technical system including mechanisms for player self-exclusion and for preventing the registration of individuals who are prohibited from gambling.

Also of note is that operators are required to maintain a list identifying players who have self-excluded on their platform and must notify the SRIJ of the identity of any players who request self-exclusion or revoke a previous self-exclusion on their website, within a maximum period of 24 hours from receipt of the relevant request.

Self-Exclusion via the SRIJ centralised portal

Under the RJO, in addition to self-exclusion through an operator’s website, players also have the right to self-exclude directly through the website of the regulator – the SRIJ. In such cases, the player is prevented from gambling on the websites of all licensed operators. This mechanism is the basis for the creation of the centralised self-exclusion portal established by the Portuguese regulator, which allows not only the submission of self-exclusion requests but also their revocation.

The key difference with self-exclusion through this centralised portal is that the player is excluded from gambling across all operators. For this reason, the SRIJ maintains a list of players who have self-excluded through its portal. This list must be downloaded by operators’ technical systems whenever it is updated. The SRIJ notifies operators immediately and in real time of any changes, following which operators are required to download the updated list.

In addition to these immediate updates, operators’ technical systems must also perform periodic downloads of the same list, to ensure that their records remain continuously up to date.

Access to the list of self-excluded players maintained by the SRIJ must be used by operators not only when registering new players and creating player accounts, but also each time a player accesses the gambling platform. In fact, the law requires that, at each login, the technical system verifies that the player is not recorded in the operator’s database as self-excluded.

 

Other gambling prohibitions: Current Challenges Faced by Operators

Overview of Gambling Prohibitions

As seen above, the SRIJ’s centralised self-exclusion portal operates effectively in identifying and managing self-excluded players, as well as in ensuring the corresponding communication with gambling operators.

In addition to self-exclusion, the RJO provides for an extensive list of persons who are prohibited from gambling, namely:

• Holders of sovereign offices and Representatives of the Republic for the Autonomous Regions;
• members of the governments of the Autonomous Regions;
• public prosecutors, police authorities, members of the security forces and their agents;
• minors and adults subject to legal guardianship or requiring prior authorisation to carry out acts of a proprietary nature;
• persons prohibited from gambling, whether on a voluntary basis or by judicial decision;
• members of the corporate bodies of gambling operators, in relation to the respective operator’s website;
• employees of gambling operators, in relation to the respective operator’s website;
• any person who has, or may have, access to the information systems of online gambling on a given website;
• persons such as sports officials, coaches, athletes (professional or amateur), judges, referees, sports agents, and persons responsible for organising sports competitions or horse racing events subject to betting, where they have, directly or indirectly, any involvement in the outcome of such events;
• employees of the regulator, the SRIJ.

The granting of licences is conditional upon the applicant’s technical gambling system including mechanisms capable of ensuring the effective enforcement of gambling prohibitions. In addition, the law requires operators to carry out prior checks on players, before completing their registration, to determine whether they are subject to any prohibition from gambling. This verification is the responsibility of the gambling operator.

Failure to comply with this obligation may result in severe penalties. In particular, it is considered a very serious administrative offence for an operator to allow a player to register without verifying their identity or without confirming that the player is not subject to any gambling prohibition.

These offences may be punished by fines ranging from EUR50,000 to EUR1 million or – where higher – up to 10% of the offender’s turnover in the financial year preceding the decision.

Furthermore, if an operator commits two very serious administrative offences within a two-year period, the regulator may revoke the relevant licence.

Challenges in Enforcing Gambling Prohibitions

The above demonstrates that a wide range of individuals are legally prohibited from gambling. At the same time, gambling operators are responsible for enforcing these restrictions at the player registration stage and may face misdemeanour liability, including substantial fines, if they fail to do so.

In this context, the centralised register of self-excluded players maintained by the SRIJ plays a crucial role in enabling operators to comply with their legal obligations. Through the continuous exchange of information between the regulator and operators’ technical systems, operators can automatically and effectively verify whether a player is subject to self-exclusion, both during registration and whenever the player accesses the platform.

The situation is different regarding other categories of gambling prohibitions established under the Law. In such cases, operators do not have access to any equivalent centralised database or verification mechanism managed by the regulator. Consequently, compliance with these obligations may, in practice, prove significantly more complex.

In practice, operators are frequently reliant on the accuracy and completeness of the information provided by players during the registration process. Yet players may, whether deliberately or otherwise, omit relevant details or misrepresent their status to bypass existing gambling restrictions.

For operators, this creates a significant compliance challenge, particularly where the relevant information is neither publicly available nor capable of being independently verified through ordinary due diligence procedures.

The challenge is especially acute in the case of individuals prohibited from gambling by judicial decision. Unless the player voluntarily discloses the restriction, or the relevant court communicates the prohibition to operators or to the regulator, operators may have little or no practical means of identifying that the prohibition exists.

Against this backdrop, imposing liability on operators may be difficult to justify where a player has intentionally misled the operator or concealed relevant information, particularly where the operator can demonstrate that it implemented the due diligence measures reasonably expected in the circumstances. Any assessment of compliance should therefore consider the practical limitations operators face when attempting to verify certain categories of gambling prohibitions.

In this context, the creation of mechanisms enabling operators to verify additional categories of gambling prohibitions – like the system already in place for self-excluded players – could strengthen the effectiveness of the regulatory framework while also providing greater legal certainty for both operators and the regulator in the performance of their respective roles.

You can read about the different gambling regimes in almost 50 jurisdictions in the DLA Piper Gambling Laws of the World guide.