ROMANIAN REGULATION
The legislator aimed to update the self-exclusion regime via certain amendments introduced in 2022 and 2023. In essence, at the end of 2023, GEO 77/2009 was modified saying that (i) ONJN must create a centralized database for all players that wish to self-exclude from gambling “locations” and (ii) operators (both online and land-based) must forward to the regulator all self- exclusion requests they receive so the centralized database can be populated. By law, ONJN should have launched the live database by end of March 2024, but this has never materialized. Instead, in 2024 the regulator started to circulate spreadsheets containing the personal data of various self-excluded players. The dissemination was not consistent, with various online and land-based operators receiving such lists, even though the text of law stipulated in explicit terms that the database should cover only land-based self-exclusions. Furthermore, the former management of ONJN had quite contradictory public positions in 2024 and argued in certain press releases that the database/lists apply equally to online and land- based sectors. This context fueled a social media movement at the beginning of 2025 where various players claimed refunds from (mostly online) operators. They argued that the current legislation also applies to them and that online operators breached the law because they did not action the lists shared by ONJN or should have been aware of all self- exclusions from the market. This perception is not backed by proper legal arguments, but the pressure was intense and certain online operators reportedly made a voluntary decision to give refunds even in the absence of a legal requirement. In April 2025, a new ONJN President was appointed and shortly thereafter certain guidelines were communicated and an implementation plan for the future self-exclusion regime published. The president of the regulator stated that the current
law applies only to land-based activities and promised a new legislative proposal to modify GEO 77/2009 so that the central database will apply to both online and retail in future. Nevertheless, it must be emphasized that the self- exclusion regime and its legislative amendment remains a sensitive and volatile topic and it is not excluded for the authorities to express other positions in the future. Being so, local advice on implementation measures (especially for online operators) remains highly recommended until the legislation will be clarified. The road ahead As the Romanian gambling market evolves, new legislative initiatives and enforcement actions are shaping the compliance obligations of both operators and suppliers. While the regulation for raffles and advertising lotteries/sweepstakes reflects a legacy structure in need of clarification, the recent amendments targeting B2B licensees mark a shift towards stricter enforcement and broader territorial control. ONJN’s future enforcement practice – together with the anticipated feedback loop following the collection of technical compliance data – will be critical in defining regulatory expectations moving forward. Operators and service providers active on the Romanian market are well advised to closely monitor ONJN communications and to adopt a forward-looking, documented compliance posture, balancing regulatory caution with commercial agility. Clearer articulation of regulatory expectations (which have started to materialize with the appointment of the new ONJN president) in the coming months would support better industry alignment and reduce the risks of divergent practices or inadvertent non-compliance.
ANA-MARIA BACIU Managing Partner, BACIU PARTNERS For information contact
+40-31 437 80 13 ana-maria.baciu@ baciupartners.ro
ANDREI COSMA Partner, BACIU PARTNERS
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IMGL MAGAZINE | JUNE 2025
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