Official magazine of the International Masters of Gaming Law
®
MALTA MARKET FOCUS
INTERNATIONAL MASTERS of GAMING LAW MAGAZINE
VOLUME 6 | NO. 3 | SEPTEMBER 2026
CASTAWAYS: FOCUS ON GLOBAL ONLINE GAMING HUBS PLUS HISTORY HANGS HEAVY ON HUNGARIAN LIBERALIZATION PROTECTING MINORS IN INDIA'S GAMING ECOSYSTEM APPLICATION OF EUROPE'S DIGITAL SERVICES ACT TO BLACK MARKET GIBRALTAR REGULATES PREDICTION MARKETS IN THEIR OWN CLASS CURACAO'S LOK REFORMS MALTA: THE GRANDADDY OF THE REMOTE GAMING HUBS SPORTS BETTING IN FLORIDA: SEMINOLE'S GAMING COMPACT ...AND MUCH MORE!
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IMGL MAGAZINE | JANUARY 2023
MALTA’S FATF GREY-LISTING IMGL OFFICERS 2026
Officers of IMGL for 2026
PETER KULICK 1 st Vice President DICKINSON WRIGHT PLLC LANSING, MICHIGAN +1 517 487 4729 PKULICK@DICKINSONWRIGHT.COM MARC DUNBAR President JONES WALKER TALLAHASSEE, FLORIDA +1 850 214 5080 MDUNBAR@JONESWALKER.COM COSMINA SIMION Executive Vice President WHSIMION & PARTNERS BUCHAREST, ROMANIA +40 31 420 6225 COSMINA.SIMION@ WHSIMIONPARTNERS.RO
PHIL SICUSO Assistant Treasurer BOSE MCKINNEY & EVANS, LLP INDIANAPOLIS +1 317 684 5265 PSICUSO@BOSELAW.COM
RON SEGEV Secretary SEGEV LLP TORONTO / VANCOUVER +1 604 629 5402 RON@SEGEVLLP.COM
DR. SIMON PLANZER Assistant Secretary PLANZER LAW AG ZUG, SWITZERLAND +41 41 512 42 82 PLANZER@PLANZER-LAW.COM
MATTHIAS SPITZ 2 nd Vice President MELCHERS LAW HEIDELBERG +49 62 2118 50141 M.SPITZ@MELCHERS-LAW.COM
ERNEST C. MATTHEWS IV Vice President, Affiliate Members INTERNET SPORTS INTERNATIONAL LAS VEGAS, NEVADA +1 954 478 8758 ERNEST@ISISPORTS.COM BIRGITTE SAND Vice President, Affiliate-Regulator Members BIRGITTE SAND AND ASSOCIATES COPENHAGEN, DENMARK +45 24 44 05 03 BS@BIRGITTESAND.COM
KATE LOWENHAR-FISHER Treasurer EXECUTIVE VICE PRESIDENT, CHIEF LEGAL OFFICER, EVERI HOLDINGS INC +1 800 566-2087 KATE.LOWENHARFISHER@EVERI.COM
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IMGL MAGAZINE | SEPTEMBER 2026
PRESIDENT’S WELCOME
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Strategic partnerships start to bear fruit for members
MARC DUNBAR President INTERNATIONAL MASTERS OF GAMING LAW
W elcome to the latest edition of the IMGL Magazine. As this issue went to press, we were in the final stages of preparation for our autumn conference in Paris, France. Both our organizing and programming committees have been hard at work creating a sparkling program of education, hospitality and networking. I am very excited to see the results of their labors and would like to express the gratitude of all of us for their commitment. Looking through the conference brochure, Paris promises to be a memorable and worthwhile event and I encourage you, if you have not already done so, to reserve your place. As with all our conferences, it will also be an opportunity to learn what has been going on in the organization at our member’s meeting. Much of what IMGL does is handled by our numerous committees and you can hear reports from some of these in Paris. One of this year’s strategic projects has been to refresh the IMGL website, boost our rankings on the various search engines and ramp up our presence on Linkedin. We have been working with an external agency to achieve these aims, and I’m pleased to report the results have been impressive as you will learn in Paris. Additionally, you will hear about some new developments in our administration which will streamline the handling of member data and information making us more efficient and more transparent. The member’s meeting will also be your opportunity to vote on the new IMGL president who will take over when my term ends in December. If you are not planning to attend, I encourage you to use your proxy to give a ringing endorsement to the new president.
Of course, the IMGL conference is just the start of a very busy autumn season as we move straight on the G2E in the US and the SBC Summit in Europe. We have a presence at both major industry events with a Masterclass and reception in Las Vegas and the first public rollout of our strategic partnership with SBC and IAGR in Lisbon. The partnership will be announced to the world as the event starts, there will be a super Masterclass on one of the main event stages and IMGL and IAGR members will be hosting new regulatory meetups throughout the week. As you will read in Simon’s interview with SBC’s founder and CEO Ras Sojmark, this is a big deal for all the organizations involved and should be a triple win for all three. Talking of IAGR, we are delighted to be taking a delegation to their event in Lima, Peru in October and to continuing to strengthen our partnership with regulators as we do. The relationship with IAGR has also reopened our links with Clarion and their ICE event and we will re-taking our place at the World Regulatory Briefing in January in Barcelona. These kinds of platforms for members can only come about through the relationships we as an organization have been able to forge and I hope we will continue to deliver for members in this way. As with many activities in life, the opportunities have to be grasped. With these and other activities we have worked hard to improve the value proposition of IMGL membership. I would heartily recommend you explore and take advantage of all that the organization can offer you both personally and professionally.. Marc Dunbar
IMGL MAGAZINE | SEPTEMBER 2026
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EDITORIAL
A place in the sun
W elcome to the Q3/2026 issue of the IMGL Magazine. One of the delights of serving as Editor-in-Chief is to peruse a broad range of submissions for review, from industry greybeard practitioners to talented law students starting out in gaming law. They contribute manuscripts of all different kinds that are relating to gaming laws and policies. Over the years, I have certainly developed personal preferences and enjoy seeing articles published on topics of a transnational nature, with thought applied to a perspective that does not stop at national or regional borders. Yet, in this issue, it is my pleasure to put an editorial focus on gaming jurisdictions that are in competition. Three of the classic international remote gaming hubs that have undergone significant overhauls of their regulatory frameworks in recent years. This IMGL Magazine issue is leaning in with articles from Gibraltar, Malta and Curaçao. Gibraltar recently regulated prediction markets. Its move was bold and counter cultural amid a generally hostile regulatory atmosphere towards prediction markets among European regulators and US courts.
Curaçao’s LOK review is designed to position the Caribbean island under the Dutch crown firmly as a regulator rather than just a licenser of gaming companies. It aims to tighten its regulatory regime whilst remaining accessible to startup and smaller players. Finally, Malta, with over two decades of regulatory experience, infrastructure and access to the European internal market, has made the Mediterranean island a favorite online hub. Reading the three articles in parallel you will find interesting differences, and I have invited authors to highlight some of them prominently in their submissions. I trust that those with particular interest in online gaming matters will find this comparative reading highly interesting. Culture and history play an often-unrecognized part in regulation, and authors from Hungary and India explore this aspect in these pages. They provide us with insights into the factors shaping gaming policies in these two markets and what the future is likely to bring. The addition of 1-on-1 interviews to the IMGL Magazine has quickly become an eye catcher for our readers. We have featured personalities at the top of the gaming industry and gained personal insights from general counsels of some of the largest
SIMON PLANZER PHD Editor in Chief IMGL MAGAZINE
Contents 6
The inertia of monopoly: regime changes & the legal roadblocks to liberalization in Hungary 12 Keep building connections: one-on-one interview with SBC's Ras Sojmark 16 Could Europe’s Digital Services Act be used to curb promotion of black market gambling? 22 Minor players, major stakes: a guide for developers offering their games in the Indian market 28 A category of its own: why Gibraltar built a bespoke regulatory framework for prediction markets 36 Curaçao’s LOK reform: from licensing jurisdiction to regulatory jurisdiction 44 Malta as a B2B gaming jurisdiction: regulatory foundations, commercial realities & the road ahead 50 The Legality of the 2021 Seminole Gaming Compact
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EDITORIAL
operators, the leaders of leading regulatory authorities and, most recently, the CEO of a large payment service provider. For this issue I had the great pleasure to sit down with one of the most colorful characters in what is a colorful industry. Ras Sojmark is the founder and CEO of SBC Events purveyors of some of the most spectacular events in the calendar. Industry veterans tend to agree that there are too many events to attend every year, but Ras’s continued focus on delivering top quality business networking combined with money-can’t-buy entertainment make his shows some of the best in the business. In our interview with him, we heard his side of the recently announced tripartite partnership of IMGL, IAGR and SBC, and the tangible benefits that will accrue to all three parties. Courtesy of this strategic partnership, IMGL members will get to rock the regulatory vibes with masterclasses, panels and dedicated networking events. Ras is excited about the future of the relationship and his enthusiasm is infectious.
IMGL has maintained very good relations with IAGR and its numerous regulators for many years. IMGL has delivered on its educational mission and provided top notch input to IAGR events. At the same time, proximity to regulators also helps our members. Under the leadership of our past and current presidents, IMGL has now linked the deal with a tie-in to one of the largest and fastest-growing media companies in the gaming industry. That projects the exposure onto a global stage with big benefits all round for all parties. This deal further emphasizes the kind of value proposition of IMGL that leadership has been working on hard over past years: to give members access to a global stage where they can help shape the present and future of gaming laws and policies. And to become part of a global village of gaming law experts. Yours truly, Simon planzer@planzer-law.com
You can access all past IMGL magaazines here or search our extensive archive of expert gaming law articles www.IMGL.org/publications
IMGL Magazine is owned, published and distributed by: The International Masters of Gaming Law PO Box 27106, Las Vegas, NV 89126 USA The IMGL is a domestic non-profit corporation registered in Nevada, U.S. with registration number NV20121147120 Editor in Chief: Simon Planzer PhD, planzer@planzer-law.com Publication & Marketing Committee: Co-chairs , Simon Planzer (Publications), Ali Bartlett (Social Networks & Digital) Members : Luiz Felipe Maia, Daniel McGinn, Luis Carvalho Staff : Phil Savage, Brien Van Dyke Head of Publications: Phil Savage phil@IMGL.org Design and production: SportBusiness Communications. Copyright: All rights reserved to IMGL. No part of this publication may be reproduced or transmitted, in any form or by any means, electronic, mechanical, photocopying, recording or otherwise without prior permission from the publisher. The articles expressed in this publication do not necessarily reflect the views of IMGL but those of the authors. The publisher and editor do not accept any liability for the contents of the authors’ contributions.
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IMGL MAGAZINE | JUNE 2025 IMGL MAGAZINE | SEPTEMBER 2026
REGULATORY REFORM
The inertia of monopoly: regime changes and the legal roadblocks to gambling liberalization in Hungary DR. GÁBOR HELEMBAI FINDS THAT POLITICAL REGIMES SHAPE THE PAST, PRESENT, AND FUTURE OF GAMING POLICIES
F or over two decades, Hungary’s gambling regulation has been characterized by an entrenched inertia, prioritizing state monopolies and restricted, non-transparent concessions over meaningful market liberalization. Following a landmark political shift in the 2026 general elections, the newly formed government now faces an unprecedented opportunity to overhaul this oligopolistic system. However, dismantling the legacy of the heavily patched 1991 Gambling Act requires balancing the urge for political accountability with the need for a modern, EU-compliant regulatory framework. This article explores the historical roadblocks to gambling liberalization in Hungary and argues that upcoming reforms must be driven by professional industry standards rather than mere political drive for accountability to avoid destabilizing the market.
Factors hindering the dismantling of an oligopolistic market From a broader perspective, a complex interplay of social, legal and political factors has contributed to the current situation. Here, the inflexibility of a system characterized by oligopolistic features has so far prevented the establishment of a modern, EU-compliant legal framework that serves the interests of both market participants and players. The persistence of Hungary’s gambling regime is well illustrated by Act XXXIV of 1991 (the 'Gambling Act') 1 , which, although it has undergone numerous amendments, has been in force for 35 years. Normally, if a law has been in force for such a long time, it is a sign of stability and predictability.
1 No official translation is available of the Gambling Act. The original Hungarian version is available here: https://njt.jog.gov.hu/jogsz- abaly/1991-34-00-00
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However, in such a rapidly changing and fast-paced industry such as gambling, it tends to have the opposite effect. It clearly illustrates that none of the recent political regimes has been willing to address the issue seriously or to rethink the state’s role in the industry through a comprehensive reform. Instead, they have simply patched up the law here and there to suit current political and economic interests. The system’s inability to change cannot be attributed to any single specific cause, but rather to several interrelated and mutually reinforcing factors. One such factor is the slow recognition and acceptance that, unlike in the past, the state cannot exercise complete control over the online space. Traditionally, the state has a deeply ingrained belief that it can control all market activity. This may well have been true for a long time in the case of traditional, brick-and-mortar operations, but ceased to be true following the emergence of the online industry. Gambling during the socialist era fell into the category of activities that were tolerated but not supported: it was subject to strict state supervision and was available to the public only to a limited extent. For example, Hungary’s first modern gambling casino under socialist rule opened in Budapest in 1981 and initially admitted only foreign visitors paying in hard currency 2 . This approach was also applied at the time of the transition to a market economy in 1991. There was no question that the lottery – the ‘cash cow’ of state-organized gambling – came under a state monopoly. Meanwhile, other forms of gambling became subject to concessions, allowing the state to decide at its discretion who would be permitted to organize gambling. This fundamental principle continues to underpin the Hungarian gambling regulatory framework to this day.
In response to the rise of online gambling, initial regulations for the sector were introduced in the late 2000s 3 . However, given the borderless nature of the industry, early enforcement proved largely unsuccessful. Despite significant estimates regarding the size of the gray and black markets, it took a decade of gradual effort to establish a regulatory framework capable of delivering measurable results. Today, this three- level defense system relies on the technical blocking of unlicensed websites, a comprehensive ban on advertising prohibited content, and the blocking of related financial transactions. Although official statistics on the exact size of the unregulated market remain unavailable, the robust revenue growth among legal operators over the past three years indicates a successful shift of players away from illegal platforms. For instance, the state operator nearly doubled its total revenue between 2021 and 2025 4 , a surge driven primarily by its betting division. This growth is consistent with stronger channelization, but certainly does not by itself prove migration from unlicensed operators. Even as late as 2024, industry estimates 5 suggested that the gray and black markets still retained a significant market share. However, the soaring profits of the state-run operator and the strong financial performance of the few licensed operators seemingly validated the state's restrictive efforts. Consequently, political decision makers felt little motivation to recognize the inherent limitations of state control in the digital sphere. Instead of adopting a more inclusive regulatory approach – such as fostering regulated cooperation with a broader range of service providers – the government opted to maintain its prohibitive stance. Furthermore, the political drive for reform was dampened by the broader economic boom of the 2010s. The combination of
2 https://www.nytimes.com/1981/05/17/world/new-budapest-casino-pulls-in-western-currency.html 3 https://fdlaw.hu/publications/gaming_betting/Inefficient%20enforcement%20and%20strict%20rules.pdf 4 Please see the annual financial reports of Szerencsejáték Zrt. in the Hungarian language here: https://rolunk.szerencsejatek.hu/hu/ eves-beszamolok 5 https://archive.g3newswire.com/hungary-for-a-piece-of-the-pie-yield-sec/
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REGULATORY REFORM
sustained economic growth and a steady influx of European Union funds meant that the financial impact of lost tax revenue from illegal gambling was largely unfelt. The last time the Hungarian government showed any inclination to open the gambling market to foreign operators was in the late 2000s, during a starkly different and much less favorable economic climate. Admittedly, the focus then was not on liberalizing online gambling, but rather on major foreign investors developing large, Las Vegas-style casino resorts in Western Hungary 6 . These projects would have brought substantial direct capital investment and significant tax revenue. None of these projects ultimately came to fruition, for reasons including financing constraints and political controversy, and they have not been revisited since. Today, however, with the national budget once again showing signs of strain, the argument that gambling is not merely a necessary evil, but a highly lucrative source of state revenue, may finally return to the forefront. Over the last 20 years, there was no strong public demand for comprehensive reform that could have forced a political response. Hungary inherited a gambling market from the socialist era where gambling was not about 'going to the casino', which was long considered a bourgeois pastime. Instead, it was about mass-market games played for small stakes. The proceeds from these games were frequently channeled into state projects, such as sports or housing development funds. With this legacy, and without a broad social base that challenges the traditional 'tolerated but not prohibited' mindset, the push for sensible regulation was supported by only a narrow demographic group. The best example of this was in 2012, when the government banned the operation of slot machines almost overnight. By restricting them to a few casinos, they dismantled an entire industry 7 . Citing national security and player protection
concerns, the Christian-conservative government pushed this program through with almost no public opposition. Later, two unstated arguments helped counter any potential social demand for change. While never officially articulated by the government, they fit perfectly into its broader political narrative. First, there was the idea that Brussels (the EU) should not dictate how Hungary regulates its markets. Second, domestic Hungarian businesses should be favored over large foreign corporations whenever possible. Aided by the public's general indifference, the majority of people quietly accepted that gambling rights were granted exclusively to Hungarian and politically well-connected entrepreneurs. Consequently, this situation was not used as a basis of political attack for many years. The topic only gained real traction in the run-up to the 2026 elections. Even then, it did not emerge as a standalone issue, but rather as part of a broader review of various state concessions, such as motorways and tobacco. Last but not least, a major source of resistance to market reform came from efforts to protect the state-run gambling operator and its associated business circles. Beyond generating profits and tax revenue, the state monopoly has historically played a structural role in the broader ecosystem of the government of the day. The company’s corporate sponsorship subsidiary has drawn intense scrutiny from investigative journalists and transparency advocates 8 . Critics argue that successive administrations have used the state-controlled operator as an off-budget financial reserve, essentially a parallel funding mechanism for political priorities. From this perspective, state dividends are legally rerouted through 'corporate sponsorships' to support entrepreneurs, influencers, and cultural figures aligned with whichever party is in power. Conversely, the official corporate stance highlights the operator as a vital benefactor of Hungarian civil society, sports, and culture. The company maintains
6 https://bbj.hu/business/industry/deals/packer-deals-himself-in-at-hungary-s-eurovegas40544/ 7 https://2010-2014.kormany.hu/en/prime-minister-s-office/news/plans-to-ban-slot-machines-in-hungary 8 A comprehensive article on the subject in Hungarian: https://444.hu/2026/07/20/felbehagyott-puskas-sorozatot-utolag-lepapirozott-tamogata- sokat-es-egy-nap-alatt-kiszort-62-milliardot-talaltunk-a-szerencsejatektol-kikert-dokumentumok-kozott
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that all sponsorship allocations strictly follow legal protocols, benefiting successful entities and ultimately serving the public interest. Ultimately, the focal point of this dispute is not about illegal bribery or covert kickbacks. Instead, it highlights a formalized, legally permissible framework where the substantial revenues of a state monopoly can be systematically utilized to support the political and ideological ecosystem of the incumbent administration. Combined, these circumstances have created a system that fiercely guards the status quo. Over the past two decades, legislation and enforcement have largely functioned as a political arena to protect the beneficiaries of this oligopolistic regime. Legal roadblocks to gambling liberalization The socialist government in power between 2002 and 2010 placed no particular emphasis on gambling. Consequently, the restrictive system established up to that point remained largely unchanged. Given this stagnation, expectations were high following the election of a conservative government in 2010. The industry waited to see if the new administration would rethink gambling regulations. Change did indeed begin in 2011, but not in the way the market expected. The restructuring of the Hungarian gambling market began when the government quintupled the monthly tax on slot machines in pubs and amusement arcades. This heavy fiscal burden placed severe strain on operators, triggering a wave of venue closures. At the time, the street-level slot machine market vastly overshadowed the traditional casino sector, generating more than ten times its gaming revenue.
the crackdown as a response to social welfare concerns and national security risks. Consequently, the previously fragmented, multi-operator market collapsed, consolidating all slot machine gambling strictly within the casino sector. This, however, was only the beginning. The government soon introduced the concept of a 'reliable gambling operator' into the Gambling Act. This designation allowed the state to bypass open concession tenders and enter directly into contracts with operators meeting these criteria. Ultimately, the majority of these scarce concessions were awarded to business groups frequently cited by domestic media as having government affiliations. This created an oligopolistic system of just two to four operators. While the specific owners have changed over time, the highly concentrated market structure remains in place today 9 . The introduction of this system also deeply impacted the online market. Legislation passed in 2015 stipulated that online casinos could only be operated by companies holding a land-based casino concession. Although acquiring such a concession was theoretically possible, it was practically unreachable for new entrants, effectively excluding all independent operators from the digital space. This framework remains largely in force today. Consequently, at the time of writing, only three licensed online casinos operate in Hungary, all managed by the same concessionaire. The path to this restrictive framework, however, was prolonged and erratic. The initial draft bills to regulate the online market emerged as early as 2008 under the then ruling socialist government. The 2010 government transition inevitably slowed this legislative process, delaying the first online gambling amendment to the Gambling Act until 2011. Following this, the statutory definition and regulation of 'remote gambling' underwent numerous, often contradictory, revisions. These iterations swung between highly restrictive measures and more liberalized models before settling on the 2015 legislation.
A decisive turning point came in October 2012, when the Hungarian Parliament outlawed slot machines outside land- based casinos. Virtually overnight, machines disappeared from arcades, bars, and hospitality venues, leaving casinos as the sole legal setting for slot gaming. The government framed 9 Please see the currently effective list of gambling licensees in Hungary here: https://sztfh.hu/nyilvantartasok/engedelyek-kozhiteles/ While the exact reasons for these rapid shifts remain unclear, they likely reflected intense behind-the-scenes lobbying by
IMGL MAGAZINE | SEPTEMBER 2026
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REGULATORY REFORM
competing economic interests. Plagued by constant legislative changes, delayed implementing decrees, and widespread regulatory uncertainty, nearly a decade passed between the first calls for regulation and the launch of Hungary’s first licensed online casino. In a fast-paced digital industry, this represented a significant loss of developmental momentum. Meanwhile, online sports betting met a similar fate. It was ultimately restricted to either the state-run operator or specific concession holders, though, unlike online casinos, a land-based presence was not a prerequisite. However, the most significant legal battles were only just beginning. Several international operators challenged these restrictive provisions, triggering legal reviews that eventually reached the Court of Justice of the European Union (CJEU). Market participants secured major victories against the Hungarian State in two landmark cases 10 . The CJEU ruled that Article 56 of the Treaty on the Functioning of the European Union (TFEU) 11 precludes national legislation that establishes a concession and licensing system for the organization of online gambling if it acts as an unjustified barrier. Specifically, the Court held that such frameworks violate EU law if they contain discriminatory rules against operators from other Member States. Furthermore, even if the rules are technically non- discriminatory, they remain unlawful if applied in a non- transparent manner, or if implemented in a way that prevents or hinders applications from foreign operators. Hungary did not immediately undertake reforms. This created a paradoxical situation: only the designated 'reliable gambling operators' could obtain a concession, but Hungarian authorities were largely unable to enforce deterrent sanctions against unlicensed operators active in the market.
The market operated under these conditions until 2023. At that point, the government shifted its strategy and liberalized the sports betting sector, while leaving the online casino rules untouched 12 . A concession was no longer a prerequisite to running a sports betting website; in theory, anyone could now apply for a sports betting license who meets the requirements set forth by the law. To demonstrate that the new system was not monopolistic, the regulatory authority issued a license in addition to the state-owned operator to one private market participant – predictably, an incumbent operator already running both land-based and online casinos. However, this regulatory 'encouragement' failed to convince independent international players. As of 24 August 2026, the public register lists only two licensed remote-betting operators. Independent operators were presumably deterred by broadly defined technical requirements, which could easily pave the way for an unreasonably protracted licensing process. Consequently, the Hungarian online sports betting sector remains a two- player market. In summary, another decade has passed – this time focused on enforcement rather than legislation – yet the oligopolistic nature of the gambling regime remains the same. Conclusion: a new government – new opportunity or old mistakes? The 2026 election results present the Hungarian legislature with a fresh opportunity to rethink gambling regulation. Driven by campaign pledges, the new government's willingness to enact change is encouraging, even if the primary motivation remains political. Reviewing the privileges of incumbent casino concession holders – who enjoyed heavily protected
10 Case C-49/16 – Unibet International and Case C-3/17 – Sporting Odds 11 Treaty on the Functioning of the European Union, Art. 56: Within the framework of the provisions set out below, restrictions on freedom to pro- vide services within the Union shall be prohibited in respect of nationals of Member States who are established in a Member State other than that of the person for whom the services are intended. The European Parliament and the Council, acting in accordance with the ordinary legislative pro- cedure, may extend the provisions of the Chapter to service providers who are nationals of a third State and who are established within the Union 12 https://igamingbusiness.com/legal-compliance/hungary-regulator-gambling-act/
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REGULATORY REFORM
oligopolies under the previous administration – is a legitimate social demand. Accordingly, an early summer 2026 government decree 13 mandated a review of both current concession agreements and the broader regulatory framework. However, merely terminating the 35-year concessions granted to politically affiliated companies will not create a modern regulatory framework. To move beyond political accountability, the government must adopt a conceptual, industry-focused approach to this rare opportunity. could inadvertently benefit the wider market in these circumstances. If terminating these long-term concession contracts proves legally challenging, the government might avoid open confrontation by introducing competition instead. Stripping incumbents of their protected status would finally open doors for international players who have been effectively barred from the market. Interestingly, political objectives Conversely, to bypass legal disputes, lawmakers might opt to sharply increase gambling taxes or administrative compliance requirements, even while liberalizing the market. While this would successfully dismantle the current license holders' privileged positions, it would severely damage the legitimate industry and risk driving some players toward the black market. Recent history offers cautionary tales: the market turmoil following Romania’s 2023- 2025 regulatory overhaul, and Poland’s similar challenges in 2017, highlight the risks of poorly calibrated reforms. Both attracted substantial criticism from operators and market specialists, although their outcomes are not identical and
Romania’s longer-term effects remain too recent to assess conclusively. Together, they illustrate how reforms may fail to produce a competitive and commercially viable legal market if accompanied by disproportionate taxation, excessive compliance burdens, or abrupt implementation. Such conditions can weaken licensed operators and deter credible entrants, while making the legal market less attractive to consumers. This, in turn, risks shifting activity toward unlicensed providers, weakening consumer protection and tax collection while increasing enforcement costs. Effective reform therefore requires predictable transition periods, proportionate taxation, and licensing rules that allow a diverse regulated market to remain commercially viable. The delicate situation in Hungary would also materially affect the state-run gambling operator, a major beneficiary of the market's artificially maintained lack of competition. Policy makers must intervene with surgical precision to ensure the state operator does not become unintended collateral damage in the reform process. Given the high stakes, lawmakers must step out of the shadow of the past 20 years. They must overcome systemic resistance, learn from regional mistakes, and rewrite the rules based on professional, industry-standard arguments. This may require re-examining fundamental issues previously considered taboo, such as the nature and extent of the state gambling monopoly. As of this writing, the ruling party has not issued a definitive gambling policy statement, and the concession review remains ongoing. We can only hope that, this time, the inertia of the monopoly will not prevail.
DR. GABOR HELEMBAI Attorney-at-law, founder of Dr. Helembai Gábor Law Office For more information contact g.helembai@helembai.com +36 70 33 89 442
13 Government Decree 1203/2026. (VI. 18.) on the revision of the casino concession
IMGL MAGAZINE | MARCH 2026
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ONE-ON-ONE
Keep building connections RASMUS SOJMARK , FOUNDER AND CEO OF SBC EVENTS, TALKED TO EDITOR-IN CHIEF SIMON PLANZER ABOUT HIS COMPANY'S PARTNERSHIP WITH IMGL AND IAGR, AND SHARED SOME OF THE SECRETS OF HIS STAR PULLING POWER.
Simon Planzer: We’re talking on the eve of the SBC Lisbon Summit where the partnership between IMGL, IAGR and SBC will be announced. How did that partnership come about? Rasmus Sojmark: I think the partnership with IMGL is a very natural one for SBC because regulation and legal expertise have become such an important part of the global gaming industry. SBC brings the platform. We bring together tens of thousands of people from across the global industry — operators, suppliers, affiliates, regulators, associations, investors and many other stakeholders. IMGL brings an incredible network of some of the most respected gaming lawyers and regulatory experts in the world. It was successfully wrapped up by Andrew McCarron on our side, Marc Dunbar, IMGL president, and IAGR’s CEO Kevin Mullaly. They were able to build on the good relationship maintained between former president Quirino Mancini and Ben Haden, IAGR president. SP: From your perspective, what do you think the relationship will achieve?
RS: There are two parts for me: a back end part and a public part. The back-end part is where IMGL’s expertise, advice and relationships contribute to how our events come together. For us, that's very valuable because we don't just want our conferences to be big. We want them to be credible and genuinely useful to the people running the industry. And regulation has never been more important. We're operating in an industry where markets are opening, regulations are changing, new technologies are emerging, and there are major discussions around things like AI, prediction markets, responsible gambling, advertising, affordability and player protection. That's where organisations like IMGL are so important. They can help us make sure we're not just discussing what is exciting today, but also the difficult issues that will determine where this industry goes tomorrow. And I think SBC can give IMGL something equally important: a much larger stage and the opportunity to bring that legal and regulatory expertise into conversations with the wider industry.
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1 on 1
RS: When I look back at SBC, it's actually quite difficult to believe how far we've come. We didn't start with some enormous business plan to build one of the world's biggest gaming and tech event companies. We started by bringing people together. That was really the foundation of SBC. I've always believed this industry is built on relationships and respecting the people that have continued to support you. In the early days, we were organising relatively small gatherings and events. Today, we're bringing tens of thousands of people together from all over the world. There have definitely been moments where I've thought, "How did we get from where we started to this?" I’m a big football fan and I well remember the early Betting on Football days at Chelsea’s ground Stamford Bridge. We hosted keynotes and appearances from some of our idols like Peter Schmeichel, Ruud Gullit, Marcel Desailly, Petr Cech, Franco Baresi, and Gaizka Mendieta. We grew our Awards events from a small Octoberfest Pub in Fulham to spectacular gala events at the Natural History Museum in London, and today we host it at MEO Arena in Lisbon. Year by year we managed to scale and retain the quality business and experiences we have become known for, and every year it felt special. We've had some incredible footballers, sports stars, business leaders and personalities involved over the years. And now we're preparing for the SBC Summit in Lisbon with my all- time favourite person: Michael Jordan. If you'd told me when we started that one day we'd have Michael Jordan speaking at our event in Lisbon with Carsten Koerl (Sportradar Founder and CEO) and Jason Robins (DraftKings Co-founder and CEO), I would not have believed you. I don't think anyone would. Even today this still feels like a dream. SP: How did you manage to scale up while keeping a focus on quality and not becoming so big that the events lose their character and uniqueness?
Ultimately, I see the partnership as IMGL bringing some of the world's best legal and regulatory minds into the SBC ecosystem, and SBC giving those voices a global platform. I can also add that we have created some additional strong partnerships that tie closely in with our IMGL partnership. We have formed partnerships with IAGR and are also collaborating with GRAF for the SBC Summit in Lisbon. And we are working closely with key industry Associations in Europe, Latam, Brazil, North America and Africa. SP : You mentioned a public part: What will visitors to Lisbon see as a result of the partnership? There are really quite a few things. We’ve got the Leaders Summit which we’re opening with an announcement of the deal. We have invited many of the regulators and the IMGL members to that event to deal on a very high level with operator CEOs and some of the key supplier and top affiliate CEOs so that should be an exciting day. Then at the SBC Summit itself there is an IMGL super-masterclass on one of the main conference stages and, in addition, we have created new Regulatory Gaming Meetups, which are running over the course of three days. There’ll be over 20 of these focused networking sessions hosted by IMGL and IAGR members and regulators covering most of the European jurisdictions, LatAm, North America and places like New Zealand and Australia. That’s a hugely strong addition to the event where operators can come and meet regulators and IMGL can contribute on the legal side. Rounding off the week we have added in a dedicated day on prediction markets where several IMGL members are participating. So I think you will see the partnership really making a difference to the event. SP: As a veteran of more industry events than I can remember, I genuinely think you strike a balance between the commercial part, high quality content and stellar entertainment, particularly with some huge names on board. I guess it wasn’t always like this. How did you get to this point?
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RS: The thing I think I'm most proud of isn't actually the celebrities or the size of the events. It's that SBC has become a place where the industry comes together. It allows me and everyone at SBC to be part of something special. We are actually creating a place where the industry feels that it belongs. I don’t want to put down my competitors, but I think this is something no other industry organiser can lay claim to. Focusing on relationships and delivering something that works to build them has always been the ambition, even if the scale of it has become much bigger than we originally imagined. That said when you grow a business, things change, of course, and you sometimes forget to take pleasure in what we have actually achieved. Very quickly we are chasing the next goal. But for me that is part of my ambition and the excitement, I have always loved to create and build things, take on new challenges and make something truly special out of it. SP: You’ve featured some big names in the last couple of years. I was at the event last year with some of the biggest names in football. What is the thinking there and how do you get those big names to show up? RS: I've always believed that B2B events don't have to be boring. Business focus and willingness to learn will align more easily when people feel happy and appreciated; when they are allowed to connect with what you offer them in more than one way. As a result, the different experiences create a better outcome for everyone. People are giving us three days of their time. They're travelling from another country, staying in hotels, being away from their families and spending money to attend. We have a responsibility to make those three days memorable and worth the trouble of attending, both when it comes to business ROI and personal experiences. For me there are five pillars of a great event: the trade show, the networking, the conference and content, the education and learning, and the visitor experience. That's what we've always
tried to combine: serious business with great experience. You need excellent content, you need the CEOs, regulators, lawyers and industry experts discussing the issues that genuinely matter. But why can't you also have Michael Jordan? Why can't you have some of the biggest names in sport, entertainment and business? Michael Jordan is not just a sports legend, he’s a leader, an entrepreneur, he’s an inspiration. Then why can't you finish the day with an evening event where The Script will perform? Or an incredible closing party with legendary DJ Tiesto dedicated to all the hard-working exhibitors? I don't see those things as in competition with each other. I think they make the event stronger. Some people might say it takes away from the business and ROI, but I think quite the opposite is true. When you have a well-executed B2B event and people are enjoying themselves, then actually more business gets done. And getting the big names has become easier as SBC has grown, but it's still about relationships, persistence and sometimes being a little bit crazy and ambitious. It’s also about reinvesting into the events, because the stars don’t come cheap. I have always made clear our events are not just about making money. We are in a position to put something back into the industry, to give people the best time and ultimately that makes the business better too. You just can’t do that if you are backed by a private equity house that needs to maximise profit. That takes money out of the industry where we are in a position to invest back into the industry. We have always had big ambitions around the Super Stage. The ambition was to create special moments paired with the greatest speakers in sports, tech and gaming; And when you start asking yourself, "Who is the ultimate name? Who could we bring to Lisbon that would genuinely make people stop and say, wow, SBC has taken this to another level?" Michael Jordan was the name; alongside industry legends like Carsten
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Koerl, CEO of Sportradar, and DraftKings Co-founder & CEO, Jason Robins.
the event is over. The bigger vision is for SBC to help connect the global gaming industry 365 days a year. Our events will always be incredibly important but we also have our news service, our iGaming Daily podcast that I know a number of IMGL members have been part of, we have webinars, we have our Leaders magazine. All of that adds up to better connections between operators, suppliers, regulators, associations, affiliates and other key stakeholders. More opportunities for people to meet and do business. More intelligence and knowledge. And much deeper relationships with the industry throughout the year. That takes investment from our side, but I think it's also at the centre of how events stay relevant. You can't simply build an exhibition floor, put up some conference stages and expect 40,000 people to keep coming. It’s a crowded calendar: people have too many choices. We have to answer a very simple question: "Why do I need to be there?" For an operator CEO, that answer is oftentimes completely different from a regulator, a lawyer, an affiliate or a startup founder. We want to create purpose, belonging, which happens when you deliver outstanding events with focus on hospitality that make people feel great, while achieving their business goals and objectives. SP: The Global Gaming Summit in Lisbon is just around the corner, but what’s coming up next year? RS: You’re right: Lisbon is a global event but I’ve been thinking for a while that we needed something focused just on Europe. So what’s next on the SBC journey is our European Summit in Amsterdam next April – SBC Summit Europe. This is a space carved out to just focus on Europe. And everyone loves going to Amsterdam, right? IMGL will be on that journey with us. We’ve always had a great relationship and we really appreciate the quality that IMGL members bring to our events. And we’re delighted to have you on board for that journey.
SP: So how are you going to top this year's lineup?
RS: Every year my team probably wishes I'd stop asking, "OK, what's bigger?" But that's part of SBC. I never want us to say, "That was good enough, let's just do it again." I don't know whether you necessarily top Michael Jordan by finding someone more famous. You top it by making the entire experience better – better people, better conversations, better networking, better content and more reasons for the most important people in the industry to be there. So, all I can say is “watch this space” SP: What’s next for SBC, youy vision for the future of the industry and how will your events stay relevant? RS: I would say that we started by connecting people, we grew by connecting more of the industry and our future is about connecting the entire gaming ecosystem. But we also know that we have to earn that place. You cannot take anything for granted. I have always had that mindset: I try never to get complacent, never think we’ve made it even when the business is approaching a couple of hundred people. Yes it’s a growth story, but at the same time, you can never take things for granted. SBC Summit is becoming the annual global gathering point for the industry. I love it when I see more and more people adding SBC to their yearly schedule as they’ve done with ICE for many years. In my opinion, and this is backed up by the people I speak to, SBC offers a far superior event experience and better content, and is more ideally placed in the calendar year with September compared to mid-January when it comes to budget and business planning for the coming year. So we have a lot going in our favor. But I don't want the relationship between SBC and the industry to start when somebody registers for an event and finish when
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REGULATION IN AUSTRALIA
Could Europe’s Digital Services Act be used to curb promotion of black market gambling? DSA’S HORIZONTAL FRAMEWORK HAS PLUSES AND MINUSES WHEN IT COMES TO ENFORCEMENT ACTIONS AGAINST PROMOTIONS OF UNLICENSED GAMBLING SERVICES, FIND LUÍS CARVALHO, TANIA PINHO AND MARTA BOTICA SANTOS
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of illegal products online. The response stopped short of committing the Commission to any dedicated inquiry into gambling-related illegal content promotion. Instead, it largely restated existing DSA obligations, such as the notice-and- action mechanism and systemic risk assessment duties, without explaining how these horizontal tools would address the sector-specific challenges of identifying unlicensed gambling content. The response is legally cautious as it leaves a central practical question unresolved: whether the general enforcement powers available under the DSA can be deployed effectively in this sector. This exchange, though narrow in its immediate institutional context, exposes a deeper tension within the European Union's regulatory architecture for digital services. It invites scrutiny of a central proposition that this article seeks to interrogate. The DSA, notwithstanding the formal enforcement powers it confers upon the Commission, exhibits an enforcement gap when applied to the dissemination of unlicensed gambling content online. The gap is not simply an absence of legal authority, but arises from the interaction between the DSA’s horizontal, cross-sectoral framework and the predominantly national regulation of gambling. It is particularly pronounced in relation to content promoted by operators who deliberately circumvent national licensing requirements and target European consumers through major digital platforms. The analysis that follows considers these issues in turn, placing the Verheyen exchange within the broader context of the DSA's tiered obligations, its enforcement practice to date, and the national and jurisprudential developments that illustrate the practical limits of applying a horizontal regulatory framework to the specific context of unlicensed gambling operators. What is striking is the disproportionality between the scale of the problem and the institutional response. Industry data points to a multi-billion-euro market of unlicensed
Introduction In April 2026, Sabine Verheyen, a Member of the European Parliament from the European People’s Party, Germany, submitted a written question to the European Commission (EC) that raised fundamental questions about the practical enforcement of the Digital Services Act (DSA) in the online gambling sector 1 . The DSA, which has been in full application since February 2024, was designed to establish comprehensive obligations for digital intermediaries. Verheyen’s inquiry challenged whether those mechanisms are proving effective in practice, particularly against the promotion of unlicensed gambling services targeting European consumers. The question is therefore not simply whether the DSA applies, but whether it can deliver meaningful intervention where illegality is defined through fragmented national licensing rules rather than a single EU standard rule. The inquiry asked whether the EC is aware that online content creators established or active within the Union are actively promoting unlicensed gambling services to substantial audiences, and whether the Commission intends to open an investigation into this practice 2 . In support of this inquiry, Verheyen invoked empirical findings from a 2024 study conducted by Yield Sec 3 and commissioned by the European Casino Association (ECA). The study estimated that approximately 71 percent of online gambling activity directed at European users occurs on unlicensed platforms, a figure that, if accurate, would point not merely to a significant market presence but to a serious weakness in the combined capacity of national licensing regimes and EU- level enforcement mechanisms to protect consumers from unregulated gambling operators. The Commission's reply, issued on 12 June 2026 under the authority of Executive Vice-President Henna Virkkunen 4 , acknowledged in general terms the issue of undisclosed advertising on online platforms, as well as the promotion
1 iGaming Expert (2026) European Commission questioned over Digital Services Act enforcement against illegal gambling. Available at: https:// igamingexpert.com/features/ec-dsa-2026-illegal/ 2 European Parliament (2026) Parliamentary question E-001475/2026: Questions submitted by Sabine Verheyen to the European Commission. Available at: https://www.europarl.europa.eu/doceo/document/E-10-2026-001475_EN.html 3 European Parliament (2026) Answer to Parliamentary Question E-001475/2026 (ASW): Reply from the European Commission. Available at: Parliamentary question | Answer for question E-001475/26 | E-001475/2026(ASW) | European Parliament 4 Ibid
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