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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IMGL MAGAZINE | SEPTEMBER 2026
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