IMGL Magazine September 2026

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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