As the country prepares to cautiously implement deposit limits across operators, Spain has to be vigilant of the surging black market, as the offshore market grew by 102% last year.
Spain is set to begin the six-month test period for its new cross-operator deposit limit system later this year on 25 September, ahead of a full rollout near the end of March next year.
Speaking on the recent Gaming in Spain webinar, Josh Hodgson, Chief Operating Officer at H2 Gambling Capital, revealed that even amidst a surging black market, the firm expects Spanish iGaming GGR to rise to €1.91bn in 2026 with a 78% channelisation rate.
Hodgson said it’s the fifth biggest by GGR, generating €1.74bn across online betting and gaming last year, with a growth rate of 51% over the past three years.
Raising concerns over the growth of the offshore market, Hodgson stated: “Whilst this growth has come from a relatively small base, it’s still a very concerning rate of growth, which is something we’ve seen across many European markets over the same timeframe.
“That’s been due to many things, but one of the most prominent being the explosion in crypto casinos in their popularity during that timeframe. So, with sort of that backdrop in mind, the introduction of cross-operated deposit limits is a concern for the market when we consider that there is already very strong offshore growth inherent in the market.”
Before the cross-operator deposit limits were introduced, H2 Gambling Capital forecasted the Spanish iGaming market would generate €2.1bn GGR in 2027.
Now, it expects around a €300m decline in onshore player spend, with around €80m of this going directly to offshore operators, resulting in a net reduction in player spend of around €220m, a 7% headwind in both 2027 and 2028.
Hodgson added: “However, given the strong underlying growth of the market, it doesn’t lead to an overall market decline in either year, but it does result in a stagnation of the growth that we have seen across this period.
“The increase in the offshore spend will lead to around 6% increase in growth in the offshore market across both those years. By the end of 2028, we now forecast the onshore market to generate GGR around €2.05bn vs €1.9bn in 2026, so not much growth at all considering how fast Spain has been growing over the previous years.
“Whereas, in the offshore market, we expect it to grow to a GGR of around €820m vs €590m in the current year, which will reduce the channelisation rate from its current rate of 76% in 2026 to 74% in 2027, and then we expect it to stabilise at around 71% in 2028 onwards.”
Xavi Munoz, Managing Partner at ECIJA Barcelona, noted that operators in the country must start preparing on a technical, operational and legal standpoint to make sure they are ready for the test period.
This includes changing their terms and conditions to meet the requirements after a new deposit limits system was approved via Royal Decree last week, with the full rollout set for 25 March 2027.
Cross-operator deposit limits
Cross-operator deposit limits were announced by the Directorate General for the Regulation of Gambling (DGOJ), the Spanish regulator, and were designed to create stronger protections for players wagering with multiple operators.
Set by default for every player in the Spanish iGaming market, deposit limits will include €700 per day, €1,750 per week, as well as €3,300 over four weeks. Customers can voluntarily remove or modify deposit limits to their preferences, but this requires a specific procedure involving extra safeguards.
Munoz said: “On 25 September, the DGOJ starts the test period for six months. Operators have to do all necessary actions to improve the system and to inform players of everything.
“Operators have to start preparing technically, operationally, and from a legal point of view as well. From our side, operators will have to change their terms and conditions. They will have to explain that the data will be sent to the DGOJ, will be checked, and will be returned.
“They have to change their privacy policy in terms of this type of processing of personal data that they will be doing, and they will have to do a privacy impact assessment on this particular processing of data.
“This is on 25 September, so it’s quite close. Then the deadline for the cross operator deposit system to start is six months later on 25 March 2027, but don’t be misled, because the test starts on 25 September.”
Hosted by Gaming in Europe Founder Willem van Oort, Munoz and Hodgson were also joined on the Spanish iGaming webinar by Camille Gonzálvez, TMT & iGaming Lawyer at ECIJA.
The webinar covered several topics, including a general regulatory framework update, a market update and growth projections, as well as an exploration of prediction betting and existing Spanish iGaming licences.
Later in the webinar, Gonzálvez provided a detailed perspective of prediction markets in Spain, offering a historical overview of their presence in the country and across Europe, the precautionary measures introduced against unlicensed providers and whether prediction betting could become part of the Spanish iGaming regulatory framework.
