The use of Codere’s name in the headline of a recent ruling from Spanish regulators has been criticised as creating “an inaccurate and disproportionate impression”, according to Fernando Martín, Partner at Loyra Abogados.
Codere was among three regulated operators highlighted as the authorities announced sanctions worth €33.5m to 32 gambling operators in Spain. However, $30m of the total fines were attributed to six illegal operators.
The Spanish gambling group argued that its inclusion within the Ministry of Social Rights, Consumer Affairs and Agenda 2030’s headline alongside 888 and Betfair unfairly grouped them in with more serious offenders, given its fine totalled a measly €17,500 of the total figure.
Martín said: “For licensed operators such as Codere, 888 or Betfair, these cases relate to administrative compliance issues. They involve failures in technical controls, internal procedures or reporting obligations. They do not relate to illegal gambling activity.
“By contrast, the €5 million fines issued to offshore operators correspond to very serious infringements and come with website and payment blocking. These are aimed at disrupting unlicensed activity.
“This difference is essential. Mixing both types of operators in a single headline creates confusion and can damage reputations. This episode illustrates why such a distinction is essential, especially at a time when consumer confusion between legal and illegal platforms is growing.”
Black market confusion
Alongside sanctioning each illegal operator €5m, the DGOJ has blocked their websites. However, the sanctions illustrate the strength of Spain’s illicit gambling market.
Recent data from EY and Jdigital revealed that 23.4% of Spanish players have used illegal gambling websites, and the market has grown to be worth €231m in 2024, approximately 16% of the value of the regulated market.
Mirroring similar findings to those in the UK, the research found that the distinction between the legal and illegal remains increasingly blurred for players.
“One of the most striking findings is the level of confusion among consumers. Almost half of the players who believe they only use legal “.es” sites have actually accessed illegal platforms, including domains such as “.com” or “.bet”. This lack of awareness is a major cause of exposure,” explained Martín.
“32.1% of players aged 18 to 24 do not realise they are using illegal operators, making them one of the most exposed demographics.
“Illegal operators exploit these weaknesses with aggressive promotions, unlimited stakes, faster payments and a strong presence on digital channels. Platforms such as YouTube, TikTok, Instagram, Telegram, and payment methods like Bizum and cryptocurrencies are central to their strategy of attracting Spanish players outside the regulated system.”
Regulating the suppliers
The DGOJ is currently considering a raft of significant reforms, including tighter restrictions on advertising and promotions, and the implementation of a regulator-developed risky player behaviour monitoring system.
Alongside this, for the first time in Spain, B2B providers will be required to register with the DGOJ, marking “the beginning of direct supervision over the technological backbone of the industry”.
“The reform introduces a clear obligation for providers to ensure that their systems are not used by unlicensed operators,” concluded Martín.
“They will need to adopt both technical safeguards and contractual controls to prevent their platforms, software or RNGs from ending up in the illegal market. This shifts part of the responsibility for enforcement onto those who develop and supply the technology.
“In addition, a licensed operator will only be allowed to certify or approve a technical system if the supplier is properly registered. This creates a direct link between the regulatory status of B2B providers and the compliance obligations of licensed operators, tightening oversight across the entire chain.”
