Andrei Cosma
Partner

“One of the professionals with the highest degree of understanding (and capacity to explain to others) the specific technical functionalities of a gambling infrastructure”, Andrei is a business lawyer with substantial expertise in the regulatory field across practice areas.

His credentials are enhanced by his previous role as a Group Legal Counsel with a high-growth B2B SaaS company.

Substantially involved in the gambling industry from the beginning of the reformation of the Romanian legal framework and well-versed in dealing with all legal aspects related to the operation of gambling activities, Andrei also provides assistance on intricate projects for global iGaming and eSports entertainment operators and services providers, with a strong component of compliance structure design, implementation and monitoring, policies and procedures creation and review, risk and operational advisory.

He also specializes in new technologies, including blockchain, cryptocurrency, AI or fintech. With a strong AML practice, he hols an AML International Advanced Certificate from the International Compliance Association.

Andrei is a member of the Bucharest Bar and of IAGA.

Adela Nuță
Managing Associate

With an extensive regulatory background, Adela’s primary focus is data privacy and regulatory compliance, with an edge in GDPR aspects and anti-money laundering (AML) frameworks.

She helps companies implement robust personal data protection procedures, including managing legal compliance for a diverse portfolio of clients in gaming and gambling, IT, retail, energy, and construction.

Adela coordinated and contributed to the development and implementation of comprehensive policies regarding data privacy and AML. These include intricate audits, risk assessments, and training sessions that helped clients safeguard sensitive information against emerging threats and prevent financial misconduct while ensuring compliance with international and domestic regulations.

She holds an LLM in Judicial Careers, and, complementing her legal studies, Adela has a second university degree in marketing and international economic affairs.

Adela is a member of the Bucharest Bar.

GAMBLING LEGAL FRAMEWORK OVERVIEW

Introduction: Evolution of the gambling landscape

Over the past decade, Romania has emerged as one of the most structurally regulated gambling markets in Central and Eastern Europe. Anchored in a licensing framework that has progressively aligned itself with European Union standards, the Romanian gambling regime has developed from a fragmented, transitional structure into a coherent and prescriptive legal ecosystem. Both land-based and online gambling operations are permitted in Romania under a comprehensive licensing regime that distinguishes between Class I licences, granted to business-to-consumer (B2C) operators and Class II licences, which apply to business-to-business (B2B) service providers. All licensees are subject to extensive regulatory, technical, operational and fiscal obligations, under the supervision of a centralised regulatory authority: the National Gambling Office (ONJN).

While Romania’s regulatory environment remains formally liberalised, its evolution has been marked by a gradual shift toward increased state oversight and more prescriptive compliance expectations for operators, alongside a growing institutional focus on the protection of vulnerable players, particularly minors and individuals at risk of gambling addiction, as well as on AML enforcement and social responsibility. This trajectory reflects a broader regional and EU-level trend, wherein member states seek to balance market accessibility and fiscal consistency with safeguards aimed at mitigating gambling-related harm.

At the same time, Romania’s regulatory approach has often been marked by frequent legal amendments and short-term legislative reactions, shaped more by public pressure and political urgency than by a consistent and forward-looking policy strategy.

In recent years, particularly between 2022 and 2024, the regulatory framework has been further recalibrated through targeted amendments introducing new rules on advertising restrictions, geographic limitations for slot-machine venues, self-exclusion systems, operator taxation and mandatory fiscal presence. For example, slot halls are now prohibited in towns with fewer than 15,000 inhabitants, operators must establish a permanent establishment in Romania, and the responsible gambling contribution has increased tenfold. Additional reforms addressed AML compliance, minimum technical requirements, and the creation of a centralised self-exclusion register. As of 2025, Romania continues to refine its legal and institutional structures to meet emerging risks and challenges—such as the proliferation of unlicensed content and technological disruption, both domestically and in alignment with broader European regulatory trends.

Market Overview

Romania today hosts a diverse gambling market that includes a full spectrum of land-based and online activities. All traditional forms of gambling are generally permitted provided the operator obtains the requisite license and authorization from the National Gambling Office (ONJN) in advance. In the land-based sector, licensed offerings range from casinos and poker clubs to betting shops and slot-machine gaming salons. The country’s capital, Bucharest, and major cities host thousands of slot machine halls and betting agencies. Slot machines remain extremely popular, making this the dominant land-based game category. However, recent reforms have tightened market parameters: as of 2024, standalone slot halls are banned in towns below 15,000 population, effectively pushing these venues out of small communities.

In the online sector, Romania has embraced a regulated model since 2015-2016, licensing dozens of international and domestic operators under its Class 1 regime. All major categories of online gambling are allowed under law, with appropriate licensing. Online sports betting is fully legal, covering fixed-odds betting as well as pari-mutuel and betting exchange products. Online casino gaming is permitted; notably, a single online casino license authorizes the full suite of casino-style games, including slots, roulette and table games, as well as peer-to-peer games like online poker. In contrast, online lottery remains off-limits to private firms due to the state lottery monopoly.

Overall, the regulated online market in Romania is still thriving, with both domestic and international operators active under local licenses. Nevertheless, a parallel ecosystem of unlicensed foreign websites continues to offer access to Romanian users without meeting the national licensing and compliance requirements. In response, ONJN has intensified its enforcement efforts by maintaining an official blacklist of unauthorised domains and collaborating with internet service providers to block access at the network level.

Regulatory framework and licensing conditions

Gambling activities in Romania are tightly regulated under a coherent legal framework initated by the 2015–2016 reforms. The cornerstone is Government Emergency Ordinance No. 77/2009 on the Organization and Operation of Games of Chance (GEO 77/2009), a primary act that has been amended multiple times (most substantially in 2023). Detailed implementation rules are set out in Government Decision No. 111/2016 (GD 111/2016). Together, these instruments define what activities are deemed gambling, specify licensing categories, and impose operational requirements on licensees. GEO 77/2009 includes the fundamental definition of a gambling (a participation fee, random outcome, prize, and public offering) and distinguishes land-based games from remote games based on whether they are conducted via communication networks.

Romania’s gambling framework also interlocks with other legislation, particularly in the area of anti-money laundering. Law No. 129/2019 on preventing and combating money laundering and terrorism financing, which implemented the EU’s 4th and 5th AML Directives, applies to gambling operators as “obliged entities.” This means all B2C licensees must conduct, among others, customer due diligence (KYC checks), monitor transactions, and report suspicious activity in line with national AML regulations. To assist the industry, in late 2021 ONJN issued sector-specific AML guidelines for the industry.

The licensing system is two-tiered. Class 1 licenses are required for any business-to-consumer (B2C) gambling operator offering games directly to players in Romania (whether land-based or online).

Each Class 1 operator must also obtain specific authorizations for the particular games they offer (for example, a betting authorization or casino game authorization) in addition to the general license. In addition to obtaining a ten-year license, operators must also secure an annual authorization for each gambling product they offer, which is subject to renewal and is conditional upon compliance with tax, reporting, and operational requirements.

Separately, Class 2 licenses apply to business-to-business (B2B) providers of gambling-related products and services, such as software developers, platform suppliers, payment processors, marketing affiliates or auditing and certification labs. The Class 2 regime ensures that all key service providers who partner with Romanian operators are vetted and approved by the ONJN. Licensed B2B providers are prohibited from offering their services to operators that do not hold a valid Romanian gambling licence, but which unlawfully allow access to their platforms for the Romanian market.

One cornerstone B2C licensing condition is the requirement of local establishment. To maintain a license, an operator must now have a significant presence in Romania. In late 2023 the government tightened this rule: gambling may only be operated “through a locally established company” in Romania, or through a company based elsewhere in the EU/EEA or Switzerland that has registered a permanent establishment for tax purposes in Romania. In practice, this means that foreign operators must either incorporate a Romanian subsidiary or open a Romanian branch (and register for Romanian tax) in order to hold a Class 1 license.

Alongside the corporate presence, the regulator imposes technical infrastructure obligations: online operators whose primary servers are located abroad must install “mirror and safe servers” on Romanian soil to mirror all gaming data for the ONJN’s access. These servers enable real-time monitoring of transactions, ensuring that Romanian authorities can independently verify wagers, payouts, and revenue. Additionally, all online gaming platforms and random number generator (RNG) systems must be tested and certified by an accredited lab (holding a Class 2 license) before going live, to guarantee fairness and compliance with technical standards.

Applicants for a gambling license are subject to a thorough vetting process. They must demonstrate transparency of ownership, solid financial standing, and an absence of relevant criminal or regulatory offenses. The licensing rules also mandate substantial financial guarantees and insurance to cover potential tax debts. Notably, the 2023 amendments radically increased the required guarantee amounts: starting 1 January 2025, online operators must post a guarantee of €2 million (or €5 million for online casino platforms), and land-based operators generally €1 million (with casinos at €3 million).

Overall, Romania’s licensing conditions reflect a highly prescriptive approach. The ONJN expects licensees to maintain a permanent and transparent footprint in the country, comply with detailed technical specs, and continually update the regulator about any changes in their operations or corporate structure.

Trend and developments

Protecting players and vulnerable persons has become an increasing focus of Romanian gambling law, especially following legislative developments since 2022. All licensed operators are required to implement robust consumer protection measures and promote responsible gambling practices as a condition of maintaining their license. Access to gambling is strictly limited to individuals aged 18 or older, and operators must verify player identity and age through official documentation. These obligations aim to prevent underage access and block self-excluded individuals from gambling.

The most significant reform introduced in recent years to enhance player protection has been the obligation of the regulator to create a centralized national self-exclusion register. Under the current law, each licensed operator maintains its own exclusion list which may inherently lead to inconsistent enforcement and enabled self-excluded players to simply migrate to a different platform. GEO 82/2023 amended the primary legal framework (GEO 77/2009) and mandated the establishment of a single, national Register of Self-Excluded Persons, to be managed by ONJN.

While the legislation initially imposed a deadline of 31 March 2024 for the implementation of the exclusion system, the platform was not fully functional by that date (and continues to be unfunctional at the beginning of May 2025). However, ONJN implemented provisional measures during the transition period, including the distribution of exclusion lists via mail channels and requiring manual enforcement by operators.

In May 2025, ONJN clarified that the current centralized self-exclusion database does not apply to online operators, but only to retail locations and that the legislation will change so online operators are also included in the spectrum of this restriction.

In the meantime, ONJN has already taken operational steps to ensure functionality during the transition. A provisional version of the national self-exclusion register is expected to become active by mid-May 2025, enabling land-based licensed operators to implement centralized self-exclusions. This interim system will provide real-time verification capabilities and support the ongoing enforcement of exclusion requests. According to the authority’s implementation calendar, the temporary system will remain in place throughout 2025, while a public procurement process is launched for the development of a permanent, fully integrated IT solution.

Full deployment of the national exclusion infrastructure is expected by the second quarter of 2026. Until then, the interim arrangements will remain operational, ensuring continuous enforcement of self-exclusion and uninterrupted protection for vulnerable players.

Advertising

Gambling advertising in Romania is subject to detailed restrictions intended to curb excessive promotion and protect minors and other vulnerable groups from inducement. The ONJN, together with other bodies like the National Audiovisual Council, oversees compliance with advertising rules. By law, all gambling advertising must respect general standards for responsible content it cannot target minors, encourage irresponsible gambling, or mislead about chances of winning. Advertisements must include responsible gambling messages and avoid depicting gambling as a solution to financial or personal problems.

Restrictions apply both to the substance of advertising and to the channels through which it may be disseminated. Gambling promotions are strictly prohibited inside or the fences of schools, kindergartens, churches etc. Outdoor advertising is further constrained by a 2023 emergency ordinance that limits the maximum surface area of gambling-related billboards to 35 square meters, a rule introduced to eliminate oversized displays on building facades and other large urban structures.

Television advertising is also regulated through a “watershed” rule: gambling commercials are permitted only after 11:00 PM, to limit exposure during hours when children and teenagers are more likely to be watching. One narrowly defined exception applies to sports betting messages that are still permitted during live sports events, including before the 11:00 PM threshold.

In addition, legislative proposals currently under parliamentary review seek to prohibit gambling advertisements featuring celebrities or public figures whose influence may affect vulnerable audiences.

Taken together, these measures reflect a steadily tightening regulatory climate, in which gambling advertising remains legal but is subject to increasing scrutiny. While several restrictions are already enforceable, others are still under legislative consideration. The overall trajectory suggests a shift toward more protective advertising standards and growing political momentum to address the social risks associated with aggressive marketing in the gambling sector.

In summary, while Romania has built one of the most tightly regulated gambling frameworks in the region, the system remains a work in progress. Its long-term effectiveness will ultimately depend not only on enforcement capacity, but also on political will, social pressure, and the broader policy climate. As reforms continue to unfold, the challenge will be to maintain regulatory coherence while adapting to new risks and rising expectations for player protection.