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 holds 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 gambling compliance, data privacy, as well as anti-money laundering (AML) frameworks and corporate law.

 

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.

 

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.

Romania – 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 complex 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 (and more recently also for B2B licensees), alongside a growing institutional focus on the protection of vulnerable players, particularly individuals at risk of gambling addiction. 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.

This trend emerged a few years ago and continued also in 2025 and beginning of 2026. Thus, in the recent years, the local industry has experienced constant tax increases (the latest change in this sense occurring in 2025), more restrictions in terms of advertising (the latest occurring at the end of last year) as well as more obligations and permits required in order to lawfully conduct their operations. All these changes have inherently created a consistent pressure for operators and suppliers alike which were required to adapt their activities in order to comply with the new regulatory and enforcement principles of the Romanian authorities.

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 (i) the requisite license and authorization from the National Gambling Office (ONJN) in advance, as well as (ii) an additional authorization from the local authorities where operations are to be performed, this new requirement being introduced as part of legislation change in February 2026.

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 used to host thousands of slot machine halls and betting agencies. Slot machines are extremely popular, making this the dominant land-based game category. However, recent reforms have tightened market parameters: starting with 2024 standalone slot halls have been banned in towns below 15,000 population, effectively pushing these venues out of small communities. Further on, in February 2026, a new legislation has been enacted whereby local authorities can decide whether or not land-based gambling is permitted in their area and, if so, the additional local tax that must be paid by each operator. This new legislation is already creating an unprecedented wave of legal complexities whereby various rules, restrictions and related new local taxes are established throughout the country for land-based halls. In this context, a notable trend is that several cities have decided to completely ban land-based gambling in their municipalities.

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 (and constantly updating) 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 complex legal framework initiated 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, 2025 as well as beginning of 2026). 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 “reporting 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. Further on, following a legislative change enacted in February 2026, land-based operators will be required to obtain, besides the permits from ONJN, also local authorizations from each municipality where they intend to operate.

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.

Further on, following a change of the legislation in force since end of July 2025, several categories of B2B licensees are subject to monthly reporting obligations to ONJN aimed to disclose to the regulator the concrete blocking measures taken in relation to unlicensed operators that are active in Romania.

One cornerstone B2C licensing condition for online operators 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 use a EU entity that has registered a permanent establishment for tax purposes in Romania.

Alongside the fiscal 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 (extended with additional €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 the Romanian regulator, especially starting with 2025. The most significant reform has been the obligation of the regulator to create a centralized national self-exclusion register. Under the current law, each online 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. On the other hand, land-based operators rely on a somehow centralized platform managed by ONJN and this difference implementation logic between online and retail has inherently created confusion for players and generated numerous legal issues.

In March 2026, the Government has published a draft emergency ordinance meant to clarify the inconsistencies from the current regime and create a national database for self-excluded players to be managed by ONJN for both retail and online sectors.

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.

Starting with October 2025, the National Audiovisual Council has issued a new secondary legislation whereby sport personalities or marketing influencers (among others) are prohibited to appear in gambling commercials.

In addition, legislative proposals currently under parliamentary review seek to prohibit gambling advertisements completely or ban online advertising during certain time intervals.

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.

Taxation

July 2025 marked the latest wave of increases for taxes imposed on the gambling industry. This wave emerged in 2022, but it appears to be of continuous interest for the political stakeholders. The most notable change is the increase of the GGR tax due by online operators from 21% to 30%.

Local authorizations for land-based operators

Following a legislative change enacted in February 2026, local authorities have the power to determine whether or not land-based gambling is permitted in their municipality. This marks a significant shift in the regulatory logic, whereby land-based operations are no longer under the scrutiny of ONJN, but also local authorities have an important role in determining the viability of the land-based sector.