Jdigital Publishes Open Letter on Future Online Gambling Regulation Model

Spain’s online gambling framework is often described as settled. It isn’t. Law 13/2011, the statute that brought licensed online betting and casino games into the Spanish market, is now under review by the Dirección General de Ordenación del Juego (DGOJ), and the country’s digital gambling trade association has decided not to wait for a draft to react to. In late September 2026, Jdigital published an open letter setting out its strategic position on the reform, arguing for an online gambling regulation model built for the next decade rather than patched to fix the last one.

Jdigital’s open letter: what it actually proposes

The letter is a position statement, not a draft bill. Its central argument is about horizon: Jdigital wants the reform of Law 13/2011 treated as a once-in-a-decade opportunity to design a long-term regulatory framework, one that accounts for technological change and the way people actually consume digital entertainment now, instead of legislating for the market as it looked in 2011.

Three things stand out in the association’s framing:

• Ambition over incrementalism. Jdigital calls for ambition, rigour and constructive dialogue with the authorities and the DGOJ, with the stated goal of consolidating a legal ecosystem that is balanced, attractive and competitive.
• A structured contribution, not a press release. The association announced the creation of three specialised working groups made up of operators, experts and other participants in the digital ecosystem.
• A defined deadline. The groups’ conclusions are to be consolidated into a single joint document towards the start of 2027, timed to feed the legislative debate rather than trail it.

Two of the working groups’ remits are spelled out. One covers market competitiveness: putting the regulated environment on an equal footing against illegal operators, technological adaptability, and the economic sustainability of the sector. The second covers player protection and how it should evolve. This gambling industry open letter is essentially a commitment to arrive at the consultation table with homework done.

The reform timeline so far

Why the 2011 framework stopped fitting the market

The problem Jdigital is pointing at is not that Law 13/2011 was badly drafted. It is that the law predates almost everything that now defines online gambling: live dealer studios streaming in real time, crash games with provably fair verification, app-first sign-ups, instant payments, and marketing that lives inside social platforms rather than television ad breaks.

When a licensing framework is written around one technological era and then amended piecemeal, two things tend to follow. Compliance costs rise for licensed operators because each amendment adds a new obligation without retiring an old one. And the gap between what licensed sites can offer and what unlicensed sites offer widens, which is exactly the channelisation problem the competitiveness working group has been asked to examine. Regulation that pushes players toward operators with no licence, no identity verification and no self-exclusion tools produces worse player protection outcomes, not better ones. That is the causal chain Jdigital is putting on the record.

What a durable online gambling regulation model has to cover

The letter sets direction rather than clauses, so the detail below is analysis of what any decade-length framework needs to get right, informed by the themes Jdigital has flagged.

Licensing requirements

A licensing framework ages badly when it enumerates permitted products. Game formats change faster than statutes; a list written today will be incomplete within three years. The more durable approach defines licence categories by risk profile and obligation, then lets the regulator authorise new formats against those criteria. Alongside that, three things matter in practice: predictable renewal terms so operators can plan multi-year investment, proportionate requirements that do not make a mid-size licensee economically unviable, and clear rules on where suppliers and affiliates sit in the chain of responsibility.

Consumer protection measures

Player protection is the second named working group, and the useful distinction is between measures that limit harm and measures that merely limit convenience. Deposit, loss and session limits, cooling-off periods, self-exclusion registers and reality checks are the standard toolkit. What has changed since 2011 is the data: operators can now identify markers of harm from play patterns, not just from a player’s own stated limits. A modern framework has to say what operators must do with that capability, and set the privacy boundaries around it.

Two design points are worth flagging. Protections only work if they reach the players who need them, which means they have to be inside licensed products players actually use. And they have to be tested against outcomes, not compliance box-ticking, or the industry ends up with expensive rules and unchanged harm figures.

Compliance standards and oversight

Compliance is where the cost of bad drafting shows up. Regulatory oversight for a decade-long framework works better with technical standards that can be updated by the regulator (certification of random number generators, RTP disclosure, reporting formats, anti-money-laundering thresholds) than with detail hard-coded into primary legislation. The same logic applies to advertising rules, which have been the most contested area of Spanish gambling policy in recent years and the one most exposed to legal challenge when the drafting is imprecise.

Industry impact and the gaps the letter targets

The immediate practical effect is procedural. By announcing working groups and a delivery date, Jdigital has set itself up to submit a consolidated industry position early in 2027, which is a stronger position than responding to a published draft line by line. Operators, suppliers and affiliates now have a channel for input, and a deadline against which to prepare their own data.

The gap the letter addresses most directly is the absence of a stated long-term objective for the Spanish market. Reviews of gambling law often proceed issue by issue: advertising here, bonuses there, limits somewhere else. Jdigital’s argument for future gambling regulation is that the reform should start from what the market should look like in 2036 and work backwards. Whether the DGOJ accepts that framing is another matter, and it is fair to note that a trade association asking for a more competitive regulated environment has obvious commercial reasons for doing so. The argument still deserves testing on its merits.

What makes gambling regulation sustainable

Sustainable gambling regulation, on the evidence of how European markets have developed, tends to share a handful of features:

1. It is technology-neutral. Obligations attach to risks and functions, not to named product types.
2. It measures channelisation. If the regulator doesn’t track what share of play sits inside the licensed market, nobody can tell whether a rule helped or hurt.
3. It is economically viable for licensees. A framework only licensed giants can afford concentrates the market, which is rarely the stated policy goal.
4. It is built on evidence and reviewed on a schedule. Fixed review points beat emergency amendments.
5. It is drafted with the people who have to implement it. Hence the working groups.

None of this changes the underlying maths of gambling. Every licensed game carries a house edge, the house profits over time, and regulation exists to make that transparent and the harm containable rather than to alter the odds. Players who want to stay in control should use the deposit and session limits and self-exclusion tools their operator is required to provide.

For readers tracking the wider picture, our coverage of how online gambling licensing requirements work and what compliance standards operators face sets out the mechanics behind these proposals. The letter itself is published by Jdigital; the reform is being led by the DGOJ.

Frequently asked questions

What is the Jdigital open letter?

A public position statement issued by the Spanish digital gambling association in September 2026, setting out its stance on the review of Law 13/2011 and calling for a long-term regulatory framework for the next decade. It also announced three specialised working groups whose conclusions will form a joint document in early 2027.

How should online gambling be regulated?

Effective frameworks combine a licensing regime defined by risk rather than product lists, enforceable player protection tools such as deposit limits and self-exclusion, technical standards for fairness and reporting that the regulator can update, and measurement of how much play stays inside the licensed market.

What makes gambling regulation sustainable?

Technology neutrality, proportionate costs for licensees, evidence-based review at fixed intervals, transparent measurement of channelisation, and consultation with the operators and suppliers who have to implement the rules.

If gambling has stopped being entertainment for you, national helplines and operator self-exclusion tools are available. Gambling is for adults only.