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Comparison with Spain and France
1) Regulation architecture
Portugal: dual-circuit model - land according to Lei do Jogo (DL 422/89), online since 2015 (separate mode). Regulator - SRIJ (as part of Turismo de Portugal).
Spain: land regulated by autonomies; online - nationally through DGOJ. Strong fragmentation by region "on the ground," uniform digital standards online.
France: ANJ Unified Supervision (formerly ARJEL). Accurate typologization of products and high intensity of law enforcement.
Conclusion: in terms of transparency and unity of the rules "land + online," Portugal and France look solid; Spain is more "mosaic" due to autonomies, but strong online.
2) Product licensing and tolerances
Online:- Portugal: Since 2015, online betting, casinos and poker (under separate licenses) have been legal.
- Spain: online betting and casinos are legal, strict technical requirements, a rich live ecosystem.
- France: historically liberal betting and poker; online slots/casinos were limited for a long time, then sequentially adjusted through the clarification of the framework and pilots (in reality - phased evolution).
- Portugal: concessions in the "zones of the game" (Estoril, Algarve, Madeira, etc.).
- Spain: wide map, autonomies have rules.
- France: historic casino chain (resorts/resort towns), strong theater and gastronomic scene.
Conclusion: for a full online portfolio (bets + casino + poker) Portugal and Spain provide a more direct path; France demands a more nuanced legal strategy.
3) Taxes (generally, logic on GGR)
Portugal: benchmark - bets 8-16% GGR, casino 25% GGR (separate accounting).
Spain: differentiated load by type of games and autonomy; online - a single national circuit, the overall effective rate is moderate, but regional fees "on the ground" are significant.
France: traditionally higher fiscal burden on some verticals and detailed reporting.
Conclusion: Portugal is convenient in practice for the predictability of the formula; Spain demands to model the regional nuances of offline; France - plan "stock" by margin.
4) Advertising and Communications
Portugal: tough tone (18 +, anti-heroization, RG banners), legal screening of creativity, emphasis on own channels and neutral content.
Spain: One of the strictest regimes in the EU; after ship adjustments, the general stiffness vector is preserved. Classic football sponsorships cut; bet on CRM/content.
France: strict rules and close supervision of ANJ, special attention to the protection of youth and transparency of offers.
Conclusion: in all three countries, "quiet" strategies win - product, CRM, educational content and RG communications.
5) RG (game in charge) and KYC/AML
Portugal: self-exclusion, deposit/time limits, reality checks, mandatory logs and payment replayer.
Spain: enhanced RG practice (self-exclusion registries, strict push rules, neutral UI).
France: high RG standard and age barrier checks, tight operator reports.
Takeaway: Top three lead on EU RG; interfaces "limits in 1-2 clicks" and metrics RG - must have.
6) Payments and payment speed
Portugal: bank cards, local methods, e-wallets, strict AML filters; crypto - only through permitted providers with fiat fixation.
Spain: strong localization (including mass rapid methods), payment SLA - critical retention KPI.
France: conservative payment architecture, high security standard.
Conclusion: Spain sets the bar for UX speed; Portugal - in discipline and cleanliness of accounting; France - for security.
7) Product trends
Live betting and multi-match streams: peak maturity in Spain; are growing steadily in Portugal; in France - neat expansion within the rules.
Fantasy/esports: Spain - developed stage and media; Portugal is a niche but growing segment; France is a regulated evolution with strong RG control.
Casino shows and live tables: popular in Portugal and Spain; in France they are introduced "carefully" and step by step.
8) Tourism and offline value
Portugal: resort-urban model (Estoril, Algarve, Madeira), bet on non-gaming (F&B, show, MICE) and cultural integration.
Spain: megacities and resorts, synergy with La Liga, gastro scene and events.
France: historical resorts, premium formats, museum and theater collaborations.
Conclusion: it is appropriate for all cities to increase the non-gaming share of 30-45% for sustainability.
9) Law enforcement and combating illegal immigrants
Portugal (SRIJ): blacklists of domains, payment curbs, API supervision.
Spain (DGOJ): system locks, cooperation with payment/data providers.
France (ANJ): high frequency of inspections and public reporting on measures.
Conclusion: three markets are characterized by "zero tolerance" for illegal immigrants; legal payments and fast KYC are key to channeling traffic.
10) Crypto and Web3 (questionable)
Portugal: let's say "crypto-in/fiat-out" through allowed gateways with full KYC/AML; anonymity - prohibition.
Spain: approach similar, focusing on RG and advertising; "clean" cryptocasinos - out of the field.
France: conservative position, priority of fiat accounting and proven payment circuits.
11) Pros/cons for operator (short)
Portugal: + predictable tax and reporting formula, seamless oversight; − smaller market than Spain.
Spain: + large market, reference live-UX; − very strict advertising and regional complexity "on the ground."
France: + high level of trust and consumer protection; − increased fiscal and procedural burden, slower expansion of the product line.
12) KPI and management boards (common standard of three markets)
Activation/KYC pass-rate, Time-to-bet, Time-to-payout.
Live share, rPS, Cash Out usage, Stream→Bet CTR.
RG indicators (limits, timeouts, early risk signals).
Effective tax rate on verticals and SLA reporting.
NPS and share of calls/disputes, replayer-closability of cases.
13) Input/scaling recommendations
Portugal: go "clean" portfolio (bets + casino + poker), immediately build replayer and RG-UX "in 2 clicks," keep a high reporting discipline.
Spain: bet on mobile/live, multimatch and fast payout; in marketing - CRM and content instead of sponsorship on T-shirts.
France: plan a long payback horizon, legal accuracy of offers and provability of 18 + targeting; gradually expand the product.
Portugal, Spain and France are the EU's three "strong but different" approaches. Portugal takes integrity and predictability (SRIJ, simple GGR tax logic and transparent reporting). Spain leads mobile live-UX with extremely strict advertising. France is a benchmark for consumer protection and enforcement, but with a higher procedural burden. For the operator, the choice is a balance between scale (Spain), stability and clarity of rules (Portugal) and a premium reputation with tight control (France).