Comparison with Hungary and Bulgaria

Romania, Hungary and Bulgaria are three neighboring markets in Central and Southeast Europe that went through notable gambling reforms from 2023 to 2025. Below is a system comparison along the main axes: regulator and licensing, taxes, advertising and responsibility, market access/geo-blocking, technical requirements and provider landscape.

1. Licensing Regulators and Models

Romania is a tiered licensing model overseen by Oficiul Național pentru Jocuri de Noroc (ONJN): separately licensed operators (Class I) and suppliers/affiliates (Class II). Foreign (EU/EEA/Switzerland) operators are allowed to comply with local requirements (tax "presence," certification, reporting).

Hungary - in 2023, the transition from a monopoly to a model allowing private operators was completed: the market is open for online sports, regulated by SZTFH (Supervisory Authority for Regulatory Affairs). Clarified technical requirements and decrees after amendments to the Law on Gambling.

Bulgaria - Unified Gambling Law; control passed to the National Revenue Agency (NRA). For online operators, there is mandatory licensing according to Bulgarian rules.

Conclusion: all three jurisdictions are licensed and "white," but Romania is historically the most "debugged" in the EU format (classes of licenses), Hungary is the "new" liberalized market after 2023, Bulgaria is mature, but with active point changes.

2. Taxes and fiscal burden (trends 2024-2025)

Romania - traditionally applied an authorization tax to online operators at the GGR level (in 2024, sources indicated 21% with a minimum annual threshold of €400k), but in 2025 the government announced/adopted a package with an increase in rates (it was reported an increase to 27% for online and 23% - retail), as well as an increase in rates for players and fixing some fees. It is important to clarify the current rates at the time of launch.

Hungary - liberalization was accompanied by the establishment of licensing requirements and technical standards; fiscal architecture changed less "dramatically" in 2024-2025, focus on compliance and access control (see below).

Bulgaria - for online operators, a tax is applied on the "difference between rates and winnings" (20%), a one-time license fee for 5 years and a corporate tax (10%) are valid.

Conclusion: Romania in 2025 became "heavier" in terms of the total fiscal burden, Bulgaria - moderately tough with an understandable formula and a reasonable corporate tax, Hungary - medium in load, but very demanding to comply with the rules.

3. Advertising, sponsorship and work with influencers

Romania - consistent tightening: in 2025, control over advertising in social networks and the involvement of public persons has been strengthened; since autumn - additional restrictions on the use of famous sports/cultural persons. Operators should review SMM policies and contracts with influencers.

Bulgaria - since May 2024, strict restrictions have been introduced, in fact, "near-total ban" on advertising games, as well as remote requirements for outdoor advertising and placement near schools/children's areas (300 m and measurement method).

Hungary - a common vector for compliance and restraint; the key emphasis of the regulator is not so much on advertising as on technical compliance and the availability of sites only for residents according to the rules.

Conclusion: Bulgaria is the "toughest" in advertising, Romania is quickly catching up (especially on social networks/ambassadors), Hungary is moderately restrictive, but with a strong emphasis on compliance.

4. Market access, extraterritoriality and blockages

Romania - allows EU/EEA market players with local presence and ONJN list (local servers are not required, but certifications/data repositories/reporting are needed).

Hungary is a pronounced extraterritorial jurisdiction: services available from Hungarian IPs are subject to national law, which is also supported by the practice of enforcement after 2023. We expect a strict line to "offshore."

Bulgaria - strict local license through the NRA; without it - the risks of blocking and sanctions.

Conclusion: all three markets are characterized by an "anti-offshore" vector, but Hungary noticeably emphasizes extraterritoriality.

5. Technical/Operational Requirements

Romania - an entrenched certification, reporting system, Class II for suppliers, clear expectations for AML/KYC and responsible gambling; ready-made road maps for obtaining licenses.

Hungary - updated technical standards SZTFH (2023), mandatory measures to protect players and technical security, domain/network compliance.

Bulgaria - NRA requirements for financial stability, reporting and technical capabilities for online operators; stable server/certification practices.

6. Providers, Products, and Local Features

Romania is a mature ecosystem with a wide presence of international studios and live casinos; the market supports betting/slot/live/virtual sports verticals. (The overall profile is confirmed by industry reviews 2024-2025.)

Hungary - accelerated integration of international brands after liberalization, but with a high "entry bar" due to regulatory rigor.

Bulgaria is a strong local production cluster (historically EGT, etc.), while advertising regulation in 2024-2025 affects marketing and growth.

Practical conclusions for operators and investors

"Fast start" and the breadth of integrations - Romania: a tested licensing path and a mature partner infrastructure, but carefully consider P&L due to an increase in fiscal burden in 2025.

"High-compliance" growth - Hungary: the market is young and promising, but increased access control and technical requirements mean increased upfront costs for compliance and localization.

"Maturity with an advertising press" - Bulgaria: an understandable tax model and a license for 5 years, but aggressive advertising restrictions require relying on CRM, SEO/ASO and partners instead of ATL media.

Final "difference map"

The most "heavy" in taxes in 2025 is Romania (fresh changes). Bulgaria is a moderately rigid but stable formula; Hungary - without sharp fiscal swings, but strict compliance control.

The toughest in advertising is Bulgaria (almost widespread bans); Romania is rapidly increasing restrictions (especially on social networks and with ambassadors); Hungary - focus on technical compliance.

Licensing is open to foreign market players in all three countries, but entry barriers and a set of procedures differ; in Hungary - increased attention to extraterritoriality.

Editorial note: Figures for rates and fees in Romania changed actively in 2024-2025; when preparing the final version of the article for publication, be sure to check the current value of taxes and advertising restrictions on the primary sources of ONJN/NRA/SZTFH and fresh legal reviews.