Gaming in Spain Webinar Points to Licensed Prediction Betting Path Amid DGOJ Regulatory Push

Key Takeaways

• Prediction Betting Fit: Current rules allow betting on sporting events as player-versus-player with the operator as intermediary, potentially opening the door for licensed prediction betting limited to sports or horseracing.
• Deposit Limits Timeline: Six-month testing begins September 25, with full cross-operator deposit limits scheduled for March 25, 2027.
• Spend and Channelisation Impact: Introduction expected to trigger a €300m annual decline in onshore player spend, with channelisation falling from 76 per cent to 74 per cent in 2027 before stabilizing at 71 per cent from 2028.
• DGOJ Proposals: Public consultation covers stricter player ID requirements to curb tax evasion, a registry for approved B2B software suppliers, and additional advertising restrictions, all requiring new primary legislation.

“Current rules allow betting on sporting events where players bet against other players with the operator only acting as an intermediary.”

That assessment, offered by Camille Gonzálvez during a recent Gaming in Spain webinar, underscores a potential route for licensed prediction betting even as enforcement actions target unlicensed platforms. Gonzálvez, TMT & iGaming Lawyer at ECIJA, outlined how this intermediary structure could accommodate prediction markets if confined to sports or horseracing.

As covered by G3 Newswire, the webinar convened Xavi Munoz Bellvehí, Managing Partner at ECIJA Barcelona, Camille Gonzálvez, and Josh Hodgson, COO of H2 Gambling Capital, to review Spain’s regulated iGaming developments. The discussion surfaced both tightening oversight and pockets of regulatory flexibility.

DGOJ Consultation Targets Illegal Gambling and Tax Evasion

The DGOJ has launched a public consultation on amendments to Spain’s Remote Gambling Act. Proposals include stricter player ID requirements aimed at preventing income tax evasion, creation of a registry for approved B2B software suppliers, and further advertising restrictions aligned with prior government efforts.

All three changes would necessitate new primary legislation. These steps are direct responses to persistent illegal gambling activity and compliance gaps in the current framework.

Hodgson provided supporting market data, reinforcing the regulator’s focus on measurable outcomes over incremental tweaks.

Cross-Operator Deposit Limits Introduce Revenue Pressure

Just before the webinar, the Spanish government approved a new framework for cross-operator deposit limits. Testing commences on September 25. Full implementation follows on March 25, 2027.

H2 Gambling Capital estimates the measure will produce a €300m decline in annual onshore player spend. Channelisation, currently at 76 per cent, is projected to drop to 74 per cent in 2027 and settle near 71 per cent from 2028 onward.

These figures signal a structural shift. Operators face not only lower overall spend but also a measurable migration toward less channelised channels. Preparation for the testing phase will require updates to compliance systems and customer messaging well before the 2027 deadline.

Prediction Betting Gains Traction Under Existing Rules

Despite recent DGOJ enforcement proceedings against Polymarket and Kalshi, the webinar identified room for licensed prediction betting. The intermediary model already embedded in sports betting rules appears compatible, provided activity stays within sports or horseracing parameters.

González’s explanation highlighted that operators would not take direct risk positions but instead facilitate player-to-player outcomes. This distinction matters. It positions prediction betting as an extension of permitted activity rather than an unregulated novelty.

With prediction betting growing in popularity, Spanish-licensed operators could capture incremental engagement. The webinar recording, available via the G3 Newswire report, elaborates on implementation nuances.

Transaction Volume Calculations Limit Competitive Edge

The competitive position of prediction markets versus traditional sports betting operators tends to be significantly overestimated. This caution, raised explicitly in the webinar, stems from differences in how transaction volumes are calculated and reported.

Prediction markets generate high notional turnover through frequent position adjustments, yet the underlying economics differ from fixed-odds sportsbooks. Operators evaluating entry must therefore discount headline volume figures and focus on actual revenue contribution and customer acquisition costs.

This limitation tempers enthusiasm. It also underscores the need for granular product-level analytics before committing resources to new verticals.

What This Means for Operators

Spanish operators and their client-partners should treat the September 25 testing start as an immediate operational milestone while monitoring the DGOJ consultation outcomes for longer-term legislative impact. The intermediary pathway for sports-focused prediction betting offers a regulated entry point that aligns with existing licenses, yet the projected €300m spend reduction and channelisation erosion to 71 per cent will compress margins and demand sharper retention strategies.

What remains underemphasized in the coverage is the practical integration cost for B2B suppliers entering the new registry and the competitive recalibration required once prediction products launch at scale. Investors and regulators alike will watch whether this balanced approach can sustain innovation without accelerating leakage to unlicensed channels. The October 15 Gaming in Spain Conference, featuring Mikel Arana as headline speaker, should provide further clarity on these execution questions.