Reversal on Advertising Restrictions Leads Spain Recovery but Market Drag Continues

In late 2020, the Spanish government implemented a comprehensive ban on online gambling advertising and promotions. The legislation, Royal Decree 958/2020, included the banning of welcome bonuses, restricting advertising to late-night hours, prohibiting celebrity endorsements, and cutting ties between gambling operators and sports sponsorships. Aimed at reducing gambling harm, particularly among young and vulnerable people, the restrictions significantly altered the market in what was marked as one of the most restrictive gambling markets in Europe.  

In April 2024, Spain’s Supreme Court partially reversed key elements of the 2020 advertising restrictions, ruling several parts of the legislation exceeded the government's legal authority. The reversal reinstated welcome bonuses, influencer and celebrity endorsements, and digital advertising placements, including on YouTube. These changes were driven by mounting industry pressure over the ban’s commercial impact, particularly on new player acquisition. However, restrictions on sponsorships in sport and protections aimed at minors remained in place, preserving the main aspects of the original legislations’ consumer protection goals.

As expected, the introduction of the original legislation led to a sharp decline in market growth. Gross Gaming Revenue, GGR, dropped 4% in 2021 – the first year of decline since regulation in 2011. While a ‘post Covid’ decline could be blamed for this, other European markets were still seeing the benefit of Covid lockdowns – with Spain being the only major onshore market to see GGR declines, and the average European onshore online market GGR increased by 25% year on year in 2021. Below we show what the Spanish online market would have looked like had it tracked the European average growth over this period (in the 4 years prior to the ban, the Spanish and total Europe growth was at a very similar rate, making this a reasonable comparison).

Spanish Online Gambling GGR and Implied GGR Without Advertising Restrictions (€m)

Source: H2 Gambling Capital, November 2025

Promotional Spend and New Accounts

Player numbers followed a similar trajectory to GGR, with total players decreasing by 1% in 2021, but it was new accounts that were impacted the most. In the 3 years prior to the ban, new accounts increased by an average of 16% per year, while promotional spend increased by an average of 29% per year. By contrast, during the three years of the ban, the number of new accounts fell by 55% as total promotional spend fell by 13% over this period.

After the legislation was partially reversed, 2024 new accounts surged by 35% compared to 2023, as total promotional spend increased by 31% year on year.

Spain Year on Year Growth in New Online Gambling Accounts and Promotional Spend

Source: H2 Gambling Capital, November 2025

The fact that a ban on advertising spend led to lower promotional activity, which in turn led to fewer new player sign-ups, is not something that will come as a surprise – this was widely expected when the ban came into place. However, the scale of the market disruption – both when the ban was implemented and when it was partially repealed, shows the significant impact that regulations have on a licensed market.

While lower growth of the online market in Spain may be viewed as a positive thing by the Government, one should be aware of unforeseen consequences – one of which is that this appears to have acted as a catalyst for growth in the offshore market, which had previously been declining. While we acknowledge that the offshore market across Europe as a whole has seen a pick-up post-Covid, with the proliferation of unlicensed crypto-casinos, the scale of the jump in the Spanish market, at the exact time of the ban on promotional activity of the onshore market, suggests that this was likely a contributor to the jump in offshore activity between 2020 and 2023. As the industry (but apparently not all Governments) knows well – gambling activity rarely disappears – it merely gets displaced to illegal sites that don’t have the same restrictions.

Spain Year on Year Growth in Onshore vs Offshore Online GGR

Source: H2 Gambling Capital, November 2025

With the Government looking to re-instate some of these advertising / promotional restrictions, licensed operators will be hoping that any changes will be done in a way that allows them to continue to promote their legal activities to players, and that this will not lead to another jump in growth for illegal market operators.