Bulgaria Notifies Brussels of Its Full Gambling Ad Ban, With a 22% Online Fee and a €100,000 Monthly Floor

Bulgaria notified the European Commission of its draft Gambling Act amendments on 2 October, closing the procedural gap that left Lithuania's promotion ban unenforceable. The text, still out to consultation and not yet before parliament, would end affiliate licences in January and charge online operators at least €100,000 a month.

• The European Commission registered Bulgaria's draft amendments to the Gambling Act on 2 October as notification 2026/0536/BG under Directive (EU) 2015/1535
• The draft, which the government announced on 23 September, bans advertising of gambling games, operators and their trademarks "regardless of the form, manner and place of distribution" but keeps sponsorship of licensed sports clubs and federations
• Every affiliate licence would be terminated from 1 January 2027, and the National Revenue Agency could order the blocking of websites, apps, social media profiles and streaming platforms that advertise gambling
• The online fee would rise from 20% of stakes less winnings to 21% in 2027 and 22% in 2028, with a minimum of €100,000 a month per operator, and payment providers would hand the state any fee above 1.5% of a gambling transaction
• Consultation closes on 23 October and no government bill has yet been tabled in the National Assembly, where rival opposition bills have waited since early September

Bulgaria Takes Its Advertising Ban to Brussels Before It Takes It to Parliament

Bulgaria has taken its gambling reform to the European Commission. The Commission's Technical Regulation Information System (TRIS) shows notification 2026/0536/BG, received on 2 October from the Ministry of Finance's tax policy directorate. It summarises the draft as providing for "a full ban on advertising of gambling games and gambling organisers and a ban on the promotion of gambling games by affiliate operators". The record flags fiscal measures and lists the end of the standstill period as "not applicable", as it does for other notifications carrying fiscal measures.

The notification answers a problem raised in the consultation. In March 2025 the Court of Justice of the European Union ruled in Unigames (C-120/24) that a Lithuanian ban on encouraging online gambling, applied to an operator's own website, was a "technical regulation" under Directive (EU) 2015/1535, and that failing to notify it made the rule unenforceable against private parties. Several consultation comments cited the ruling and noted that the bill's explanatory memorandum did not mention the procedure.

The Ministry of Finance's consultation, number 12738-K, opened on 23 September, runs until 23 October and had drawn 21 comments by Tuesday. Only after it closes can the Council of Ministers approve the bill and send it to the National Assembly, whose register showed no government amendment to the Gambling Act as of 6 October. The law is meant to take effect on 1 January 2027.

What the Text Says That the Announcement Did Not

The draft is more specific than Prime Minister Rumen Radev's announcement. Alongside the general ban, a new Article 10 permits only the information needed to play, on an operator's website and premises; broadcasts of draws by the state-owned Bulgarian Sports Totalizator; and facade signs on licensed venues of no more than 20% of the facade and 50 square metres, a tenth of it carrying the warning "Gambling carries a risk of developing addiction", with no illuminated or moving panels.

Sponsorship survives in a narrower form than the "sports kit and facilities" exception described in September: operators may sponsor licensed sports clubs, federations and associations, and events supporting culture, health and education, showing only their registered trademark or company name. Branding is barred on kit for minors, and broadcasters may not add digital sponsor branding to televised or streamed events beyond the signs physically at the venue.

Enforcement sits with the National Revenue Agency (NRA), which has regulated gambling since the State Commission on Gambling was abolished in 2020. It could order the blocking of websites, apps, social media profiles and streaming platforms that advertise gambling. Anyone who publishes gambling advertising would face a fine of €10,000 to €20,000, or €20,000 to €50,000 for a company, doubled for a repeat offence. Under Paragraph 79, every licence issued to an affiliate operator is terminated from 1 January 2027.

A 22% Online Fee With a €100,000 Monthly Floor

The variable fee on online gambling, now 20% of stakes less winnings, would rise to 21% from 2027 and 22% from 2028, with a floor of €100,000 a month per operator, according to the draft and its impact assessment. The one-off online licence fee of BGN 400,000 becomes €400,000, roughly doubling it after the switch to the euro. Operators could keep 1% of the fee in 2027 and 2% from 2028 if they give it to licensed Olympic sports federations and professional football clubs as sponsorship, advertising or donations.

Banks, payment institutions and e-money firms would pay the state any part of their fee on a gambling deposit or payout above 1.5% of the transaction. Foreign online licensees would need a registered place of business in Bulgaria by 30 June 2027 or lose the licence, and casinos and gaming halls would have to connect their machines to the NRA's systems by the same date.

Opposition, Media and Affiliates Push Back

The opposition wants the ban tighter. Assen Vassilev, leader of We Continue the Change, said on 24 September that betting shop facades, penalties and the definition of trademarks left gaps, and that "the only measure that has worked in the United States for online gambling has been cooperation with banks and credit card issuers", according to the Bulgarian News Agency (BTA). His party filed its own Gambling Act bill on 4 September, and Democratic Bulgaria MPs, with Bozhidar Bozhanov as first sponsor, filed another on 9 September, according to the parliament's register.

In the consultation, affiliates argue that ending their licences pushes players to unlicensed sites, media and advertising businesses object to the ban's breadth, and some commenters say requiring central systems to sit in Bulgaria breaches EU data rules.

Notifying Brussels Closes the Door Lithuania Left Open

Unigames made procedure the industry's strongest defence: an unnotified promotion ban cannot be enforced against an operator. By notifying before the bill reaches parliament, Bulgaria removes that argument. Member states keep wide discretion over gambling under EU case law, so the stronger challenges are likely to target the place-of-business and server requirements, which touch the freedom to provide services more directly than an advertising rule does. Whether Brussels or another member state comments on them is the next thing to watch.

The Sponsorship Exception Is Funded by the Tax Increase

The draft bans almost every channel except the one that pays for Bulgarian sport, then routes part of the tax rise back to the same clubs and federations through the 1% and 2% retention. That places Bulgaria closer to Belgium, which bans most advertising and is phasing out sponsorship, than to Italy's 2018 ban on both, and it echoes the near-total online ban the Netherlands is planning. Brands stay on shirts and in stadiums while disappearing from screens, billboards and affiliate sites. The retention also gives clubs and federations a direct interest in the higher rate passing. The opposition's argument that the exception is too wide will be the main fight in committee.

The €100,000 Floor Will Thin the Licensed Market

A minimum of €1.2 million a year per online operator, owed whatever its revenue, plus a local place of business and the loss of affiliate and media marketing, weighs most on the smallest licensees. That matters for channelisation in a country that hoped euro adoption would weaken its black market. The draft leans on blocking orders to hold the line, while Vassilev argues that only cooperation with banks and card issuers has worked. Either way, it makes licensed play more expensive at the moment it strips licensed brands of their visibility.

Bulgaria has done the procedural work that undid Lithuania's ban. Whether the economics hold up is a question the consultation, the Commission and then the National Assembly will answer in turn.