Spain's Snap Election Sinks Its Loot Box Ban but Leaves the Deposit Limits Standing

Pedro Sánchez's dissolution of the Cortes kills the only gambling-related measure that was actually before parliament, a ban on minors buying loot boxes. The Gambling Act reform never got that far, and the rules that matter most to operators were made by decree, where the election cannot reach them.

• Royal Decree 806/2026, published in the Boletín Oficial del Estado (BOE) on 6 October, dissolves the Cortes and calls a general election for 29 November, after Congress rejected two housing decree-laws on 2 October
• The ban on minors accessing paid loot boxes, Article 5 of the organic law on protecting minors in digital environments, lapses with the dissolution: the bill was still at report stage in the Justice Committee 18 months after the government sent it to Congress
• The Gambling Act reform does not lapse because it never reached parliament: the Directorate General for the Regulation of Gambling (DGOJ) has only held a prior consultation, which closed on 22 June
• Rules made by royal decree and regulator resolution are untouched: joint deposit limits of €700 a day, €1,750 a week and €3,300 over four weeks take effect on 25 March 2027, and new mandatory gambling ad warnings were published in the same edition of the BOE as the dissolution
• The trade body Jdigital said in September it had no expectation the reform could become law this legislature, and has announced a Supreme Court challenge to the deposit limits, which now face the courts rather than the voters

The Cortes Are Dissolved, and Only One Gambling Measure Was Inside Them

Prime Minister Pedro Sánchez announced the dissolution in an institutional declaration on 5 October. Royal Decree 806/2026 sets the campaign from 13 to 27 November and convenes the new chambers on 23 December. At a press conference the next day, Sánchez tied the decision to Congress's rejection of his housing decree-laws "last Friday" and said the government would "continue governing" until the election, approving two new housing decree-laws for the Diputación Permanente, the standing body that sits while the chambers are dissolved, to validate.

Under Article 207 of the Rules of the Congress of Deputies, dissolution lapses every matter pending before the chamber, except those the Diputación Permanente must hear. For gambling, that catches one item. The Organic Law for the protection of minors in digital environments, presented by the government on 27 March 2025 and processed under the urgent procedure, would bar minors from "random reward mechanisms": paid video game features whose random outcome is a virtual item exchangeable for money or other virtual items. The committee's rapporteurs met on 29 September and said work would continue "in the coming weeks", according to Europa Press. The bill now dies, along with its better-known plan to restrict social media for under-16s.

The Gambling Act Reform Was Still a Questionnaire

The larger project never left the ministry. On 18 May the Ministry of Social Rights, Consumer Affairs and Agenda 2030, through the DGOJ, opened a public consultation on amending Law 13/2011, covering celebrities and influencers in gambling advertising, customer acquisition promotions, search engine advertising and wider risk warnings. The consultation document states that it was held before any text was drafted, under Article 26 of the Government Act, Law 50/1997. Submissions closed on 22 June. No draft has been approved by the Council of Ministers, so there is nothing to lapse. Cristina Romero de Alba, a partner at Loyra Abogados, called the election "a significant pause, and potentially a change of direction" for the reform, according to GamblingNews.

Decrees and Resolutions Carry On

The government is not a caretaker yet. Article 21 of Law 50/1997 says it ceases after the general election and then continues in office with limits: it must confine itself to ordinary business and may not present bills to Congress. Until 29 November it keeps full regulatory powers, and the DGOJ keeps working. The BOE that carried the dissolution decree also published a DGOJ resolution, signed by director general Mikel Arana on 18 September, replacing the "play responsibly" message in gambling adverts with rotating warnings, among them that the probability of being a player who loses money is 75%. It takes effect 60 days after publication, with three months' grace for existing advertising contracts.

Royal Decree 520/2026, published on 25 June, enters into force on 25 March 2027 and requires the regulator to give operators a test version of the joint deposit limit system six months beforehand. The DGOJ's mandatory problem-gambling detection mechanism was still a draft resolution at the end of June, according to Loyra Abogados. Enforcement is unaffected too: the block on Polymarket and Kalshi stands, and the audiovisual regulator fined Gol TV's owner over betting adverts this month.

The Loot Box Ban Is the Real Casualty

Spain's loot box measure was the most concrete gambling-adjacent law in the pipeline, and it died not because it was defeated but because a bill on urgent procedure spent 18 months in committee. Restarting it is not a formality: a new government must approve a bill again for Cortes that only meet on 23 December, and it rode inside a broader bill whose social media limits drew the political attention. A narrow, standalone loot box measure might travel faster in the next legislature. Until then, Spain has no specific statutory rule on paid random rewards for minors.

The Ministry's Most Consequential Rules Never Needed Parliament

The rules operators will feel in 2027 were made by decree and resolution, which is why the election barely touches them. That is also their weakness. In April 2024 the Supreme Court annulled parts of the 2020 advertising decree for lack of legal basis, and Jdigital now questions whether the deposit limits fit the legal framework, according to Sector del Juego. Putting the advertising curbs on a statutory footing was a central aim of the Gambling Act reform. The election has postponed the step that could have given the ministry's decrees firmer legal ground, just as Jdigital brings its challenge.

The Industry Had Already Priced In the Next Legislature

Jdigital's open letter of 21 September said that, with the legislature in its final phase, there was no expectation a reform "of this magnitude" could complete its parliamentary passage, and that the work should be seen "with a horizon that extends beyond the current legislative term". It plans a joint document for early 2027. Dissolution has simply fixed the date. Whoever holds the consumer affairs portfolio next inherits a consultation, not a text, alongside a regional bloc that wants a say in any rewrite of the law.

The election has taken one gambling measure off the road to the statute book. The decrees that remain will be judged by the Supreme Court, and the law they lean on will be rewritten, if at all, by the next government.