Bulgarian Stakeholders Welcome Proposed Restrictions But Warn They Could Boost Black Market

July 8, 2025
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A Bulgarian gambling trade group and others have warned that the government's proposal to restrict risky gambling behaviour could push players to the black market and is “not supported by established European regulatory models”.
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A Bulgarian gambling trade group and others have warned that the government's proposal to restrict risky gambling behaviour could push players to the black market and is “not supported by established European regulatory models”.

The Association of the Gaming Industry in Bulgaria (AGIB) sent its opinion on the Restricting Risky Behaviour in Online Betting draft law to the Minister of Health, the Minister of Finance and the executive director of the National Revenue Agency (NRA), which supervises gambling activity in the country, on July 7.

AGIB says the draft legislation, published on June 5 for public consultation, is a “positive step” to protect vulnerable individuals and promote “controlled behaviour on the part of consumers”.

However, it warns that the law, which proposes to limit the time spent on online betting websites, introduce loss limits as well as maximum bet amounts, will redirect vulnerable players to other licensed sites, and “also to many illegal gambling sites”.

Several key issues highlighted by the AGIB include a need for a centralised solution to prevent operators from redistributing bets and losses between them to allow customers to bypass restrictions, making responsible gambling measures “meaningless”.

Additionally, the trade body warns that the plan to add people who have reached spending limits to a self-exclusion register for seven days without explicit legal consent could contradict people's constitutional right to freedom of personal choice and economic freedom.

“We note that unregulated online gambling is already flourishing, according to official data, over 6,400 unlicensed betting sites are present in the NRA [block] list. Therefore, we propose that the draft regulation be revised towards more centralised, balanced, legally justified and practically feasible measures that achieve the protection objectives, without threatening the legal market,” AGIB said.

Sofia-based lawyer and gambling compliance expert Georgi Dimitrov similarly told Vixio GamblingCompliance that “any steps towards regulating risky behaviour are commendable”, but the mechanisms in the draft law have “not been thought over very well considering the local gaming environment and recent practices on an EU level".

He believes there is a significant risk that the law will drive players to the black market, adding, “There are plenty of examples of overregulation attempts in European jurisdictions where the inability to cope with unlicensed operators and restrictive regulations has led to channelling a higher percentage of gambling activities to the black market.”

“Considering that the target audience is individuals with gambling problems or underage users means that the law should work in their favour and should be able to apply to platforms simultaneously, as such players can be flexible and can easily switch to easily accessible and unprotected alternatives,” Dimitrov said.

On July 1, a consultation response posted by ARZ Solidarity, a non-governmental association that provides support for gambling addicts in Bulgaria, welcomed the draft, sharing its own opinion, "especially since the state has so far not paid sufficient attention to both the prevention and treatment of gambling addiction”.

However, it also has a long list of concerns, such as a lack of clarity on how the maximum time spent on an online betting website is determined, and loss limits allowing 10 average monthly salaries or five for people under the age of 24 to be lost in a day.

ARZ’s proposal is for the draft law to be revised with the help of gambling addiction experts, including from gambling operators, and that “all regulations be aligned with best practices from Europe”.

“The reasons should clearly indicate what the proposed regulations are based on, as well as what the expected results are based on,” ARZ said.

On June 16, 2025, Bulgaria notified the European Commission of the draft regulation.

The notification’s standstill period ends on September 17, 2025.

Separately, on June 17, 2025, a new gambling law was submitted to parliament, proposing to end the local licensing system currently in place in Bulgaria and establish a state-owned gambling monopoly.

Supplier licensing is also proposed for the production, distribution, service and import of gaming equipment.

An explanation accompanying the draft law said the changes are needed to address “the large increase in gambling addiction” in Bulgaria and tackle the “abuse of private gambling operators against the country’s tax, legislative and political system”.

The proposals show a clear intent from Bulgarian authorities to address rising public concerns around gambling addiction.

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