Portugal - SRIJ: Taxes and AML
(Section: "Markets and Jurisdictions")
1) Regulator and frame
SRIJ (Serviço de Regulação e Inspeção de Jogos) - control, regulation and inspection of ground games and online games/betting; operates in the Turismo de Portugal system together with the Comissão de Jogos (Games Commission).
Online is regulated by RJO - Regime Jurídico dos Jogos e Apostas Online (Decree Law No. 66/2015 and subsequent changes).
2) Licenses and tolerances (online)
Online licenses are issued by SRIJ by type: fixed odds betting, fortune/gambling games (casino games), online bingo, etc. Only locally licensed operators and the state lottery monopoly (SCML) are allowed.
3) Taxes: High breakdown
3. 1 Online (IEJO - Imposto Especial de Jogo Online)
Fortune games/online casinos: 25% of GGR (monthly base).
Bets with fix. odds (sports betting): IEJO is charged on turnover (handle); enforcement uses a scale of 8-16% (progression by volume), with many reviews indicating a baseline 8% monthly for brevity. Check with the current RJO/Budget version of the year.
3. 2 Ground sector
IEJ (land casino special tax): progressive GGR bets (benchmark: ~ 2. 5-35% depending on geography/levels).
Bingo/state games: stamp duty (bingo 25%; state games - 4. 5% to the rate and add. 20% to the prize over €5,000).
Reporting and payment discipline: IEJO/IEJ - monthly settlements and payments; part of IEJO goes to SRIJ income as a regulator (distribution is fixed in RJO).
4) AML/CFT: operators' responsibilities
Basic Act: Law No. 83/2017 on AML/CFT (AML/CFT), applies to "obligated persons," including the gambling sector; functional coordination is carried out by SRIJ and UIF financial intelligence (Polícia Judiciária).
KYC/KYB Policies: Identification prior to admission to play/payout; verification of age, sanctions/RAP, source of funds for triggers; maintenance of KYC dossiers and journals. (Nat. FATF assessments/reviews support a risk-based approach).
Transaction monitoring: limits, anomalies, communication of accounts/means of payment; STR/SAR escalation to UIF.
Storage: retention of CUS/logs according to the terms of the law; CNPD-supervised data protection (GDPR).
5) Responsible Gaming (RG) and advertising
Mandatory: self-exclusion, "cooling," limits on rates/deposits, warnings about risks; marketing - "social. Responsible promotion."
Guide SRIJ 1/2020/SRIJ/JO (online bonuses): if the activation of the bonus requires a minimum bet in real money, the minimum cannot exceed the size of the bonus; transparent T & Cs are mandatory.
Block lists: SRIJ publishes unlicensed domains/payments - communication providers and PSPs are ordered to block. (See SRIJ/market public reports.)
6) IT circuit and regulator access
API/uploads for SRIJ, test accounts, secure channels.
WORM logging with exact "stavka→raschet→vyplata→korrektirovka" tracing, time synchronization.
Certification: platform, RNG/calculation modules; regular recertification.
Reliability/security: DR/BCP with target RPO/RTO, encryption at rest/transit, RBAC/SoD, scheduled pentests.
7) Market facts for reference
Online market showed growth 2024-2025; according to the industry press, GGR Q2-2025 ~ €287 million, IEJO raised ~ €81. 2 million; active ~ 17 operators and ~ 30 licenses (sports/casinos). Use for capacity planning, not as "norms."
8) Checks and sanctions
Office/field: reconciliation of IEJO/IEJ reporting and payments, IT audit, "secret buyers," bonus/advertising control.
Measures: fines, additional charges, UX/RG regulations, blocking domains/payments, suspension/revocation of licenses.
Mitigation: voluntary disclosure of errors, corrective plans, strengthening of internal controls.
9) Entry roadmap
1. Strategy: product matrix (sports/casino/bingo), certification roadmap.
2. SRIJ licensing: RJO package, suitability of key persons, financial stability.
3. Finkontur: IEJO/IEJ models, separate GGR/handle accounting, integration of reporting forms.
4. KYC/AML/RG: risk policy, data providers (sanctions/PEP), STR/SAR scenarios, RG mechanics.
5. IT/security: WORM, DR/BCP, API SRIJ logs, version control; UAT on tax base calculations.
6. Marketing: pre-moderation of creatives, evidence registry (screenshots/URLs/dates), self-exclusion filtering.
7. Go-Live: freeze configurations, runbook incidents, contact window with regulator.
8. First 90 days: rhythm of IEJO declarations, otchetnost↔billing reconciliations, AML/RG internal audit.
10) Compliance checklists
Taxes and reporting
- Product classification and correct base: GGR (casino), handle (sports)
- IEJO/IEJ Monthly Declarations, Payment Calendar
- Bonus accounting/void/cashout by RJO/SRIJ guides
- otchetnost↔billing reconciliation (<0. 5% discrepancy)
AML/KYC & RG
- KYC/KYB Policies, Sanctions/PEP, Source of Funds Triggers
- Self-exclusion, deposit/rate limits, cooling
- STR/SAR logs, CMC/log retention periods
- Guide Bonus Policy 1/2020/SRIJ/JO
Engineering and safety
- Platform/RNG Certification, Version Control
- WORM logging, time synchronization
- DR/BCP tests; encryption, RBAC/SoD, pentests
- API/uploads for SRIJ, test accounts
Marketing & Affiliates
- RG-marking, prohibition of aggressive offers/targeting of vulnerable
- Creative magazine (screenshots/URLs/dates), quick feedback
- Self-excluded filter in all channels
11) KPI for operational control
Fiscal: IEJO/IEJ timeliness ≥99%; discrepancy otchetnost↔billing <0. 5%.
AML/KYC: average verification time; share of false positives; SLA of STR/SAR escalations.
RG: proportion of players with active limits; Self-exclusion TTR <1 min; the proportion of RG complaints.
Infobez: MTTR incidents; percentage of critical vulnerabilities closed on time.
Marketing: proportion of compliant creatives; lack of communication with the self-excluded.
12) FAQ
Casino online: What is the tax base?
GGR, IEJO rate - 25% monthly.
Sports betting online: Base and bet?
IEJO counts as a handle; the scale used as 8-16% by volume is applied, with operational calculation on a monthly basis (check the current version of RJO).
Who follows AML and RG?
SRIJ (gambling sector supervision) + UIF (Polícia Judiciária) under STR/SAR; basic law - No. 83/2017.
Are there any special rules on bonuses?
Yes: the guide 1/2020/SRIJ/JO limits the "minimum real money rate" to the amount of the bonus and requires transparent T & C.
Note
IEJO/IEJ rates and formulas are periodically refined in RJO and annual budgets. Before launching, check the current norms and reporting forms (especially on the scale for sports betting) - this will help to avoid additional charges and prescriptions.