The “disciplinary moratorium” of the Gambling Act: what’s next for on-line gambling portals pending license approval?

According to Spanish Law 13/2001, regulating gaming (Ley de Regulación del Juego, LRJ), companies that offer online gaming, both from Spain and to Spain, are required to apply for and obtain a double license: a general one, for each game modality and a specific one, for each of the types of the game modality. The Act contains a general regulation of gaming -requirements, prohibitions, obligations, taxes- and refers to subsequent orders regarding the basic regulations for the development of each game modality.
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In the Official Gazette of 17 November, 2011 the ministerial orders were published establishing the basic rules for most of the game types included in the scope of the LRJ: various forms of bets, poker games, bingo, roulette, blackjack and baccarat, state contests and the so-called complementary games.
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The first call for state gaming licenses was held by Order published in the Official Gazette of 18 November, 2011, passing the bidding terms and calling the interested parties to submit the application requests1. The deadline for submitting the applications was 14 December. More than 300 licenses for the different types of games under the call have been requested.