New Gambling Rules in Bulgaria - What Will Change in Practice? An Interview with Aleksandar Popov, Former Head of Gambling Supervision at the National Revenue Agency

27 October 2026, 10:35 Bulgaria

The proposed amendments to Bulgaria’s Gambling Act would introduce new financial and regulatory requirements for the licensed sector. For businesses, the key question is what the combined burden of these requirements will be and to what extent it will be matched by more effective enforcement against illegal gambling. How should the results of advertising restrictions, website blocking and player protection measures be measured?

Game Spectrum discusses these issues with Aleksandar Popov, former Director of the Gambling and Gambling Activities Supervision Directorate at Bulgaria’s National Revenue Agency (NRA). In this interview, he comments on the fiscal approach underpinning the proposals, the risk of players moving to unlicensed services and the need for technically feasible rules. The discussion also explores how international experience, oversight of financial flows and better use of data can help curb the illegal market without creating unjustified obstacles for compliant operators.

Based on your experience in gambling supervision, which problem should the amendments under discussion address as a priority, and how well do the proposed measures address it?

The impression given is that the main priority is to reduce gambling-related harm and curb the unlicensed market. In my view, however, the proposals are predominantly fiscal in their approach, while some of the measures create conditions that could lead to market concentration. Player protection and efforts to curb illegal gambling must be considered together. If we restrict access to a licensed service but leave illegal services easily accessible, there is no basis for assuming that we have protected the player.

I would approach the measures under discussion with a specific question: what problem does each one solve, and what data supports it? A higher fee, an additional local presence requirement or a new advertising ban does not automatically mean more effective oversight. An assessment of the overall impact and realistic implementation timelines are needed.

In previous comments, I have pointed out that fiscal considerations play a significant role in the reforms. The state may have revenue objectives, but these should be stated separately. Collecting more money is not, in itself, evidence that people are better protected.

Some of the proposals build on the existing advertising restrictions. How do you assess what those restrictions have achieved, and what lessons should inform the next changes?

My opinion remains that the 2024 amendments were adopted too quickly and left questions about their interpretation and implementation. Reducing the presence of advertising in certain channels is one thing; demonstrating that risky gambling has decreased is another.

I would not declare either success or failure solely on the basis that we are seeing fewer television advertisements. We need to track which messages consumers encounter, through which channels and from which operators. In a digital environment, banning a particular format does not necessarily eliminate the influence of advertising. Nor should an online presence be assumed to be lawful simply because it exists.

For the next changes, I would insist, first and foremost, on measures that can be implemented effectively. A rule that the state cannot enforce creates strictness on paper but does not guarantee protection. My personal view is that the state should focus more on the content of advertising messages, the audiences they reach and oversight of their distribution, rather than relying mainly on blanket bans. In an open digital environment, advertising influence can shift to other channels, including those that are more difficult to oversee. If a compliant operator becomes harder to identify while an illegal one remains visible, we need to assess whether we have achieved our objective.

Looking at international experience, which country has succeeded in both improving player protection and curbing the unlicensed market? What specifically has worked?

I would look at Denmark and the Netherlands, but for different lessons. Denmark provides a useful example of combining a regulated market with self-exclusion and access to support. The Dutch experience also demonstrates the difficulty of achieving stronger protection while keeping gambling activity within the licensed sector. For that reason, I would not simply transplant either model.

In Denmark, the ROFUS system enables voluntary self-exclusion, while StopSpillet provides counselling and support. The regulator publishes market data and information about these tools. This provides a basis for discussing outcomes, rather than merely the number of measures taken.

For me, the lesson is that a licensed service must be subject to oversight, identifiable and accessible in practice to adults who are legally entitled to use it. At the same time, illegal gambling must be made more difficult to offer, and help must be available to people experiencing problems. I would not attribute the overall outcome to a single ban or register: a high share of gambling activity within the licensed market and lower levels of gambling-related harm are different indicators and must be assessed separately.

What can we apply from this experience in Bulgaria, and what should change in the powers, resources or cooperation between institutions?

I would start with better use of data and technology. I have previously suggested direct electronic reporting from land-based gaming machines to the NRA as a possible way forward. The objective should be to provide reliable information for supervision, rather than to build an expensive system whose data nobody analyses.

The regulator needs expertise in payments and technology, staff capable of analyzing risk and the ability to respond to rapidly changing websites, applications and payment methods. Timely and verifiable access to information is important for oversight; any additional requirement concerning the physical location of infrastructure must be justified separately.

Cooperation between the NRA, investigative authorities, payment service providers and technology platforms must be governed by clear procedures, a legal basis and response deadlines. I have also previously emphasized the need for international cooperation on shared challenges: illegal gambling, money laundering and advertising through global platforms. This is more useful than simply copying other countries’ tax rates or restrictions.

In this context, where would the Bulgarian regulator’s efforts have the greatest impact: blocking websites, restricting advertising or stopping payments to unlicensed operators?

I would not treat these as competing approaches. Blocking access, restricting illegal advertising and cutting off the provision of services to unlicensed operators must work together. A domain can be replaced; if the organization can still easily attract customers and receive payments, the effect of blocking is limited.

If I had to identify where additional resources should be directed, I would focus on financial flows and the intermediaries that enable operators to reach consumers. This requires work targeting specific operators and schemes, rather than making payments more difficult across the entire sector.

The grounds for imposing restrictions must be verifiable, with scope for errors to be corrected promptly and decisions to be challenged. If a measure obstructs lawful payments while illegal channels bypass it, it may prove counterproductive. Its impact must therefore be assessed after implementation, rather than assumed in advance.

How will we know whether these measures are actually shrinking the unlicensed market? What should we measure beyond the number of blocked websites?

The number of blocked websites is an indicator of work carried out. By itself, it does not show how many players or how much money have left the illegal market. The same operator may use many addresses.

We need to assess the share of activity taking place with licensed operators and changes in the unlicensed segment. The methodology must distinguish between player numbers, wagers and gross gambling revenue, rather than mixing measures that are not comparable. Estimates of the illegal market inevitably involve uncertainty, and that uncertainty must be explained.

I would combine representative surveys with aggregated payment and web traffic data, reports of suspected violations and inspection findings. Visiting a website is not the same as placing a bet, just as growth in the licensed market does not automatically prove a decline in the illegal market. It is also useful to measure how quickly the regulator identifies a violation, disrupts a specific scheme and responds when it reappears.

Behind these indicators is the behavior of players themselves. How can we track whether someone whose access has been restricted by a licensed operator stops gambling or turns to unlicensed websites - and what does this mean for responsible gambling measures?

We cannot reliably track every individual after their access has been restricted. The licensed operator knows that it has blocked access, but usually has no reliable information about whether that person has stopped gambling, moved to another channel or sought help. This limitation must be acknowledged.

One possible approach is to use voluntary follow-up surveys, work with support organizations and analyze aggregated findings, with a clear legal basis and safeguards for personal data. I do not support introducing unrestricted monitoring of financial and personal behavior under the pretext of responsible gambling.

For these measures, this means that self-exclusion must be linked to accessible help, prevention and follow-up support. Responsible gambling funding should support programmes with verifiable outcomes. If, after being denied access, a person is left to seek an alternative on their own, we have fulfilled an administrative requirement, but we still do not know whether we have reduced the harm. The possibility of people moving to illegal websites is a reason to improve protection, not to abandon it.

Bringing these two objectives together - more effective oversight and better player protection - which three outcomes, one year after the changes take effect, would convince you that the reform is working?

First, convincing evidence of reduced participation in unlicensed gambling, obtained using a methodology announced in advance and applied consistently. Not simply more blocked addresses, but an actual reduction in the accessibility and use of illegal gambling services.

Second, effective protection for at-risk players: verifiable enforcement of restrictions, earlier referral to support and better access to counselling. We can assess these practical outcomes within a year, but reaching a robust conclusion about gambling addiction will require a longer period of observation.

Third, more effective supervision alongside predictable conditions for the licensed market. This means faster responses to violations and reports, and clear requirements that are technically feasible to meet and do not create unjustified obstacles for compliant operators. If revenue collection increases, but the illegal market also grows and protection does not improve, I would not call that a successful reform.