On 5 October 2026, the Spanish Prime Minister, Pedro Sánchez, announced the early dissolution of the Spanish Parliament (Cortes Generales) and called a general election for Sunday, 29 November 2026. The dissolution decree, signed by the King, was published in the Official State Gazette (BOE) on 6 October 2026 and entered into force on the same day.
For licensed operators, the dissolution has a limited impact on the obligations that have already been approved, and, in our view, the direction set by the Directorate General for the Regulation of Gambling (DGOJ) is unlikely to change. Its main effect will instead be on the reform of Law 13/2011, of 27 May, on the regulation of gambling (the Spanish Gambling Act), whose future will now depend on the next Government’s legislative agenda. Below we set out our analysis of each of these issues.
I. No impact on Jdigital’s appeal against the joint deposit limits system
First, the dissolution of Parliament does not affect the appeal that Jdigital (the Spanish online gambling association) has announced it will bring before the Spanish Supreme Court against Royal Decree 520/2026, of 24 June, which introduces a system of joint deposit limits per player across all licensed operators. In the association’s view, the measure is not consistent with the legal framework and is also disproportionate.
As a reminder, the Royal Decree sets default joint limits applicable to all operators of €700 per day, €1,750 per week and €3,300 per four-week period, which will be managed centrally by the DGOJ. It is scheduled to enter into force on 25 March 2027.
However, judicial proceedings run independently of the parliamentary calendar and, in any event, lodging an appeal does not in itself suspend the Royal Decree unless the Supreme Court grants interim measures. Consequently, as Royal Decree 520/2026 has already been published in the BOE, its implementation timetable remains unchanged for the time being, and operators should continue preparing to connect to the DGOJ’s technical system.
II. A change of government is unlikely to alter the DGOJ’s agenda
Operators should also bear in mind that, even if the election were to result in a change in the governing party, the DGOJ’s regulatory agenda is not expected to shift substantially. Gambling has historically been a sensitive matter from a public health and consumer protection perspective and, for this reason, the regulator’s priorities (responsible gambling, protection of vulnerable players, restrictions on advertising and the fight against the illegal market) have been maintained across successive governments.
Although a new government could take a different approach to the reform of the Gambling Act, at Loyra Abogados we believe it is unlikely to reverse the overall direction of gambling regulation. Operators should therefore continue to plan their regulatory compliance on the basis of the current regulatory roadmap.
III. The reform of the Gambling Act: a matter for the next government
The reform of the Gambling Act is, by contrast, the area most affected by the early election. The Ministry of Social Rights, Consumer Affairs and 2030 Agenda, through the DGOJ, opened the prior public consultation on 18 May 2026 and, since then, the DGOJ has held a round of meetings with industry associations and other stakeholders. However, no draft bill has been published to date.
As the reform has not progressed beyond this preliminary stage, it has not reached Parliament and, therefore, it does not lapse upon dissolution, so the work carried out so far, including the consultation responses, remains valid. Nevertheless, the reform cannot move forward in the short term either. On the one hand, it cannot be submitted to Parliament until the new legislature begins and, on the other, once the outgoing Government becomes a caretaker government after the election, Article 21.5(b) of Law 50/1997, of 27 November, on the Government, prevents it from submitting bills to Parliament. Consequently, it will be for the Government that emerges from the election to decide whether, and when, to resume the reform, which in our view is unlikely to reach Parliament until well into 2027.
IV. DGOJ regulatory projects: what may still be approved before 29 November
Unlike the reform, DGOJ resolutions do not require parliamentary approval and are, therefore, not affected by the dissolution as such. Consequently, the DGOJ’s pending regulatory projects may continue to progress over the coming weeks. These include, for example, the resolution setting out the technical specifications of the mandatory messages on the risks of gambling, which was notified to the European Commission under the TRIS procedure.
In this context, operators should not rule out the publication of some of these measures even before the upcoming election is held and, accordingly, we recommend that they closely monitor the BOE, the DGOJ website and the TRIS database over the coming weeks.
V. Next steps
At Loyra Abogados, we will closely monitor the outcome of Jdigital’s appeal, the DGOJ’s regulatory activity, and the progress of the Gambling Act reform. As always, we will keep our clients informed of any relevant developments and remain available should you have any questions or require further information.
Loyra Abogados
Gambling Department
