Demo play, no-deposit offers and free tournaments in Portugal

Authority

Serviço de Regulação e Inspeção de Jogos (SRIJ)

Official register

srij.turismodeportugal.pt/pt/jogos-e-apostas-online/entidades-licenciadas

Minimum age

18

Self-exclusion and help

Self-exclusion at the SRIJ, three months at least; Linha 1414, run by ICAD

Four blanks above, and one article that is not blank at all

Portugal produces the emptiest set of boxes in this record and one of the sharpest provisions in it, which is a combination worth explaining rather than apologising for. The regime says nothing about trial play, nothing about a check on age before a "free play" session opens, nothing about a "no deposit" offer and nothing about a "freeroll" (four questions, four blanks, and no inference offered in place of an answer).

What it does say, in a single article, is that promoting online gambling without a licence can be punished with up to five years. The subject of that sentence is not an operator but whoever does the promoting, which puts a page of this kind squarely inside the provision rather than outside it looking in.

The Portuguese shape is the inverse of the German one. Germany regulates the free game in detail and says comparatively little about the person describing it, while Portugal leaves the free game untouched and reserves its severity for the description (one regime addresses the product, the other addresses the publisher).

We would rather set that contrast out at the top than bury it, because a reader who skims the four empty boxes and concludes that Portugal is a relaxed market will have drawn exactly the wrong lesson from them!

The definition, which answers the demo question only by omission

The governing instrument is the decree-law of 2015 that created the Portuguese online regime, and its definition of an online game of fortune or chance has two limbs that both have to be satisfied (a definition in two parts, with nothing in it about a version played for nothing). The game has to involve a "monetary amount", and its outcome has to depend exclusively or mainly on luck (two limbs, and the first of them is the one that matters to a trial version).

A game played without money therefore appears to fall outside the definition, which is the same structural answer that Denmark gives and that Belgium gives for its gambling act. The reasoning is available to anybody and it is not difficult to follow (no money, therefore no monetary amount, and therefore no game of fortune within the meaning of the decree).

We are nevertheless leaving the first box empty, and the reason is a point of method rather than one of caution (method, and not timidity about a conclusion). The regime does not address a "fun mode" at all, so what we have is the absence of a provision plus an inference from a definition, and we record the absence rather than publishing the inference as a finding (the distinction is the whole value of this record).

A reader who wants the inference may have it, with the label attached. A "demo" or a "practice play" mode with no money in it looks, on the face of the definition, like something the Portuguese regime does not reach; what we cannot tell you is whether the regulator agrees, because nothing we read states a position either way.

Article 49, and the two words that make it unusual

The penalty is the headline, and up to five years is severe by the standards of this collection, where most of the exposure is administrative and is measured in fines (five years here, against a fine of a hundred thousand euro across the border in France). What makes the article unusual is not the length of the sentence available but the breadth of the conduct it describes: promotion "by any means", which is a formula wide enough to take in a page, a post, a video and a link.

Two further words widen it again, and they are the ones to notice. Honest ignorance is not a defence. Negligence is punishable, and so is the attempt, which means that a person can commit this offence without intending to promote anything unlawful and can commit it without the promotion having worked (negligence and attempt, both expressly covered).

Most prohibitions in our record require a licensee to do something or to refrain from doing it, which leaves the person reading about them as a bystander (the German treaty and the Swedish act are both drafted that way). This one requires nothing of a licensee at all; it describes a result, attaches a criminal consequence to bringing that result about, and then declares that carelessness will do in place of intent!

In our reading that makes Portugal the jurisdiction where the gap between "we did not know" and "we are not liable" is narrowest. The practical consequence for anybody publishing a list of operators is that the licence status of each one has to be checked before publication and not after a complaint.

The advertising rules, which are the verified part of this page

Where the regime becomes concrete is on the manner of advertising, and these requirements come from a trade source and not from the decree itself. Advertising may not target or depict minors, and it is restricted within two hundred and fifty metres of a school or of a facility for young people (a distance rule, measured on the ground rather than on a map), which is a constraint no "banner" network was ever designed to respect.

Gambling may not be presented as a source of income, of success or of prestige, and it may not be associated with advertising for credit (the second of those two is the rarer prohibition, and the more interesting of the pair). Those two together rule out most of the register that this trade falls into when nobody at all is supervising it.

Every communication has to carry a responsible-gambling message and a link to the national register of "self-exclusion", which gives these rules a standing apparatus comparable to the Danish one and rather more severe than the Swedish. Sponsorship and "influencer" marketing are permitted here, but both of them are subject to standards of transparency that the regulator sets rather than the market.

The self-exclusion mechanism deserves a line of its own. Its design differs from the schemes run by Portugal's neighbours, and the difference is a number. A person who registers with the regulator is excluded for a minimum of three months (three months, and not a day or a week), which makes the instrument a decision rather than a gesture, and puts it closer to the Nordic registers than to a cooling-off button sitting inside an operator's own account page.

Affiliates, and the exact shape of the part left open

An affiliate needs no separate licence in Portugal, and that is the beginning of the analysis rather than the end of it (no licence, which is the same position an affiliate occupies in Denmark and in Italy). The licensed operator remains responsible for the promotional content its affiliates publish; that single rule imports the whole advertising code into an affiliate's own pages by way of a contract.

For an unlicensed offer the position is the criminal one described above: promotion through an "affiliate link" is prohibited and criminally relevant under this regime. An intermediary who knowingly facilitates such a "placement" can be liable in its own right. The word knowingly is doing real work in that sentence, and so is the negligence standard sitting beside it (two standards inside one article, which is an unusual pairing).

Every one of the four answers above is marked "not verified", and the causes divide into two kinds. On trial play, on age checks and on "freeroll" tournaments the regime is silent, so there is nothing to verify; on offers, we found no Portuguese source stating whether a "bonus" or a "free chip" without a deposit is permitted, restricted or simply ignored.

If you need the one address that settles the only question this page can answer with confidence, it is the regulator's published list of licensed entities, which is the document that decides whether a given operator may be written about at all. Your own check in Portugal starts there, and it starts before anything is published rather than after a complaint has arrived (before, which is the only moment at which it helps).

By the Free Best Casino editorial team · Last updated October 2026