Although the licensing system of online sports betting has been in force from 1 January 2023 (with payment bocking rules in force from 1 July 2023), the envisaged enforcement activity of the Supervisory Authority for Regulatory Affairs (SARA) had not taken place until the beginning of August 2023.
Now, several international igaming operators have received notifications from the SARA regarding their alleged unlicensed provision of online gambling (incl. online casino games and sports betting). As we have already noted in our previous articles, there are significant EU and Hungarian law concerns connected to the new Hungarian online gambling regime’s compliance, which issues have a significant impact on the enforceability of any potential sanctioning decision issued the SARA.
As for now, no SARA decisions have been taken against international operators, however this is expected to happen in the near future. It is expected that the SARA will issue a series of fines (up to EUR 250k) IP blockings, criminal reports for the police for illegal gambling against gambling operators and possibly against banks (domestic and foreign as well) that fail to comply with the very strict payment blocking expectations. Operators might, and most probably will, challenge such sanctions before Hungarian courts based on EU law arguments which will likely lead to yet another surge of mass litigations over the EU law compatibility of the Hungarian licensing and payment blocking system.
Authors

Dániel Élő
Dispute Resolution
Dániel Élő
How can we help? Get in touch.
Follow us on LinkedIn
Related articles

The Hungarian gambling authority relaunched enforcement against international iGaming operators
Although the licensing system of online sports betting has been in force from 1 January 2023 (with payment bocking rules in force from 1 July 2023), the envisaged enforcement activity of the Supervisory Authority for Regulatory Affairs (SARA) had not taken place until the beginning of August 2023.

iGaming related payment account blocking in Hungary from 1 July 2023? – A perspective of payment service providers
According to the new payment blocking rules, in case the Supervisory Authority of Regulatory Affairs (SARA) have established that an operator provided “prohibited gambling” (i.e. not licensed by the SARA) towards Hungarian players, it shall also issue a decision ordering the restriction of the payment account used for the payment of bets or winnings by the given gambling operator.

January Update: Forms are available for companies to apply for Hungarian online sports betting licenses
The Hungarian gambling authority’s (SARA) Implementation Decree have been published on 19 December 2022 with the already known amendments to the Gambling Act, and with the start of the new year the forms through which EEA companies may submit their applications for online sports betting licenses have appeared on the SARA’s website.