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.