Advertising has traditionally been an important tool for the development of the gambling industry. In Bulgaria, however, the current legal framework imposes significant restrictions on the marketing of gambling activities, particularly on the internet, social media and digital platforms. For businesses, the legal assessment depends not merely on how a communication is labelled but on its actual content, commercial context, distribution channel and the role of the persons involved.
By Atty. Stephany Valcheva · 2026-09-27 · Legal review: 12 October 2026
Gambling advertising in Bulgaria is subject to a restrictive regime under the Bulgarian Gambling Act. Article 10 prohibits gambling advertising in radio and television programmes, subject to a limited exception for draws of the State Enterprise Bulgarian Sports Totalizator, as well as in public places, printed publications and electronic media, including internet pages, and on specified state and municipal property. The Act permits certain forms of outdoor and sports advertising subject to specific conditions.
Since 1 August 2026, Bulgaria has also operated a dedicated licensing regime for affiliate operators. A person promoting gambling in return for performance-linked commission, such as commission based on recruited players, deposits or bets, may fall within this regulated category and require a licence. An affiliate licence does not disapply the advertising restrictions under Article 10 of the Gambling Act.
Article 10(1) of the Gambling Act prohibits gambling advertising in radio and television programmes, except for the broadcasting and announcement of draws of the State Enterprise Bulgarian Sports Totalizator. Advertising is also prohibited in public places, including building façades, unless a specific statutory exception applies.
The prohibition extends to printed publications and electronic media, including internet pages. For particular online content, both the distribution channel and whether the communication falls within the statutory definition of gambling advertising must be assessed.
Under § 1, item 23 of the Supplementary Provisions, gambling advertising includes information that directly invites consumers to participate in gambling, creates an impression that gambling can resolve personal or financial problems or produce financial prosperity, or invites participation by promising large winnings. The definition also covers commercial messages, communications, recommendations or actions using the name of a gambling game or the trademark of a gambling organiser.
The classification therefore does not depend on whether the material is formally described as an advertisement. A publication, video, recommendation, branded item of content or other commercial communication may fall within Article 10 where its substance meets the statutory definition.
The Gambling Act permits advertising through specifically identified physical media. Billboard advertising is permitted only where the billboard is situated at least 300 metres from the educational institutions, universities, community cultural centres, children's playgrounds, student accommodation and facilities providing social services to children and young people specified by law.
Advertising on the façade of licensed gambling premises is permitted only in relation to the organiser's activities at those particular premises. The combined advertising and signage area may not exceed 20% of the façade and may not exceed 50 square metres.
Advertising is also permitted on sports clothing, sports facilities, halls, stadiums, swimming pools and specified materials or products of sports organisations. This exception does not apply to sports clothing, materials or products intended for minors.
In addition, gambling advertising may not occupy more than 5% of the total outdoor advertising area operated by each particular outdoor advertising service provider.
Advertising permitted under Article 10(2) is subject to strict content limits. It may contain the name, type and variant of the gambling games, the organiser's registered trademark and, in the case of permitted sponsorship, its company name, as well as information concerning draws and the winnings in those draws.
Numbers are prohibited in advertising under Article 10(2). This restricts the use of numerical amounts or values in permitted advertising, including where they are used to communicate prize amounts, bonuses, odds or other quantitative incentives.
For billboards, permitted façade advertising and the relevant sports facilities or materials, except sports clothing, at least 10% of the advertising area must display the warning equivalent to: "Gambling carries a risk of developing addiction."
Licensed gambling organisers may sponsor events supporting sport, culture, healthcare, education, social activities and the prevention or treatment of gambling addiction. Sponsorship remains subject to Article 10(1)-(4) and is not a general exemption from the advertising restrictions.
Mandatory regulatory information on the website through which a licensed organiser provides online gambling should be distinguished from promotional content. Article 47v requires specified information in Bulgarian concerning the operator, licence, game rules, acceptance of bets, payment of winnings and other aspects of the regulated service.
The fact that information appears online is not, by itself, sufficient to determine its legal character. The relevant question is whether the particular communication fulfils a regulatory information requirement or constitutes a commercial message, recommendation or action falling within the statutory advertising definition.
Communications that invite participation, promise financial outcomes, emphasise winnings or use a gambling brand in a commercial context to promote a game or organiser require particular scrutiny. The law focuses on the substance and function of the communication rather than solely on its formal description.
Since 1 August 2026, affiliate operators have been subject to a specific licensing regime in Bulgaria. An "affiliate operator for the promotion of gambling games" is a natural or legal person other than the gambling organiser that promotes gambling under an agreement in return for performance-linked commission, including commission based on recruited participants, deposits, bets or paid winnings.
A person providing advertising, media or technical services is not an affiliate operator merely because of the nature of those services where its remuneration is not linked to the specified results. This distinction is particularly relevant for advertising agencies, media companies, influencers, website owners and other marketing partners.
An affiliate operator must hold a licence under the Gambling Act and may promote gambling only for organisers holding a valid licence. The licensing application identifies the websites, mobile applications, social-media profiles and video or streaming platforms through which the person conducts the activity. Affiliate activity remains expressly subject to the advertising restrictions under Article 10.
Persons that already had an affiliate arrangement with a licensed organiser on 1 August 2026 were required to submit a licence application by 15 August 2026. Where the application was submitted within that transitional period, the existing arrangement remains effective until the licence is issued.
Holding an affiliate licence does not authorise content that is otherwise prohibited under Article 10. The licence regulates the right to conduct affiliate activity, while the individual promotional method must independently comply with the advertising restrictions.
An influencer is not automatically an affiliate operator. Where remuneration is linked to recruited customers, deposits, bets or other results and the remaining statutory elements are satisfied, the activity may fall within the affiliate licensing regime. Where remuneration is fixed and not performance-linked, the person may fall outside the affiliate definition, but the content remains subject to Article 10.
The same distinction applies to media companies, advertising agencies, publishers and technical service providers. The regulatory status of the person and the legality of the particular communication are separate questions. A person may fall outside the affiliate regime but still incur liability for publishing, broadcasting or distributing prohibited advertising.
When entering into agreements concerning permitted information or sponsorship, persons covered by Article 10(7) must check the public NRA register to verify that the relevant organiser holds a valid licence.
Liability is not limited to the gambling organiser. Article 105 provides sanctions both for an organiser advertising in breach of Article 10 and for persons publishing, broadcasting or distributing prohibited advertising. Since 1 August 2026, a separate sanction also applies to affiliate operators promoting gambling in breach of Article 10.
The applicable liability therefore depends on the person's role in commissioning, creating, publishing or distributing the communication. Legal entities and sole traders are subject to the applicable administrative pecuniary sanction regime.
Under Article 105(1), a gambling organiser advertising in breach of Article 10 is subject to a pecuniary sanction of BGN 30,000 to BGN 50,000. Following the introduction of the euro, these statutory lev amounts continue to apply through the automatic conversion rules and correspond to EUR 15,338.76 to EUR 25,564.59 at the official conversion rate.
A person publishing, broadcasting or distributing advertising in breach of Article 10 may be subject to a pecuniary sanction of BGN 10,000 to BGN 30,000 if a legal entity or sole trader, corresponding to EUR 5,112.92 to EUR 15,338.76 after conversion. A natural person may be fined BGN 5,000 to BGN 10,000, corresponding to EUR 2,556.46 to EUR 5,112.92.
Under Article 105(3), an affiliate operator promoting gambling in breach of Article 10 may be fined EUR 2,000 to EUR 5,000 if a natural person or be subject to a pecuniary sanction of EUR 3,000 to EUR 8,000 if a legal entity.
The 2026 regime also provides separate sanctions for using an unlicensed affiliate operator and for promoting gambling on behalf of an organiser without a valid licence. Use of an unlicensed affiliate may result in a pecuniary sanction of EUR 5,000 to EUR 20,000. Promotion for an unlicensed organiser may result in a fine of EUR 3,000 to EUR 10,000 or a pecuniary sanction of EUR 5,000 to EUR 20,000. These sanctions are doubled in the case of a repeated infringement.
Where a gambling organiser commissions or carries out advertising outside the forms permitted under Article 10(2), the Executive Director of the National Revenue Agency may impose a compulsory administrative measure temporarily withdrawing the licence for a period of three to six months. Since 1 August 2026, a corresponding measure may also apply where an affiliate operator promotes gambling in breach of Article 10(9).
Before a withdrawal decision is issued on the applicable grounds, the NRA notifies the organiser or affiliate operator and provides one month to discontinue the infringement and remedy its consequences. If the required evidence is submitted within that period, the NRA verifies it within 14 days and, where the infringement and its consequences have been properly remedied, the compulsory administrative measure is not imposed.
This procedure concerns the compulsory administrative measure. It does not automatically extinguish administrative liability for an infringement already committed.
Before publishing a communication connected with a gambling operator or game, businesses should determine its legal character, the distribution channel and the role of each participating party. Particular attention should be given to distinguishing ordinary advertising, media and technical service providers from affiliate operators receiving performance-linked remuneration.
For permitted outdoor advertising, compliance should address the 300-metre distance requirement, the 5% provider quota, the content limitations, the prohibition on numbers and the minimum area required for the gambling-addiction warning.
Agreements with media companies, advertising agencies, influencers and other partners should clearly regulate permitted content, remuneration and pre-publication controls. Where remuneration is linked to recruited participants, deposits, bets or other results, a separate assessment should be made as to whether the partner falls within the affiliate licensing regime.
Vassilev & Chisuse Law Firm provides legal assistance in gambling regulation, advertising and marketing campaigns, sponsorship arrangements and regulatory compliance. Assistance may include pre-publication legal review of campaigns and agreements, assessment of the affiliate operator regime, preparation of internal compliance rules and representation before the National Revenue Agency and the administrative courts.
This material is provided for general informational purposes only. It does not constitute individual legal advice. As of that date, additional bills amending the Bulgarian Gambling Act have been introduced in Parliament but remain within the legislative process and do not form part of the law currently in force.