1. We recall that Spain is one of the safest and most secure gambling markets in Europe, with one of the strictest regulations, even before the approval and entry into force of the regulation approved today.

2. We consider that this Royal Decree responds to a tendency of the national regulator to the standarization of the already hyper-regulated activities, where the measures and good practices of the operators have contributed to have really safe environments and frameworks. 

3. This regulation comes at a time when levels of gambling problem are falling, as shown by the prevalence figures of gambling problem in the country and reflected in the reports of the National Plan on Drugs, confirming that gambling activity by players is totally moderate, controlled and responsible.

4. Jdigital defends the regulation of the sector as long as it is proportionate and aims to generate safer environments for online gambling in Spain. However, this regulation must serve its technical purpose and cannot be an obstacle to launch political messages, confusing and alarmist for society, about a perfectly safe sector, according to Government data and in comparison with the countries around us, and already battered after the entry into force of the Royal Decree on Commercial Communications.

5. Throughout the processing of the Royal Decree, and after a first version of the text that we consider absolutely disproportionate, Jdigital has developed an important contribution with the aim of improving, on the one hand, the rule and, on the other hand, make it more effective in achieving the objectives it pursues. 

6. Some of these allegations have been taken into account and included in the final draft of the regulation (vacatio legis and implementation times of the regulation); while others, important for the development of the gaming activity, have not been finally reflected in the text, such as the age limitations and the establishment of economic limits in general without taking into account the economic characteristics of each player.

7. The technical complexity of this regulation requires time to make changes in technological developments for its proper implementation with guarantees and efficiency. In this sense, we are reassured to know that the regulator will apply a vacatio legis to adapt a vast amount of programming in webs and apps that entail a very high cost for operators in terms of resources and equipment.

8. Despite the will expressed in the explanatory memorandum, the regulation contains vague aspects and other legal considerations that will have to be carefully evaluated. Jdigital remains firm in its responsibility as defender of the rights and interests of the online gaming sector in Spain. In this sense, in the coming weeks we will carefully study the impact of the approved measures and we will study all possible ways to continue improving and interpreting the regulation.

9. In the coming months there are new opportunities for the online gaming sector and the regulator to join forces to improve the security of the sector: 

1. working on a system to limit joint deposits between operators; 

2. Define the main risk markers associated with gambling activity (in the framework of the presentation to the European Commission of a standardized model of markers between European countries).

3. To address the problem of fraud in the sector, which is reflected in the current figures of economic transactions. 

10. Now that the legislature is running out and that regulations have already been implemented to limit the activity of operators, the industry demands that the regulator work on the opportunities that do exist to improve the gaming market and investment in Spain. 

Therefore, Jdigital will continue to reach out to the regulator to address as effectively as possible the creation of safe environments for online gaming in Spain, as it has done so far.