Romania’s gambling regulator has moved from asking platforms for help to using legal powers against the channels that feed the black market. By the end of July 2026 the ONJN had blacklisted about 2,680 domains since 2013, it can order the removal of illegal gambling content and ads, and since 2025 payment, software and platform providers licensed under Class 2 must block and report Romanian players’ access to unlicensed sites. The ONJN estimates that more than 70% of Europe’s online gambling market is unlicensed. That supply competes for the same ad inventory, payment rails and affiliate traffic as licensed operators.
The numbers ONJN put on the table
In its summer 2026 statements the ONJN set out its enforcement record:
- About 1,500 domains blacklisted from the regulator’s creation in 2013 to April 2025.
- About 1,180 added since April 2025, under the leadership that took office then, including roughly 800 in one Supervisory Committee meeting announced on 31 July 2026. Polymarket was among them; see our post on the Polymarket blacklisting.
- A new tool to detect clone sites that reuse the same structure under different domains, which explains the size of the July batch.
- 98% compliance with its content-removal orders, reported in August 2026 in its follow-up to the Court of Accounts audit.
The list kept growing after the summer. It held 2,881 domains as of 25 September 2026. Some well-known illegal brands, such as NV Casino, Verde Casino and Vulkan Casino, remained reachable in Romania in late 2025 even after criminal complaints, according to the ONJN’s then-president.
The removal-order lever, and why it is not enough
Romanian law now allows the ONJN to issue orders to remove illegal gambling content, a power few Romanian authorities have. Domain blocking runs through internet service providers under technical protocols, with ANCOM supporting enforcement.
A 98% compliance rate measures how well platforms respond to the orders ONJN sends. It does not measure the size of the illegal market. Operators rotate domains, launch mirrors and rely on VPN use, and each new domain must go through the legal listing procedure again. The ONJN itself says no definitive international technical solution exists yet. Blocking is a continuous task, not a project with an end date.
Blacklist compliance versus whitelist compliance
There are two ways a platform can approach gambling ads in Romania.
- Blacklist-based. Remove ads for operators the regulator has named. This is reactive and always one domain behind.
- Whitelist-based. Serve gambling ads only for operators holding an ONJN license and authorization. Under OUG 77/2009, only licensed operators may offer or advertise gambling in Romania, so this is the standard the law implies.
The second approach shifts the work to before the ad runs: verify the advertiser against the ONJN Class I register, then serve. That is the question regulators are now putting to the platforms: if the standard is “licensed only”, why do unlicensed operators still buy ads?
The CJEU removed the platforms’ favorite shield
On 16 July 2026 the EU Court of Justice ruled in case C-421/24, referred by Italy’s Council of State in Google’s challenge to a €750,000 fine imposed by AGCOM in 2022 over YouTube videos promoting gambling. The Court held that Google could not rely on the hosting exemption where it had reviewed a creator’s channel and content before entering a commercial partnership. At that point Google was not acting as a purely technical intermediary.
The case returns to the Council of State. Its reasoning reaches well beyond YouTube. Revenue-share deals, partner programs, managed ad accounts and affiliate arrangements all involve a commercial review before the partnership starts. A platform that checks a partner and then shares in its revenue will find it harder to argue that it did not know what the partner was promoting.
The platform-side numbers
Platforms say they remove most violating ads. Internal Meta documents reported by Reuters in November 2025 suggested a different picture for scam advertising generally: a December 2024 estimate of about 15 billion “higher-risk” scam ads shown to users every day, a projection that about 10% of annual revenue (roughly $16 billion) came from scam ads and banned goods, and a policy of acting only when systems were 95% certain an advertiser was a fraudster. Meta disputes the characterization.
Those figures are not gambling-specific. They explain why regulators no longer accept removal statistics as proof that a platform is not profiting from illegal supply.
The payments squeeze
Since 2025, Class 2 payment processors, software providers and platform or hosting providers must:
- determine the player’s real location in their own systems, independently of the gambling site;
- block Romanian players’ access to platforms on the ONJN blacklist;
- report to the ONJN monthly, including nil reports, and provide detailed data on request.
Failure to report can lead to suspension or revocation of the Class 2 license. Cooperation with unlicensed operators is a criminal offense for the provider and its management. The ONJN has also warned about transaction masking and miscoded merchant category codes, and has appealed to card schemes, acquirers and EMIs to cooperate. For providers, MCC accuracy is now a regulatory matter, not only a scheme-rules matter. Our payments advisory covers this setup.
The legislative rewrite on the table
In summer 2026 the ONJN said the framework would be reopened. The items it raised publicly included easier license revocation, minimum standards for game rules, rules on test accounts (linked to GGR manipulation risk), live-streaming rules, stricter rules on advertising content and a legal definition of white label. In September 2026 the press reported discussion of a new gambling law that would treat retail and online more uniformly. No draft has been published, and the change of ONJN leadership in August makes timing uncertain.
The tech build
The ONJN has launched procurement for four systems: device traceability for slot machines and VLTs, a new self-exclusion platform, monitoring of online and land-based operators with automatic black-market detection, and digitalization of internal workflows including licensing. With the Authority for the Digitalization of Romania it is building a metadata-analysis system to flag suspicious transactions and GGR manipulation using data from operators’ mirror servers. The public register of gambling devices, with a QR code for each authorized machine, has been online since 21 October 2025.
Romania is not alone
Italy’s AGCOM brought the Google case. The UK Gambling Commission describes an upstream strategy aimed at hosts, payment providers, software suppliers and search engines rather than only at operators. Regulators are converging on the same idea: the black market depends on intermediaries, so the obligations land on the intermediaries.
Operational impact
If you are a licensed B2C operator in Romania
Stronger enforcement against the black market should help acquisition costs, but only if it holds. Your affiliates are a liability surface: one promoting both you and unlicensed brands puts you in the same file. Reconcile transaction data now, because the metadata system targets GGR manipulation. The Class 1 guide sets out the authorization conditions that revocation would test.
If you are a B2B supplier or platform
The white-label definition is the item to watch. Game producers and platform providers are named in the ONJN’s appeals, and serving blacklisted sites that accept Romanian players is already prohibited. Contract clauses, geolocation and due diligence on every operator client are now part of holding a Romanian Class 2 license.
If you are an affiliate or influencer
Affiliates fall under Class 2 and carry the same ban on serving unlicensed sites; see Class 2 for affiliates. Commercial partnerships with creators match the facts of the CJEU ruling.
If you are in payments
Blocking and reporting obligations are already law. Treat MCC accuracy and merchant onboarding for gambling as compliance controls with criminal exposure behind them.
The second-order effect
Enforcement alone relocates supply. If taxes, product rules and marketing limits make the licensed offer much less attractive than the illegal one, players and some operators drift to the gray and black markets. The ONJN’s then-president acknowledged that risk and called for a market that is fair for both organizers and players. The regulator’s own governance is also under scrutiny, with two DNA files involving ONJN officials; see the ONJN corruption probe.
What applies now (October 2026)
On 21 August 2026 the interim government replaced ONJN president Vlad-Cristian Soare with Valentin-Ioan Tomescu. The legal tools described here do not depend on who leads the regulator: the blacklist, removal orders and Class 2 blocking and reporting duties remain in force under OUG 77/2009 as amended. The blacklist reached 2,881 domains on 25 September 2026. The announced rewrite of the gambling law has not yet produced a public draft.
The bottom line
The dialogue phase is over. Platforms, payment providers, software producers, affiliates and influencers now carry legal obligations to stop facilitating unlicensed gambling in Romania, and the CJEU has made it harder for ad platforms to claim they are mere conduits. Licensed operators and suppliers should audit their partners and data now, before the automated monitoring systems go live.