Romanian Class II suppliers may not provide any gambling-related service, directly or indirectly, to an operator that accepts Romanian players without an ONJN Class I license. The rule comes from OUG 82/2023, approved and extended by Law 107/2024 (in force 28 April 2024), and a breach costs RON 150,000–200,000, the revenue from the deal and the Class II license itself. Law 141/2025 has since added geolocation and monthly reporting duties.
We first covered the ban in May 2025. This update keeps what the law said then and adds the rules that apply in October 2026.
What the law says
Parliament adopted Law 107/2024 in April 2024. It approved OUG 82/2023, the 2023 overhaul of OUG 77/2009, and it was published in Monitorul Oficial no. 370 on 18 April 2024. Among other changes, it made it a contravention to provide gambling-related services to entities that lack a Romanian Class I license and allow players in Romania to access their platforms.
The prohibition reaches the whole B2B chain: game studios, platform and turnkey providers, aggregators, hosting providers, payment processors and affiliates. It covers Romanian residents and also Romanian citizens who are not tax resident in another state. A supplier cannot avoid it by routing the service through a group company or a reseller, because the law catches indirect provision too.
Penalties for non-compliance
A breach is fined RON 150,000 to 200,000 (roughly €30,000–40,000) per contravention. ONJN must also confiscate the revenue obtained from the prohibited service, and the Class II license is revoked.
Revocation is the sanction that matters most. A supplier without a Class II license cannot contract with any Romanian Class I operator, so one unlicensed client can cost access to the whole regulated market. The Class II fee itself is modest (see the Class 2 license guide for the full cost schedule), but the commercial value of the license is far higher.
Obligations before ONJN issued its order
Law 107/2024 required ONJN to set out the technical measures suppliers must apply. In May 2025 ONJN had published a draft order that would have required Class II licensees to notify ONJN of every contract with an entity that holds no Romanian Class I license, and to obtain a written commitment from that client to block Romanian players. Until the order was final, suppliers were expected to apply the technical measures available to them.
The measures we recommended then still form the core of a defensible setup:
- IP and geolocation blocking of Romanian traffic reaching non-Romanian brands.
- Payment screening (BIN and IBAN) for Romanian cards and accounts.
- KYC flags for Romanian nationals who claim foreign tax residence.
- A compliance log showing each control, its date and its result.
Why the clampdown happened
Lawmakers wanted to protect the tax base and players. A Court of Accounts audit published in February 2025 estimated potential authorization-fee shortfalls of more than RON 3 billion across 2019–2023 and found that ONJN had not cross-checked online operators’ declarations. Extending responsibility to suppliers gave the regulator leverage over offshore brands it cannot reach directly. We cover the wider reform in Romania overhauls gambling regulation.
Strategic steps for Class II suppliers
- Check every client against the ONJN Class I register and the ONJN blacklist before go-live and at least monthly.
- Add termination rights triggered by loss of a Class I license, blacklisting or proven Romanian access.
- Run your own geolocation and do not rely solely on the operator’s data.
- Keep a dated compliance log in a format you can hand to ONJN on request.
- Bring in Romanian counsel early; the rules have changed twice since 2024.
Wider market implications
The ban turns Class II holders into gatekeepers. For many studios and platforms, the Romanian Class II license was attractive because of its fixed cost and the access it gives to an EU-regulated market. That trade now comes with a duty to police the rest of the client book. Suppliers with a large share of business from unlicensed or “grey” markets have to choose between those clients and Romania, or prove that those clients block Romanian players. In our experience, most suppliers choose the second route: they restructure client contracts and traffic controls rather than give up the license.
What applies now (2026)
The 2024 ban is still in force, with heavier operational duties since Law 141/2025 (Monitorul Oficial no. 699 of 25 July 2025):
- Blacklisted domains. Class II licensees may not provide any service to a domain on the ONJN blacklist that fails to restrict Romanian access. The list held 2,881 domains on 25 September 2026.
- Independent geolocation. Holders of Class II licenses for gambling software, platform management or hosting, and payment processing must deploy technical solutions that determine a player’s real location, independent of the operator’s own data.
- Blocking requests. Where an unlicensed operator lets a Romanian player in, the supplier must ask the operator to block access immediately.
- Monthly report. By the 10th of the following month, the supplier reports to ONJN the players blocked and the domains, platforms or apps used. Practitioners advise filing a nil report when nothing happened.
- Reports on demand. An up-to-date access report must be ready for ONJN at any time. Commentators describe a failure to produce it as serious non-compliance that can lead to suspension or revocation.
Enforcement is real. ONJN’s report for April 2025 to April 2026 counted about 11,000 control actions, roughly RON 10 million in fines, 70 criminal complaints and 60 license revocations. One point remains unsettled: some Romanian practitioners read the 2025 amendments as exposing suppliers to criminal liability for serving unlicensed operators, while other commentary treats the breach as administrative only. Until the courts settle it, assume the higher exposure.
For who must file, what each report contains and how to build the process, see Class II reporting obligations under Law 141/2025. For the compliance calendar that keeps a Class II license in good standing, see the deadlines and taxes that keep your license alive. Our compliance team can set up the geolocation evidence, monthly reporting and client screening, and represent you if ONJN asks questions. The way domains end up on the list is explained in how sites get blacklisted.