Game rules and the special part of the internal rules: what ONJN approves

Every Romanian gambling operator needs two documents approved by the ONJN Supervisory Committee before it can obtain an operating authorization for a game: its game rules (regulament de joc) and the special part of its internal rules (regulament intern – partea specială). Both are defined in art. 2 of HG 111/2016, the methodological norms for OUG 77/2009. The game rules govern the relationship with players; the special part governs who inside the company is responsible for what. Neither can be changed without new approval.

This guide was first published in September 2019. The structure is unchanged; the content now reflects the tax, AML, self-exclusion and labor rules in force in October 2026.

How ONJN approves the two documents

The operator drafts both documents and files them with the license or authorization application, for each type of game it will run. Having reviewed them, the Supervisory Committee can:

1. approve one or both documents as proposed;
2. approve them with its own amendments; or
3. reject them, giving reasons, and ask the operator to submit a revised version.

Approval is not a one-off. Under art. 27 of HG 111/2016, any later amendment may be made only with the Supervisory Committee’s approval, and amended game rules apply to players only from the date of approval. An operator that changes its terms on the website without approval breaches its authorization, even if the change favors players. Our Romania Class 1 license guide shows where both documents sit in the application dossier.

Part I: the game rules

What they are

HG 111/2016 defines game rules as the set of rules, norms and procedures issued by the operator and approved by the Supervisory Committee that govern how the game is run between the operator and the participant. They are the legal basis of the player relationship: by taking part, the player accepts them without reservation. For betting, lotteries and tournaments the norms add specific content requirements (for example arts. 17, 20 and 72).

What they should cover

In our experience, game rules that pass review without rounds of amendments cover the following:

• Operator identification: company, license and authorization numbers, and confirmation that the operator meets the legal conditions for the game type.
• Means of play: the certified main means of play (software, terminals, live tables), dedicated equipment and venues, and the auxiliary means such as chips, tickets, coupons and account balances, with how players obtain them.
• Who may play: the legal right to participate, the ban on minors in venues and in all gambling, and the ban on traditional (land-based) play without a valid identity document. The minimum age is 18; bills to raise it to 21 passed the Senate in 2026 but had not been enacted when this guide was updated. See our article on enforcing the ban on minors.
• Responsible gambling: limits, reality checks and self-exclusion, including checks against the national self-exclusion database run under ONJN Order 79/2025.
• Stakes and prize funds: minimum and maximum stakes and, where relevant, how the prize fund is set from participation fees.
• Results: how random results are generated, or how results based on events outside the operator’s control (sports, races) are determined and settled, including void and cancelled events.
• Validation and payment: approval of results, validation of winnings and of the proof of winning, and the payment terms. HG 111/2016 leaves payment terms to the game rules, so they must be stated precisely.
• Tax: withholding on winnings at the bands in force since 1 August 2025 under Law 141/2025: 4% up to RON 10,000, RON 400 plus 20% of the excess up to RON 66,750, and RON 11,750 plus 40% above that. Online, the tax is withheld when the player withdraws. Rules approved before August 2025 that quote older rates must be amended. Details are in our article on bookmakers’ tax duties.
• Personal data: what is collected for tax returns and AML, and the GDPR legal basis for each purpose. Art. 6 GDPR allows six: consent, performance of a contract, legal obligation, vital interests, public interest or official authority, and legitimate interests, unless the player’s rights prevail, especially where the player is a child.
• AML: suspicious transaction reporting, reporting of cash transactions of €10,000 or more, and customer due diligence when a player collects winnings or buys or exchanges chips for at least €2,000 in one or linked operations (Law 129/2019, art. 13). See our Law 129/2019 article.
• Complaints: how players complain, response times and the escalation route to ONJN and consumer bodies.

Where they must be available

For land-based casinos, a copy identical to the version approved by the Supervisory Committee must always be kept at the venue and shown to participants (art. 43); poker clubs and tournaments have the same rule. Online operators must display copies of their license and authorization on the website (art. 12) and the ban on minors on the start page (art. 8); in practice the approved game rules are published there as well, and the published text must match the approved one word for word.

Part II: the internal rules and their special part

The general part: Labor Code requirements

Every Romanian employer must have internal rules under arts. 241–246 of the Labor Code (Law 53/2003). The employer drafts them after consulting the union or employee representatives. Art. 242 requires at least the following categories of provisions:

1. health and safety at work;
2. equal treatment, non-discrimination and removal of any breach of dignity;
3. rights and obligations of employer and employees;
4. the procedure for employee requests and complaints;
5. concrete rules on work discipline;
6. disciplinary offences and sanctions;
7. disciplinary procedure;
8. how other specific legal or contractual provisions apply;
9. criteria and procedures for professional evaluation;
10. notice periods; and
11. the general training policy, where one exists.

The last two were added after this article first appeared. Under art. 243, the employer must bring the rules to each employee’s attention on the first working day, on paper or electronically, and keep proof; they bind the employee from that moment and must be displayed at the employer’s premises. Any change follows the same procedure.

The special part: what ONJN approves

Gambling operators must add a special part, specific to the type of game they are authorized for. HG 111/2016 defines it as the section setting the individual responsibilities and competences of the staff directly involved in running the games, and it is subject to Supervisory Committee approval. Changes also need approval.

The special part must cover staff duties, the financial and accounting records system, the security of documents and assets, and the location of the servers. In practice it maps each obligation in the game rules to a named role:

• organization chart and reporting lines;
• who provides dedicated equipment to players, and who manages auxiliary means of play and how players obtain them;
• who enforces the ban on minors and the ID requirement, and who checks the self-exclusion database;
• who sets stakes and prize-fund categories;
• who approves results, validates winnings and proof of winning, and authorizes payments;
• who calculates and withholds tax and prepares returns;
• who processes personal data and on what legal basis; and
• who is the designated AML person, who files suspicious and cash transaction reports, and who applies due diligence at the €2,000 threshold.

ONJN reads the two documents together. A duty in the game rules with no owner in the special part, or a role in the special part that does not exist on the organization chart, is a common reason for amendments.

What applies now (2026)

Three developments since 2019 affect both documents:

• Tax and AML figures have changed. The 2025 winnings bands and the AML rules as amended by Law 86/2025 must be reflected, and the EU AML Regulation (EU) 2024/1624 will apply from 10 July 2027.
• Self-exclusion is centralized. Operators must check players against the national database under ONJN Order 79/2025 and assign that task in the special part.
• Land-based venues need a local authorization. Under OUG 7/2026, local councils decide whether gambling halls may operate, where, and on what terms, and venue, equipment and game-rule requirements are to be set in methodological norms. Land-based operators should expect their game rules to be revisited once those norms are adopted.

Operators whose rules were approved several years ago should review them now and file amendments in one batch, rather than piecemeal. Our compliance services include drafting game rules and special parts and managing their approval with ONJN.