Message 001
Communication from the Commission - TRIS/(2026) 1405
Directive (EU) 2015/1535
Notification: 2026/0258/ES
Notification of a draft text from a Member State
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MSG: 20261405.EN
1. MSG 001 IND 2026 0258 ES EN 22-05-2026 ES NOTIF
2. Spain
3A. Subdirección General de Asuntos Industriales, Energéticos, de Transportes y Comunicaciones, y de Medio Ambiente.
Dirección General de Coordinación del Mercado Interior y otras Políticas Comunitarias.
Secretaría de Estado para la Unión Europea
Ministerio de Asuntos Exteriores, Unión Europea y Cooperación.
Plaza del Marqués de Salamanca, 8 (28006 Madrid)
3B. GOBIERNO DE CANTABRIA
Consejería de Presidencia, Justicia, Seguridad y Simplificación Administrativa
Servicio de Juegos y Espectáculos
C/Peña Herbosa, 29
39003 Santander
4. 2026/0258/ES - SERV10 - Electronic signature
5. ORDER REGULATING THE USE OF DEBIT BANK CARDS IN GAMBLING ESTABLISHMENTS IN CANTABRIA.
6. The purpose of the order is to regulate the use of bank debit cards or other similar devices integrated into machines intended for ticket management, coin exchange and prize payouts, for use in gambling machines
7.
8. The purpose of this order is to regulate the use of bank debit cards or other similar devices integrated into machines intended for ticket management, coin exchange and prize payouts, for use in Type B gambling machines in gambling establishments in Cantabria and in Type C machines at the Casino.
Electronic devices that allow the reading of cards, or other similar payment methods, must be integrated into machines intended for ticket management, coin exchange and prize payouts.
It is a ticketing management system that allows players to insert credits into a gambling machine using tickets, in addition to the existing cash method. Tickets are issued in the form of redeemable vouchers or tokens that are validated at gambling machines within the premises, or at terminals or cash machines equipped with validation units and ticket printing systems (POS-TITO system or similar).
The unmanned point-of-sale terminal will issue tickets for the amount requested by the user, by debiting the corresponding amount from their debit card, subject to the limit set out in Article 5.
The ticket issued may be used at any machine equipped with the ticket system for redemption into vouchers or another ticket, provided that the machine is connected to the ticket-issuing system (POS-TITO system or similar) at the same premises.
Printed tickets are valid only at the gambling premises where they were issued. If a customer wishes to stop playing or leave the premises, they can redeem the balance on their tickets at the cashier’s desk or exchange counter for either cash or a credit to their debit card.
9. The provisions set out in Decree 23/2008 of 6 March, which approves the Regulation on Recreational and Gambling Machines, state in Article 7(i) that:
For Type B1 and Type B2 machines installed in gambling arcades, bingo halls and casinos, the use of electronic or magnetic cards known as prepaid cards shall be permitted. Their issuance which shall be authorised by the regional ministry responsible for gambling, exclusively for each establishment, and they must be purchased and redeemed on the premises of the same establishment. The payment of prizes may also be carried out through such cards. The limit set out in point (d) of this article shall not apply to these cards.
The same consideration is given to Type B3 machines in Article 8(1)(b) , to Type B4 machines in Article 8 bis (e), and to Type B5 machines in Article 8 ter (2).
In addition, Article 11(a) on the general requirements for Type C machines states that:
(a) The stake shall be the amount specified for each model in the approval and registration decision in the Gaming Register. Nevertheless, several bets may be placed on a single game, up to the maximum limit set in the Resolution on approval and registration of the model.
Casinos may use tokens, prepaid magnetic cards or other physical media instead of legal tender, which shall be exchangeable or refundable for legal tender within the same establishment.
Given the fast-paced nature of today’s society and the constant evolution of payment methods, there is a need to adapt the regulation of the gambling industry, making it possible to reduce the handling of large amounts of cash. In this sense, payment through electronic systems may constitute a key element for the optimisation of the financial system, facilitating fast, secure and accessible transactions from any location. This transformation is essential to ensure a safer and more transparent environment, aligned with technological developments and current needs.
Given that Law 4/2022 of 24 June on the Regulation of Gambling in Cantabria, adopted in the exercise of the exclusive powers conferred on the Autonomous Community by Article 24(25) of the Statute of Autonomy for Cantabria, paves the way for further regulatory development, this draft aims to continue that process, establishing a balanced regulatory framework that strikes the necessary balance between the principle of free economic initiative and the need to prevent the effects that its exercise may have on public order, public health and public safety, as well as to prevent fraud.
Starting from the recognition of gambling as a legitimate social activity—insofar as it constitutes an expression of the principle of individual freedom enshrined in the Spanish Constitution of 1978—it has, over the years, established itself as a sector within the economy, characterised by its dynamism and evolution, and particularly influenced by recent technological advances.
In this regard, gambling activities have intrinsic characteristics that make it necessary for the Administration to set out regulations establishing mechanisms that provide security for gambling users, guarantee the protection of minors and those who need it for health reasons and safeguard public order and the proper conduct of gambling activities.
In addition, it is important to note that such payment systems have a positive impact on improving the security of gambling establishments and the traceability of the transactions carried out, thus contributing to the reduction of fraud and money laundering.
9a. Given that Law 4/2022 of 24 June on the Regulation of Gambling in Cantabria, adopted in the exercise of the exclusive powers conferred on the Autonomous Community by Article 24(25) of the Statute of Autonomy for Cantabria, paves the way for further regulatory development, this draft aims to continue that process, establishing a balanced regulatory framework that strikes the necessary balance between the principle of free economic initiative and the need to prevent the effects that its exercise may have on public order, public health and public safety, as well as to prevent fraud.
Starting from the recognition of gambling as a legitimate social activity—insofar as it constitutes an expression of the principle of individual freedom enshrined in the Spanish Constitution of 1978—it has, over the years, established itself as a sector within the economy, characterised by its dynamism and evolution, and particularly influenced by recent technological advances.
The order proposes the use of personalised debit cards in gambling establishments to purchase tickets or top up electronic cards for use in gaming machines, whilst balancing this against the objectives of protecting public health and safety, as well as preventing fraud.
9b. Gambling activities have intrinsic characteristics that make it necessary for the Administration to set out regulations establishing mechanisms that provide security for gambling users, guarantee the protection of minors and those who need it for health reasons and safeguard public order and the proper conduct of gambling activities.
In addition, it is important to note that such payment systems have a positive impact on improving the security of gambling establishments and the traceability of the transactions carried out, thus contributing to the reduction of fraud and money laundering.
9c. The purpose of the draft Order is to regulate the requirements for the authorisation of the use of bank payment cards or other similar devices in gambling activities for the acquisition of payment cards or physical or electronic payment media for use in type B and C gambling machines located in gambling premises’.
Until now, gambling establishments have been using the TITO system, which allows them to issue tickets or electronic cards from the establishment itself, which are used to access the games on the machines installed on the premises. Currently, these tickets or electronic cards can only be purchased with cash. Under this order, it is envisaged that they may be purchased using cards, provided these are debit cards registered in the name of the person using them, with a maximum limit of EUR 300 per day, conditions according to which the device must be configured.
The Order does not impose any new obligations or unnecessary administrative burdens on the parties concerned beyond those provided for in Law 4/2022 of 24 June on the Regulation of Gambling in Cantabria.
As has been the case until now, payment in cash may continue to be used exclusively. This new option will not be mandatory and will allow businesses to legally offer customers an alternative payment method, even subject to the established restrictions.
10. References to the basic texts: The basic texts were forwarded with an earlier notification:
2012/0425/E
11. No
12.
13. No
14. No
15. Yes
16.
TBT aspects: No
SPS aspects: No
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European Commission
Contact point Directive (EU) 2015/1535
email: grow-dir2015-1535-central@ec.europa.eu
