The pre-2024 picture
Before OUG 82/2023 entered force on 1 January 2024, Romania's online gambling tax stack consisted of:
- 16% special revenue tax on gross gaming revenue (GGR) for online Class 1 operators.
- Standard 16% corporate income tax on net profit (the microenterprise regime has always been statutorily unavailable for gambling under Article 47 of the Fiscal Code).
- Player-level taxation at progressive rates on winnings, withheld at source by the operator.
- Annual ONJN authorisation and supervision fees as fixed amounts.
- 1% responsible-gambling contribution to the dedicated state fund.
The pre-2024 stack produced an all-in effective tax burden of approximately 25–30% of GGR for typical online operators — meaningfully higher than offshore alternatives but still competitive against premier-tier EU jurisdictions like the UK and Malta.
What OUG 82/2023 changed
OUG 82/2023 — issued in October 2023, in force from 1 January 2024, with further amendments through 2024 — reshaped the tax stack significantly. The headline changes:
- Revenue tax raised from 16% to 27% of GGR — the central change, a 65% increase in the rate applied to the gambling-revenue base. This was framed politically as a budget-deficit measure rather than a gambling-policy intervention.
- Responsible-gambling contribution doubled from 1% to 2% of revenue.
- Player-level taxation thresholds re-calibrated — the 3% rate now applies up to RON 66,750 (raised from RON 66,000), the 20% rate between RON 66,750 and RON 445,000, and the 40% rate above. The rate structure itself was preserved but the bracket boundaries shifted modestly.
- Stricter substance requirements on Romanian commercial presence, originally proposed and partially watered down through 2024 amendments under industry pressure.
- Tightening of bonus deductibility — bonus awards to players are creditable against GGR only where they meet specific structural tests, narrower than the pre-2024 treatment.
The 27% rate puts Romania in the same tax-burden tier as the UK and slightly above Malta — but with materially fewer of the brand-prestige benefits of either.
The reform was contested by industry but enacted with limited political pushback. Subsequent draft amendments — including proposed exemptions for "responsible" operators and a potential return to 16% — have not been enacted as of mid-2026.
What the 27% applies to
The 27% rate applies to gross gaming revenue (GGR), defined under Article 17 of GEO 77/2009 as amended as:
Total stakes received from players, minus total winnings paid to players, minus deductible bonuses (where structurally qualifying), minus jackpot contributions to dedicated jackpot pools.
Critically, operational costs are not deducted before the 27% applies. Marketing, technology, payment-processing fees, customer-acquisition costs, and salaries are not offset against the GGR base. This is the key structural distinction between Romania's revenue tax model and a profit tax model.
The bonus-deductibility question is the most-litigated under the 2024 framework. To be creditable against GGR, a bonus must:
- Be a direct credit to the player's gaming account (not a marketing cash gift or external reward).
- Be subject to wagering requirements that result in eventual conversion to GGR if the player loses the bonus before withdrawal.
- Be documented in the operator's bonus terms and conditions filed with ONJN.
- Not exceed 15% of the operator's monthly GGR, in aggregate across all bonuses — a cap introduced in mid-2024 to limit aggressive bonus-engineering.
The cap means operators running heavy bonus programmes pay 27% on a base that includes substantial bonus value they cannot deduct. This has shifted player-acquisition strategies away from headline-grabbing bonus offers toward more sustainable engagement models.
Player-level taxation
Romanian players pay tax on their gambling winnings at progressive rates, withheld at source by the operator and remitted to ANAF:
- 3% on winnings up to RON 66,750 per gaming session.
- 20% on winnings between RON 66,750 and RON 445,000.
- 40% on winnings above RON 445,000.
The thresholds apply per gaming session, not annually — a player who wins multiple separately-classified jackpots in a year does not aggregate them for tax purposes. This is structurally favourable for high-volume players relative to most European jurisdictions.
The operator's compliance burden: withhold tax at the correct bracket at the moment of withdrawal, issue a tax certificate to the player, and remit to ANAF monthly. Errors in player-tax withholding are among the most common findings in ONJN inspections — see our substance piece.
Corporate income tax interaction
On top of the 27% GGR tax, gambling operators pay standard 16% corporate income tax on net profit. The interaction works as follows:
- 27% special tax is calculated on GGR and remitted monthly. This tax is deductible from the operator's income for corporate income tax purposes — i.e., it functions as a business expense for CIT calculation.
- After deducting the 27% special tax (along with operational costs — staff, marketing, technology, etc.), the resulting net profit is subject to 16% CIT under Title II of Law 227/2015.
- The microenterprise regime is statutorily unavailable for gambling under Article 47 of the Fiscal Code.
- Dividend tax of 8% applies on distributions, withheld at source — see our personal tax piece.
The combined picture for an operator with EUR 10M GGR and typical operational margins:
- GGR: EUR 10,000,000
- 27% special tax: EUR 2,700,000
- Operational costs: ~EUR 5,500,000 (marketing, tech, payments, staff, rent, supplier fees)
- Responsible-gambling fund: EUR 200,000 (2% of GGR)
- Net profit before CIT: EUR 1,600,000
- 16% CIT: EUR 256,000
- After-tax profit: EUR 1,344,000
- All-in effective tax burden: ~31% of GGR
International comparison
Where does Romania's 27% rate sit in the international landscape? Quick comparison across the jurisdictions Romanian operators most commonly weigh:
- United Kingdom — Remote Gaming Duty of 21% on GGR, plus standard 25% corporation tax. Effective burden similar to Romania at ~28–32% but with materially more banking access and EU/global brand strength via the UKGC.
- Malta — 5% gaming tax on GGR plus corporate income tax (with significant refund mechanisms reducing effective CIT to 5–7% for non-Maltese shareholders). All-in effective burden ~10–15% of GGR — materially lower than Romania, plus the MGA brand premium. Higher upfront cost and slower timeline.
- Curaçao — Headline tax burden ~2% of GGR plus modest annual fees. All-in burden ~4–6%. But Curaçao licences carry significant reputational and banking-access constraints; many operators use Curaçao as a back-up jurisdiction rather than a primary base.
- Anjouan — Similar to Curaçao on tax burden (~2–4%). Faster timeline but even more banking-access constraint.
- Sweden, Denmark, Spain, Germany — Tax burdens range 18–25% of GGR. Comparable to Romania but with smaller addressable markets in absolute terms.
Romania's tax burden positions it above offshore alternatives but below the most punitive European regulated markets. Combined with the moderate-cost authorisation and growing Romanian domestic market, the all-in commercial proposition remains competitive — though materially less attractive than pre-2024.
Forward planning
The political environment around Romanian gambling taxation is volatile. Operators planning entries in 2026 should model for:
- Potential further rate increases — draft proposals to lift the rate to 30–32% have circulated but not enacted. Probability of enactment in 2026–2027 we assess as moderate.
- Tightening of bonus rules — further restrictions on bonus deductibility and player-acquisition costs are likely as the regulator targets revenue extraction.
- Player-tax bracket adjustments — periodic recalibration of the 3%/20%/40% thresholds, typically modest.
- Substance requirements — likely strengthening, particularly around local employment and Romanian-territory data hosting.
- Crypto and emerging-product taxation — once Romanian MiCA transposition stabilises, expect dedicated tax treatment for crypto-deposit operators.
The strategic decision for operators: Romania remains commercially viable but the margin for error is smaller than it was pre-2024. The cluster pieces on Class 1, Class 2, and jurisdiction comparison cover the structural decision in more detail.
Frequently asked questions
Is the 27% on player deposits or net gaming revenue?
On net gaming revenue (GGR) — total stakes minus total winnings paid out, with limited deductions for qualifying bonuses and jackpot contributions. Player deposits before play are not taxed. The base is calculated monthly and the 27% remitted monthly.
Do I deduct bonuses before applying the 27%?
Only qualifying bonuses, subject to a 15% monthly cap. The bonus must be a direct credit to the player's gaming account, subject to wagering requirements, documented in the operator's ONJN-filed bonus terms, and within the aggregate 15%-of-monthly-GGR cap. Marketing cash gifts and external rewards do not qualify.
Is the 27% rate the final tax burden, or are there additional layers?
The 27% is the headline gambling-specific tax. Operators additionally pay 16% corporate income tax on net profit (after deducting the 27% as a business expense), 8% withholding on distributed dividends, 2% responsible-gambling fund contribution on GGR, plus annual ONJN authorisation and supervision fees. All-in effective burden runs ~30–32% of GGR for typical operators.
What player-level tax applies to winnings?
Progressive: 3% up to RON 66,750 per session, 20% from RON 66,750 to RON 445,000, 40% above. Withheld at source by the operator at withdrawal, remitted to ANAF monthly. Players receive a tax certificate. The session-based (not annual) bracket structure is materially favourable for high-volume players.
Will the rate change again in 2026?
Drafts have circulated proposing increases to 30–32% but none have been enacted. Equally, industry has pushed for a return to 16% citing market shrinkage; this has also not been adopted. Our working assumption for 2026 planning is rate stability at 27%, with moderate probability of an upward revision. We re-assess this view quarterly.
Can I use a tax-efficient corporate structure (e.g. a Maltese holding) to mitigate the burden?
The 27% applies at the Romanian Class 1 operating entity level regardless of upstream corporate structure. Holding-company optimisation (Maltese, Dutch, Cypriot) can affect the effective rate on distributed profits — particularly via EU Parent–Subsidiary Directive treatment — but does not reduce the 27% GGR tax. Structural planning is meaningful at the 16% CIT and 8% dividend layers, not at the 27% layer.
Talk to us
Modelling the actual effective tax rate for your specific business model — across GGR projections, bonus strategies, holding structures, and CIT planning — is part of every Bespoke iGaming engagement. We work the spreadsheet against your real projections and tell you what Romania actually costs versus the alternatives. Book a discovery call.
Related guides
- iGaming licensing under ONJN: the complete 2026 guide — the pillar overview
- ONJN Class 1 (B2C) authorisation in detail — where the 27% tax applies
- Romania vs Malta, Anjouan, Curaçao for iGaming — jurisdictional tax comparison in context
- The 1% microenterprise tax (and why it does not apply to gambling) — the statutory exclusion under Article 47
- 10% personal income tax and 8% dividend tax — shareholder-level taxation on distributed profits