Romania’s iGaming framework: ONJN public consultation on T&C standards, test accounts and virtual credit

Romania’s remote gambling regulatory framework may be entering a new phase.

ONJN has launched a public consultation on two draft orders that could significantly affect remote gambling operators, suppliers, affiliates, streamers and other stakeholders active in the Romanian iGaming market.

The consultation is open until 17 July 2026.

The first draft order concerns minimum standards for the drafting, content, transparency and application of game rules, terms and conditions and promotional rules used by remote gambling operators.

The second draft order concerns the use of test accounts, virtual credit and demonstration sessions on remote gambling platforms, including in the context of public demonstrations, live streams and promotional content.

To support stakeholders reviewing the consultation, we have attached to this news update two practical bilingual working documents:

• a working document covering the draft order on T&C, game rules and promotional rules; and
• a working document covering the draft order on test accounts, virtual credit and demonstration sessions.

These documents are intended to help operators and other industry stakeholders navigate the proposed requirements, identify operational impact points and assess whether comments should be submitted to ONJN before the consultation deadline.

Why this matters

These proposals are not limited to legal drafting.

They may affect how operators structure T&Cs, present bonuses and promotions, manage withdrawals, communicate KYC/AML checks, evidence version control, use test accounts, monitor virtual credit and regulate their relationships with affiliates, streamers and marketing partners.

1. Game rules, T&C and promotional rules

The first draft order seeks to introduce minimum standards for T&Cs and promotions.

Among the relevant proposals are requirements for T&C and related documents to be drafted in clear, simple and unambiguous language. These documents would need to be available before registration, before deposits and before bonus acceptance.

The draft also refers to sensitive clauses, including provisions dealing with withdrawals, account suspension, cancellation of winnings, bonuses, KYC/AML checks, fees, unilateral changes to T&C and dispute resolution.

Economic transparency is another key area. Operators may need to communicate clearly, before participation, relevant commercial information such as cost of play, stake limits, win limits, fees, estimated withdrawal-processing times and RTP, where applicable.

Bonuses and promotions are also under review. Bonus value, wagering requirements, expiry dates, eligible games, withdrawal limitations and the order of use of own funds and bonus funds may need to be presented in a visible summary and expressly accepted before activation.

The draft also addresses clauses that may be considered incompatible with the proposed framework, including broad discretionary powers, vague technical-error exceptions, unjustified withdrawal restrictions and disproportionate exclusions of liability.

2. Test accounts, virtual credit and demonstration sessions

The second draft order focuses on ensuring a clear separation between test or demo activity and real-money gambling activity.

Test accounts would need to be notified to ONJN through a framework notification and recorded in a dedicated register. The register would need to reflect relevant information such as account identifiers, purpose, responsible persons, virtual credit allocated or consumed, simulated rounds, technical incidents and evidence of exclusion from jackpots, bonuses and real-money reporting.

Virtual credit would need to remain strictly virtual. It would have no monetary value and could not be deposited, withdrawn, converted, transferred or used in real-money games.

The draft also seeks to prevent test accounts from influencing GGR, RTP, tax reporting, jackpots, bonuses, promotional campaigns or other real gambling indicators.

A particularly important area concerns public communication. Demo sessions, live streams and promotional materials using test accounts or virtual credit would need to clearly and continuously inform the public that virtual funds are being used and that the amounts displayed do not represent real-money winnings.

Operators would remain responsible for compliance even where the content is produced by streamers, affiliates, influencers, agencies or other partners acting in connection with their brand or platform.

What operators should review now

Operators and relevant stakeholders should consider reviewing:

• existing T&C and game rules;
• bonus and promotional rules;
• withdrawal and KYC/AML communication flows;
• sensitive clauses and limitation-of-liability provisions;
• version control and audit trails;
• test-account policies and registers;
• virtual credit controls;
• contracts with affiliates, streamers and agencies;
• internal approval processes for demo or promotional content.

How Cojocaru & Asociații can assist

Cojocaru & Asociații can assist operators, suppliers and industry stakeholders with regulatory impact analysis, review of T&C and promotional rules, test-account governance, promotions review, internal compliance documentation and preparation of comments for submission to ONJN.

The consultation remains open until 17 July 2026.

For businesses active in or entering the Romanian iGaming market, this is an important opportunity to assess the proposed framework before the rules are finalized and to prepare a structured response where appropriate.

This material is for general information only and does not constitute legal advice.