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Coljuegos — Empresa Industrial y Comercial del Estado Administradora del Monopolio Rentístico de los Juegos de Suerte y Azar — Colombia online-gambling standards explorer (Lei 643/2001 · Acuerdo Coljuegos 04/2016 + pipeline 2017–2025 · Resolución 20244000022654/2024 (consolidated RG framework) · Decreto 0240/2026 (16 percent INC after Corte Constitucional struck down 19 percent IVA))
All 162 Colombian standards, organised by theme
A searchable, filterable index of Colombia's online-gambling rulebook, drawn from article 336 of the 1991 Constitution, Ley 643 of 2001 (the rentistic-monopoly framework), Ley 1393 of 2010, Decreto-Ley 4142 of 2011 (creation of Coljuegos), Decreto 1068 of 2015 Parte 7, the Acuerdos Coljuegos that govern juegos operados por internet (notably Acuerdo 04 of 2016) and the technical Resoluciones on AML, certification and supervision. Standards are grouped by theme, tagged editorially and deep-linkable.
Editorial summary, not legal advice. Every card on this page is a plain-English summary of the regulator's own rule, cross-checked against the primary source. Always verify against the published text before filing, launching, or advising.
Colombian gambling sits on top of a constitutional rule that earmarks the proceeds for the public health system. Article 336 of the 1991 Constitution, Ley 643 of 2001 and Ley 1393 of 2010 fix the rentistic monopoly; Decreto-Ley 4142 of 2011 hands operational power to Coljuegos.
9 standards4 player-flagged
44%
player-flagged
Regulatory risks this theme addresses
Operating outside the rentistic monopoly without a concession contract with Coljuegos
Failing to direct the constitutionally earmarked revenue to the health system
Treating the regime as a licence model when it is a contractual concession one
Constitution, framework laws and supervising bodies 9
Constitución Política art. 336
Gambling as a national rentistic monopoly
Player Rights
Article 336 of the 1991 Political Constitution treats gambling as a national rentistic monopoly (monopolio rentístico de arbitrio rentístico) whose net proceeds are earmarked for the public health system. No private party may operate any game of chance other than under a regime established by the framework law and a specific authorisation from the competent state body.
Requirements
Operate only under a Coljuegos concession contract or authorisation expressly anchored in art. 336
Treat net rentistic income as constitutionally destined to the SGSSS public health system
Do not rely on local or municipal permissions that bypass the national monopoly
Document constitutional anchoring in the compliance manual
Article 336 also requires that operating regimes for monopolies be set by a framework statute approved by absolute majority of Congress; Ley 643 of 2001 is that statute.
Ley 643/2001
Régimen Propio del Monopolio Rentístico de los Juegos de Suerte y Azar
Player Rights
Ley 643 of 16 January 2001 is the framework statute for the gambling monopoly. It defines games of chance, classifies them (lotteries, permanent betting or chance, novel games, localised games and promotional games), fixes the destination of revenue to health and creates the rentas del monopolio (exploitation rights and administrative expenses).
Requirements
Map every product to one of the five Ley 643 categories before launch
Pay derechos de explotación and gastos de administración exactly as Ley 643 prescribes
Direct net monopoly income to the entities listed in arts. 41 to 49 of the law
Maintain records sufficient to evidence revenue destination on Coljuegos request
Online betting is operated as a juego novedoso under Ley 643 and was first opened by Acuerdo Coljuegos 04 of 2016.
Ley 643/2001 art. 5
Definition of games of chance and the rentistic monopoly
Article 5 of Ley 643 defines games of chance and luck (juegos de suerte y azar) as those where one or more persons pay a sum or make a bet in cash or kind to a person who, depending on a future event of uncertain outcome not influenced by the bettor, commits to give in return a prize in cash or kind. The definition covers every game in which the result is uncertain regardless of the level of skill involved.
Requirements
Treat any product where the outcome depends on a future uncertain event as inside the monopoly
Do not rely on a skill-game classification to escape Coljuegos jurisdiction
Document the legal qualification of every product offered to Colombian players
Apply Ley 643 even when the prize is in kind, not cash
Ley 643/2001 art. 7
Five-year terms and contractual operation by third parties
Player Rights
Article 7 sets the framework under which the operation of games of chance may be carried out by third parties through concession contracts or authorisations. It establishes the maximum term of five years for concessions and links the contractual model used today by Coljuegos for online betting.
Requirements
Treat the operating right as a fixed-term concession of up to five years, not a perpetual licence
Build commercial plans on a five-year horizon with renewal as a separate procedure
Provide for the orderly handover of player accounts and balances at contract end
Maintain records of contract milestones for audit
Ley 1393/2010
Earmarking of monopoly proceeds for the SGSSS
Ley 1393 of 12 July 2010 reinforces the destination of gambling revenue to the Sistema General de Seguridad Social en Salud and modifies certain rates and allocations under Ley 643. It strengthens the health-funding rationale for the rentistic monopoly and conditions any change to allocation rules.
Requirements
Treat changes in rates as having direct downstream consequences for the SGSSS
Cooperate with Ministerio de Salud and Supersalud transfer reporting
Disclose to senior management the political sensitivity of the health-funding mandate
Track legislative proposals that affect the allocation of monopoly revenue
Decreto-Ley 4142/2011
Creation of Coljuegos as the national regulator
Player Rights
Decree-Law 4142 of 3 November 2011 created the Empresa Industrial y Comercial del Estado Administradora del Monopolio Rentístico de los Juegos de Suerte y Azar (Coljuegos) as a decentralised public enterprise attached to the Ministerio de Hacienda y Crédito Público. Coljuegos exercises exploitation, administration, operation and regulatory issuance powers over the games of chance that are not assigned by law to a different entity (it does not administer lotteries or chance, which remain with departments and the Capital District).
Requirements
Direct all licence-equivalent processes for online betting to Coljuegos
Recognise that lotteries and chance (apuestas permanentes) sit with departmental operators, not Coljuegos
Use Coljuegos as the regulator name on all bettor-facing disclosures and complaints
Track Coljuegos board appointments and structural decrees that affect supervisory capacity
Decreto 1451 of 2015 later adjusted Coljuegos's internal structure.
Decreto 1068/2015 parte 7
Único Reglamentario for the gambling sector
Decree 1068 of 26 May 2015 is the Decreto Único Reglamentario del Sector Hacienda y Crédito Público. Part 7 of Book 2 consolidates the regulatory provisions for games of chance, including the régimen for novel games operated by internet, raffles, promotional games and concession contracts. Any subsequent decree on Coljuegos matters typically amends Parte 7 of Decreto 1068.
Requirements
Use Decreto 1068 Parte 7 as the canonical secondary-regulation reference
Cross-reference each Coljuegos Acuerdo to the article of Decreto 1068 it implements
Track amendments such as Decreto 1486 of 2024 that change Parte 7 content
Brief legal counsel on changes to Decreto 1068 before redesigning a product
Decreto 1451/2015
Reorganisation of Coljuegos's internal structure
Decree 1451 of 14 July 2015 modified the structure of Coljuegos, redefining its vice-presidencies and supervisory directorates. The current organisation includes a Vicepresidencia de Desarrollo Comercial (commercial development) and a Vicepresidencia de Operaciones (operations and supervision), which jointly manage the JOSAO online-betting authorisations.
Requirements
Direct commercial enquiries to the Vicepresidencia de Desarrollo Comercial
Direct supervisory filings and sanctions correspondence to the Vicepresidencia de Operaciones
Use the correct functional area when escalating regulatory questions
Keep contact records updated after each Coljuegos restructure
Supersalud — supervisory mandate
Health-system supervision of monopoly transfers
The Superintendencia Nacional de Salud supervises the transfer of gambling revenue to the SGSSS. Although it does not authorise operators, it has visibility over the rentistic transfers and may request supporting information from Coljuegos and ADRES (the Administradora de los Recursos del Sistema General de Seguridad Social en Salud).
Requirements
Anticipate Supersalud or ADRES requests for supporting transfer information
Keep transfer evidence for at least five years
Coordinate with Coljuegos before responding to Supersalud queries
Track Supersalud rulings that affect monopoly-revenue allocation
2
Theme 2
Licensing & concession contracts
Colombia does not issue licences in the European sense. Operators sign a five-year concession contract with Coljuegos under Acuerdo 04 of 2016. The contractual model dictates fees, guarantees and operational duties, and ends with handover of player accounts and balances.
26 standards18 player-flagged
69%
player-flagged
Regulatory risks this theme addresses
Operating without an effective concession contract and approved performance guarantee
Letting the bank or insurance guarantee lapse mid-term
Failing to plan for orderly contract termination and player-balance return
The JOSAO concession-contract model 20
Acuerdo Coljuegos 04/2016
Reglamento for novel games operated by internet (JOSAO)
Player Rights
Acuerdo 04 of 5 July 2016 approved the reglamento for the novel-game modality of juegos operados por internet (JOSAO). It is the foundational online-gambling instrument in Colombia. It sets the requirements for becoming an operator, the contractual concession model, the technical platform, player accounts, KYC, financial reserves and the player registry.
Requirements
Use Acuerdo 04 of 2016 as the controlling regulation for any online betting product
Cross-reference every product feature to a specific article of the Acuerdo
Track subsequent Acuerdos (06 of 2018, 02 of 2019, 04 of 2019, 02 of 2020, 05 of 2020) that amend it
Apply the consolidated text, not only the original 2016 version
Acuerdo 04 of 2016 was the first online-gambling framework in Latin America.
Acuerdo Coljuegos 04/2016 art. 1
Object and scope of the JOSAO regulation
Article 1 sets the object of the Acuerdo: to approve the reglamento for the novel game of internet-operated games of chance. Article 2 defines its subjective scope, applying to legal persons that operate the game, to players and to any natural or legal person involved directly or indirectly in the operation.
Requirements
Treat affiliates, payment processors and platform providers as within scope of the Acuerdo
Apply the rules to every interactive channel offered to Colombian players
Document how each external party in the value chain meets the Acuerdo's standards
Update scope analysis when launching new product modalities
Acuerdo Coljuegos 04/2016 art. 9
Concession contract as the operating title
Player Rights
Article 9 fixes the contractual concession as the legal title under which operators carry out internet gambling. The contract is signed with Coljuegos and replaces the concept of a unilateral administrative licence; rights and duties of both parties are governed by the contract clauses and the surrounding regulation.
Requirements
Build governance on contractual remedies, not licence-suspension procedures
Manage the contract life cycle (signature, performance, renewal, termination) end to end
Ensure each contractual obligation has a named owner inside the organisation
Retain signed-contract copies and amendments in the compliance manual
Acuerdo Coljuegos 04/2016 art. 10
Eligibility of the applicant operator
Player Rights
Article 10 sets the eligibility criteria for the applicant. The applicant must be a legal entity domiciled in Colombia or a foreign legal entity with a permanent branch in Colombia, with the corporate object including the exploitation of games of chance, and with shareholders and directors who meet the suitability tests.
Requirements
Incorporate or branch in Colombia before applying
Add the exploitation of games of chance to the corporate object
Run suitability and criminal-record checks on ultimate beneficial owners and directors
Maintain an up-to-date corporate organigramme during the contract term
Acuerdo Coljuegos 04/2016 art. 11
Five-year term of the concession contract
Player Rights
Article 11 sets the term of the concession contract at up to five years, counted from the date Coljuegos approves the performance guarantee. The term cannot be shorter than three years. Renewal requires a new procedure and a fresh performance guarantee.
Requirements
Plan product, commercial and people roadmaps on a maximum five-year contract horizon
Diarise the renewal procedure at least twelve months before contract end
Treat the date of guarantee approval, not signature, as the start of the term
Provide for orderly product wind-down if the contract is not renewed
JOSAO concession contracts run for a fixed five-year term. Renewal is not automatic. The operator must initiate the renewal procedure before expiry, evidencing continued compliance with capital, guarantee, technical-certification and AML obligations. Early termination grounds include serious breach of derechos de explotación payment, loss of the póliza de cumplimiento, revocation of platform certification by the accredited laboratory, and conviction of the operator or its UBOs for offences against the rentistic monopoly.
Acuerdo Coljuegos 04/2016 art. 12
Minimum paid-in capital
Article 12 sets a minimum subscribed and paid-in capital for the operator, which Coljuegos has periodically updated. The capital floor must be maintained throughout the contract term and evidenced in the audited financial statements.
Requirements
Maintain the capital floor in every quarter of the contract term, not only at signing
File evidence of capital with each annual financial-statement upload to Coljuegos
Replenish capital quickly after any drawdown to avoid a contract breach
Track changes in the capital floor published by Coljuegos
The minimum paid-in capital must be acreditado at the moment of application and held throughout the concession term. Operators must evidence the capital with up-to-date estados financieros and certifications signed by the legal representative and the statutory auditor (revisor fiscal). At the 2026 SMLMV of COP 1,750,905, working out the obligation in pesos is straightforward: SMLMV times the SMLMV-denominated figure stated in the applicable Acuerdo amendment.
Acuerdo Coljuegos 04/2016 art. 13
Performance guarantee in favour of Coljuegos
Player Rights
Article 13 requires the operator to constitute a performance guarantee (garantía única de cumplimiento) in favour of Coljuegos, through an insurance policy or a bank guarantee issued by an entity legally established in Colombia. For internet games the guarantee may be issued for annual periods and must be renewed at least three months before expiry; coverage extends until the liquidation of the contract.
Requirements
Issue the performance guarantee with a Colombia-domiciled insurer or bank
Calendar the renewal three months before each expiry date
Keep the guarantee in force from execution through to liquidation of the contract
Notify Coljuegos immediately of any insurer downgrade that affects acceptability
The performance guarantee in favour of Coljuegos can be constituted as a fidelity-bond insurance policy, a bank guarantee, or a fiduciary trust. The instrument must remain live for the entire five-year concession term plus the contractual liquidation period and must be reissued or extended before expiry to avoid an automatic breach event. The minimum dedicated reserve to back prize payments and refunds of unused participation credits is COP 615,000,000 per JOSAO supplementary guidance. Insurers must be authorised by the Superintendencia Financiera de Colombia.
Acuerdo Coljuegos 04/2016 art. 14
Non-contractual civil liability insurance
Article 14 requires the operator to take out non-contractual civil liability insurance (responsabilidad civil extracontractual) meeting the parameters of Decreto 1082 of 2015 art. 2.2.1.2.3.2.9. The insurance covers third-party damages arising from the operation.
Requirements
Take out the civil-liability policy before commencing operations
Align coverage limits with the Decreto 1082 parameters Coljuegos applies
Renew the policy in line with the performance-guarantee cycle
File a certified copy of each renewal with Coljuegos
The non-contractual civil-liability policy covers damages to third parties arising from the operation, including platform failures that affect player balances. The policy must run in parallel with the concession contract and remain endorsed in favour of affected third parties; insurers must hold a current authorisation from the Superintendencia Financiera de Colombia.
Acuerdo Coljuegos 04/2016 art. 15
Documentary requirements for the application
Player Rights
Article 15 lists the documents to file with the application: certificate of incorporation, financial statements, technical platform documentation, business plan, KYC programme, AML programme (SIPLAFT or SARLAFT), responsible-gambling programme and proof of capital and guarantee.
Requirements
Bundle the documentary set in the order Coljuegos requires
Submit certified Spanish translations for any foreign-issued document
Anticipate Coljuegos clarification requests with a versioned change log
Retain the full application file for the duration of the contract
Acuerdo Coljuegos 04/2016 art. 18
Authorised game types under the JOSAO regime
Game Design
Article 18 lists the types of games that may be offered: games whose outcome depends on a random number generator (casino, slots, poker, bingo, live games) and games whose outcome depends on a real event on which the player makes a prediction (sports and event betting). Subsequent Acuerdos expanded the catalogue (notably to include virtual games and additional novel modalities).
Requirements
Map each product to one of the categories of art. 18
Treat additions (virtual games, novel modalities) as requiring a Coljuegos product approval
Do not launch a product outside the authorised catalogue without prior Coljuegos clearance
Track Acuerdos 04 of 2019, 02 of 2020 and 05 of 2020 for catalogue extensions
Acuerdo Coljuegos 06/2018
Amendments to the JOSAO regulation
Acuerdo 06 of 2018 amended Acuerdo 04 of 2016, refining the technical platform requirements, the catalogue of authorised games and the supervisory data feeds that Coljuegos receives from operators. It tightened reporting cadence and aligned platform standards with international testing-lab criteria.
Requirements
Update the technical platform documentation to reflect the Acuerdo 06 changes
Reconfigure the supervisory data feed cadence as required
Re-certify components affected by the technical-standards update
Refresh the internal compliance manual to incorporate the amendments
Acuerdo Coljuegos 02/2019
Further amendments to JOSAO
Acuerdo 02 of 2019 introduced additional adjustments to JOSAO, refining product definitions and operational rules. It is part of the iterative regulation cycle by which Coljuegos has matured the online regime since its 2016 launch.
Requirements
Track every Acuerdo update applicable to JOSAO and apply the consolidated text
Document version history of internal procedures against each Acuerdo amendment
Brief commercial teams on product-rule changes within ten business days of publication
Re-test affected systems before re-launching changed products
Acuerdo Coljuegos 04/2019
Expansion of authorised novel games
Game Design
Acuerdo 04 of 2019 expanded the catalogue of authorised novel games operable by internet, including additional modalities such as virtual sports. The expansion responded to operator requests and to the consolidation of the online market after the first three years of JOSAO.
Requirements
Apply for product-specific authorisation before launching newly enabled modalities
Re-certify virtual-sports products with an accredited laboratory
Update player-facing terms and conditions to reflect the new product offer
Capture the broader product set in the AML risk assessment
Acuerdo Coljuegos 02/2020
Authorisation of novel games marketed via internet
Game Design
Acuerdo 02 of 2020 authorised the commercialisation of additional novel-game modalities through the internet channel and refined the conditions under which betting on real sporting and event outcomes can be offered. It also adjusted certain technical platform requirements.
Requirements
Treat product launches enabled by Acuerdo 02 of 2020 as requiring Coljuegos product clearance
Update technical certifications for any component touched by the Acuerdo
Adjust player-account flows where the Acuerdo introduces new product specificities
Refresh internal training within thirty days of any Acuerdo amendment
Acuerdo Coljuegos 05/2020
Operational adjustments during the COVID-19 period
Acuerdo 05 of 2020 introduced operational adjustments adopted during the COVID-19 emergency, including temporary measures around payment timing, contract performance and the introduction of additional online-only product variants in response to land-based closures.
Requirements
Treat the Acuerdo 05 measures as fixed legal precedents, not as expired emergency rules
Document each temporary measure that has since been folded into the standing regime
Brief finance teams on any payment-cadence adjustments that remain in force
Retain Acuerdo 05 in the compliance library for historical reference
Acuerdo Coljuegos 07 de 2024
Keno authorised as a new novel-games modality
Game Design
Acuerdo 07 de 2024 of the Coljuegos Board of Directors approves the regulation of Keno as a novel game of chance, expanding the catalogue of national-competence modalities beyond the prior set fixed in Acuerdo 08 of 2020 and Acuerdo 03 of 2021. The instrument defines the game mechanics, the operator obligations, and the rentistic transfer rates of between 15% and 17% of gross gaming income for derechos de explotación plus 1% for gastos de administración. The Acuerdo was subsequently amended by Acuerdo 03 de 2025.
Requirements
Operate Keno only under a concession contract awarded under the framework approved by Acuerdo 07 de 2024
Apply the 15 to 17 per cent exploitation-rights rate plus 1 per cent administration expense to all gross Keno revenues
Read Acuerdo 07 de 2024 jointly with Acuerdo 03 de 2025, which amends specific game-mechanic provisions
Block minors and self-excluded persons from Keno participation through both terminal and internet channels
Apply the responsible-gambling, KYC and SIPLAFT baselines defined for novel games to the Keno operation
Coljuegos estimated that Keno would transfer approximately COP 485 billion to the health system over five years; the regulation sits inside the broader novel-games taxonomy and does not displace the existing internet-operated games regime.
Acuerdo Coljuegos 09 de 2024
Super Astro novel-game regulation substituted
Game Design
Acuerdo 09 de 2024 of 25 October 2024 substitutes Title 3 of Acuerdo 08 of 16 September 2020 and restates the regulation of the Super Astro novel game of chance. The Acuerdo strengthens technological follow-up and control of the operation to secure the rentistic transfer to health, prohibits minors from betting whether by terminal or internet, and excludes persons registered in the Coljuegos self-exclusion regime from participating.
Requirements
Operate Super Astro only under the regulation as substituted by Acuerdo 09 de 2024
Implement age verification at every channel through which Super Astro bets are placed, including terminals and internet
Block participation by any player listed in the Coljuegos self-exclusion register
Maintain the technological controls required by the substituted Title 3 for revenue traceability
Apply the technical requirements annex issued under Resolución 20244000025304 for the Super Astro platform
The Acuerdo replaces the prior Super Astro regulation in its entirety; references to the 2020 Title 3 in older internal procedures must be retired.
Acuerdo Coljuegos 01 de 2024
Revancha minimum prize and Baloto subaccount adjustment
Game Design
Acuerdo 01 de 2024 of 8 February 2024 modifies paragraph 4 of article 2.5.2 of Acuerdo 03 of 2021, which had substituted Title 2 of Acuerdo 08 of 16 December 2020. The change fixes the minimum prize of the Revancha lottery at the value paid by the player for that lottery, set at COP 2,100, and was justified by the financial-sustainability analysis required to keep 50 per cent of Revancha gross income available for prizes.
Requirements
Pay the Revancha minimum prize at the value of the player's Revancha entry, no lower than COP 2,100
Maintain the 50 per cent gross-income-to-prizes ratio used as the financial basis for the modification
Read Acuerdo 01 de 2024 alongside the chain of amending acuerdos to the JOSAO Title 2
Update internal prize-table and payout-engine configuration to reflect the Revancha minimum
The instrument is narrow but binding on the operator of the Baloto and Revancha lottery; it sits inside the longer chain of Acuerdos 01/2022, 02/2023, 01/2024, 02/2024 and 02/2025 that progressively recalibrated the Baloto game.
Acuerdo Coljuegos 02 de 2025
Baloto and Revancha bet values, draws and minimum prize recalibrated
Game Design
Acuerdo 02 de 2025 of 8 May 2025 modifies Acuerdo 03 de 2021 and its successive amendments to update the Baloto and Revancha rule set. The Baloto bet value moves from COP 5,700 to COP 6,000 and the Revancha bet value from COP 2,100 to COP 3,000. The Operador Nacional de Juegos may add one additional weekly Baloto and Revancha draw on Mondays within two months of entry into force, and the minimum initial Baloto prize is raised from COP 1 billion to COP 2 billion.
Requirements
Charge the Baloto entry at COP 6,000 and the Revancha entry at COP 3,000 from the instrument's effective date
Introduce the additional Monday Baloto and Revancha draw within the two-month window granted by the Acuerdo
Guarantee a minimum initial Baloto prize of COP 2 billion for the first draw under the new regime
Adjust prize-table mathematics so the higher minimum is funded without crossing the rentistic-transfer floor
Update player-facing terms, jackpot communications and ticketing systems to reflect the new bet values
The Acuerdo is the latest link in the Baloto chain (Acuerdo 03/2021 as modified by 01/2022, 02/2023, 01/2024, 02/2024). Operators of resale and digital channels must propagate the new bet values across all consumer-facing surfaces on the effective date.
Acuerdo Coljuegos 03 de 2025
Keno regulation amended within first year of operation
Game Design
Acuerdo 03 de 2025 modifies Acuerdo 07 de 2024 which had established the Keno game regulation. The instrument refines game-mechanic and operational provisions before the first full year of Keno operation closed. The amending act was opened to industry observations between 25 April and 5 May 2025 before formal issuance.
Requirements
Operate Keno under the consolidated text of Acuerdo 07 de 2024 as modified by Acuerdo 03 de 2025
Update the responsible-gambling, KYC and reporting integrations to the amended Keno mechanics
Track any further amendments referenced in proyectos de acuerdo published on the Coljuegos consultation page
Retire references to the original-only Acuerdo 07 de 2024 in operator manuals
The amendment is operationally significant for the small set of Keno-authorised operators and should be read as part of the same regulatory unit as Acuerdo 07 de 2024.
Authorised operator catalogue and renewal 4
Coljuegos — authorised operators register
Public register of authorised JOSAO operators
Player Rights
As of May 2026 there are fifteen operators authorised to offer online betting in Colombia, the most recent being MrYoker (Global Vitxo S.A.S., contrato de concesión C2261 de 2026). The count has moved between fourteen and sixteen since 2024 as contracts have renewed and lapsed; the Coljuegos register at coljuegos.gov.co is the live source of truth.
Requirements
Check the Coljuegos register before integrating with any commercial partner
Display the authorised-operator badge on the player-facing website
Notify Coljuegos of any commercial-brand change in advance
Treat any operator absent from the register as illegal for advertising and partnership purposes
As of 2026 the public register lists 15 authorised JOSAO concessionaires: Aquila Global Group (Wplay), Corredor Empresarial (Betplay), Colbet (Betsson), E Total Gaming (Zamba), Codere Online Colombia (Codere), Luckia Colombia (Luckia), Sportium Apuestas Colombia (Sportium), Rush Street Interactive Colombia (Rushbet), Wonderbet, Teclino (Rivalo), Servicios Distrired (Megapuesta), Games and Betting (Yajuego), Grupo Vinnare (Fullreto), Bwin Latam (Bwin), and Stake Colombia (Stake). Operators must use a .co domain and display their concession contract number. The list at https://www.coljuegos.gov.co/publicaciones/301721 is the authoritative reference for legality checks.
Coljuegos — concession renewal procedure
Renewal of the five-year concession contract
Concession renewal requires a fresh application following the original procedure, including updated KYC, AML, technical-platform and capital evidence. Coljuegos publishes the renewal calendar; operators are expected to file at least six months before contract end to ensure continuity.
Requirements
File the renewal application at least six months before the current contract ends
Refresh every documentary element of the original application file
Issue a new performance guarantee covering the renewed term
Plan for a transition window in case Coljuegos requires clarifications
Coljuegos — contractual termination and handover
Termination and orderly contract liquidation
Player Rights
Articles 17 of the Ley 80 of 1993 framework apply to early termination of the concession contract for breach. On termination the operator must hand over the player database, return player balances and cooperate in the liquidation procedure. Performance guarantees remain in force until the contract is formally liquidated.
Requirements
Maintain a documented termination-and-handover playbook from contract signature
Return all player balances within the deadline Coljuegos sets at termination
Hand over the player database under the agreed migration protocol
Keep the performance guarantee live until the formal liquidation act is signed
Resolución Coljuegos 20241200017144/2024
Pre-filing review for localised-games licensing requests
Player Rights
Resolution 20241200017144 of 14 August 2024 partially modifies Resolution 20182300011754 of 2018, which fixed the procedure for authorising the operation of localised games of chance. From 16 August 2024, Coljuegos applies a documentary pre-review (preradicado) before assigning a formal filing number. The change responded to a year in which over half of the 489 localised-operator requests received were filed with incomplete documentation, which had been silently consuming statutory response windows.
Requirements
Submit the full evidentiary set required by Resolution 20182300011754 before requesting a radicado number
Treat the preradicado review as the operational gate for the statutory response clock
Correct any documentary gap flagged at preradicado before resubmitting
Track this resolution alongside the underlying 2018 procedure when relying on the localised-games licensing pathway
Do not rely on legacy filing dates that pre-date 16 August 2024 for new submissions
Coljuegos retains the procedural framework of the 2018 resolution; the 2024 amendment only adds the pre-filing review step and is operationally relevant to land-based licensing teams.
Garantías, pólizas y capital 1
Pólizas y garantías 2026 (consolidado)
Performance bonds and guarantee schedule 2026
Coljuegos requires JOSAO concessionaires to keep an active suite of financial guarantees in favour of the regulator and in favour of damaged third parties throughout the concession term. The instruments may be issued as fidelity insurance, bank guarantees or fiduciary trusts, by an institution authorised by the Superintendencia Financiera de Colombia. The dedicated reserve to back prize payments and refunds of unused participation credits cannot fall below COP 615,000,000.
Requirements
Maintain a performance guarantee (póliza de cumplimiento) in favour of Coljuegos for the full concession term plus the contractual liquidation period
Maintain a non-contractual civil-liability policy covering damage to third parties arising from the operation
Hold a dedicated reserve of at least COP 615,000,000 exclusively to back prize payments and refunds of unused participation credits
Use only insurers or financial institutions authorised by the Superintendencia Financiera de Colombia
Reissue or extend each guarantee before expiry to avoid an automatic contractual breach event
File evidence of every guarantee change with Coljuegos within the timeframe set in the concession contract
Treat the guarantee suite as one of the highest-priority compliance calendar items: a lapsed póliza de cumplimiento triggers contractual breach independent of any operational failure. The fidelity-bond, bank-guarantee and fiduciary-trust alternatives provide flexibility, but each requires Coljuegos approval of the form and amount. The COP 615 million minimum prize-payment reserve is a floor: high-volume operators must scale it to reasonably expected prize liabilities.
Acuerdos amenores y novedosos durante COVID-19 1
Acuerdo Coljuegos 04/2020
Acuerdo 04/2020: SUPER astro lottery commercialisation through authorised JOSAO platforms
Player Rights
Acuerdo 04 of 20 April 2020 adds article 9-1 to Acuerdo 8/2014 and numeral 3 to article 20 of Acuerdo 3/2019 to permit the SUPER astro lottery game to be sold through Coljuegos-authorised JOSAO platforms during and after the COVID-19 emergency. Sales through this channel must be name-bound to a registered JOSAO player account; tickets are nominative and emailed to the player; the bet location is the DANE municipality / department on the player's account; the central game system records every bet at the same granularity as terminal sales; ticket cancellation is prohibited (mandatory pre-confirmation step); promotions apply equally across all JOSAO platforms; exclusivity agreements are prohibited under Ley 256 of 1998; and the operator must launch on a minimum of two JOSAO platforms.
Requirements
Register every SUPER astro online bet in the Coljuegos Sistema Central del Juego with the DANE code of the player's registered municipality
Issue every ticket in the player's name and email it to the address on file
Implement a pre-confirmation step in lieu of cancellation
Launch on a minimum of two JOSAO-authorised platforms simultaneously
Apply promotions equally across all participating JOSAO platforms
Apply for joint authorisation (game operator plus platform operator) with the corresponding certification
Refrain from exclusivity agreements between game operator and platform operator (Ley 256/1998)
Recital data published in the act records the JOSAO modality at 13 percent of total sector sales as of April 2020, with 2,849,223 active accounts and 16 authorised operators. The act applies to concession contracts C1277/2015 (SUPER astro under Acuerdo 8/2014) and C1725/2019 (SUPER astro under Acuerdo 3/2019).
3
Theme 3
Player accounts, identity and national-ID linkage
Every JOSAO player must be a registered adult resident in Colombia, identified by cédula de ciudadanía, cédula de extranjería or passport. The player account is the unique gateway to play, deposit, withdraw and to receive any prize.
11 standards11 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Allowing play before completion of KYC verification
Failing to enforce the one-account-per-document rule
Routing winnings to an account not linked to the verified player
Player registration and KYC 5
Acuerdo Coljuegos 04/2016 art. 20
Player account as the unique participation gateway
Player Rights
Article 20 requires that every player participate exclusively through a personal user account registered on the operator's interactive channel. Anonymous play is prohibited; the account is the single record of all activity, balances and prizes for the registered user.
Requirements
Block any play that is not channelled through an authenticated user account
Forbid account sharing in the terms and conditions and detect it operationally
Tie every transaction (bet, deposit, withdrawal, prize) to a single registered account
Maintain account audit logs for at least five years
Acuerdo Coljuegos 04/2016 art. 21
Player age and residency requirements
RG CriticalPlayer Rights
Article 21 requires the player to be of legal age (eighteen years or older) and resident in Colombian territory. The address declared at registration must be located in Colombia, supporting both consumer-protection rules and Coljuegos's jurisdictional perimeter.
Requirements
Block registration where the declared age is below eighteen
Verify Colombian residency through documentary or address evidence
Geo-fence the platform to Colombian territory using technical controls
Re-verify residency where activity patterns suggest sustained foreign use
Acuerdo Coljuegos 04/2016 art. 22
KYC documentation requirements
RG CriticalPlayer Rights
Article 22 sets the KYC documentation: cédula de ciudadanía for Colombian nationals, cédula de extranjería for foreign residents, or passport. The operator must verify the authenticity of the document and the identity of the holder before allowing play.
Requirements
Capture and verify a clear image of both sides of the identity document at registration
Run automated document-authenticity checks before activating play
Refuse registration where the document does not match the declared identity
Retain KYC artefacts for at least five years after account closure
Most authorised operators complete identity verification within 48 working hours.
Coljuegos — single document per account rule
One verified document equals one account per operator
RG CriticalPlayer Rights
Coljuegos requires that a single identity document map to a single account per operator. The control prevents account multiplication for the purpose of abusing bonuses, evading deposit limits or breaching self-exclusion.
Requirements
Reject second-account creation where the identity document already maps to an existing account
Detect duplicate accounts proactively through device, e-mail and IP correlation
Close duplicate accounts and migrate balances to the original account
Document the de-duplication policy in the KYC manual
Coljuegos — biometric reinforcement
Biometric verification on high-risk events
RG CriticalPlayer Rights
Acoljuegos-authorised operators increasingly apply biometric reinforcement (liveness, facial-match) at registration or on high-risk events (large deposit, large withdrawal, password reset, prize claim). Biometric reinforcement supports both KYC integrity and self-exclusion enforcement.
Requirements
Apply liveness checks at registration where document quality is below threshold
Trigger biometric reverification on the first large withdrawal
Match facial biometrics to the document photo at high-risk events
Document the biometric vendor and the matching threshold in the KYC manual
Account lifecycle, closure and balances 3
Acuerdo Coljuegos 04/2016 — account dormancy
Dormancy treatment for inactive player accounts
Player Rights
Operators must define a dormancy threshold for inactive accounts and notify the player before applying any dormancy measure. Balances on dormant accounts remain payable to the player; they are not absorbed by the operator.
Requirements
Define and publish the dormancy threshold in the terms and conditions
Notify the player ahead of any dormancy reclassification
Hold dormant-account balances available for return to the player
The player may close the account at any time. On closure the operator must settle any outstanding balance to the registered withdrawal method and retain KYC and transaction records for the period required by AML and tax law.
Requirements
Honour closure requests within five business days unless a regulatory hold applies
Pay the outstanding balance to the verified withdrawal method on closure
Confirm closure to the player in writing
Retain KYC and transaction records for at least five years post-closure
Acuerdo Coljuegos 04/2016 — segregation of player funds
Segregation of player funds from operator working capital
RG CriticalPlayer Rights
Player funds must be held separately from the operator's working capital, in a bank account or instrument distinct from the operator's operational treasury. Segregation is essential to ensure player balances are recoverable in an insolvency scenario.
Requirements
Operate a dedicated bank account for player funds with no commingling
Reconcile player liabilities to segregated balances daily
Report any segregation breach to Coljuegos within twenty-four hours
Maintain an attestation by external auditor on segregation at year end
Prohibited bettor categories 3
Coljuegos — minors prohibition
Prohibition of play by persons under eighteen
RG CriticalPlayer Rights
Persons under eighteen years of age are prohibited from registering, depositing or playing on any JOSAO platform. Operators are responsible for preventing minor access and must demonstrate effective controls.
Requirements
Block any registration where the declared date of birth indicates a minor
Cross-check the date of birth with the identity document
Retain age-verification evidence per account
Investigate and close any account suspected of being operated by a minor
Coljuegos — self-excluded players
Prohibition of play during the self-exclusion period
RG CriticalPlayer Rights
Self-excluded players cannot register or play during the period of their self-exclusion. The prohibition is absolute for the duration declared by the player and operators must enforce it across the platform.
Requirements
Apply the self-exclusion block at the identity-document level, not only at the e-mail level
Refuse re-registration during the self-exclusion period
Refund any deposit accepted in breach of self-exclusion within two business days
Refer attempted breaches to the responsible-gambling team for investigation
Coljuegos — staff and related parties
Prohibition of play by operator staff and related parties
Player Rights
Operators must prohibit play on their own platform by employees, directors and related parties whose involvement could compromise the integrity of the game or the supervisory chain. The prohibition is typically enforced through the internal code of conduct.
Requirements
Maintain an internal register of prohibited persons and enforce it at registration
Block accounts where ownership or employment status changes to prohibited
Audit prohibited-bettor lists quarterly
Discipline breaches through the code of conduct
4
Theme 4
Responsible gambling
Coljuegos requires every JOSAO operator to provide an active responsible-gambling toolkit: deposit and loss limits, session limits, reality checks, problem-gambling messaging and the Toma el Control programme. Limits are immediate to reduce, delayed to increase.
13 standards13 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Treating responsible gambling as a static disclaimer rather than an active toolkit
Letting players raise limits without the cooling-off period
Failing to detect markers of harm in session and spending data
Deposit, loss and time limits 5
Coljuegos — daily, weekly and monthly deposit limits
Player-set deposit limits with asymmetric application
RG CriticalPlayer Rights
Operators must offer the player the ability to set daily, weekly and monthly deposit limits at registration and at any time thereafter. A reduction takes effect immediately; an increase only takes effect after a seventy-two-hour cooling-off period and a second confirmation by the player.
Requirements
Surface the deposit-limit tool at registration before the first deposit
Apply any reduction immediately on player confirmation
Apply any increase only after a seventy-two-hour delay and second confirmation
Audit limit changes monthly for anomalies
Coljuegos — session-time limit
Player-set session-duration limit
RG CriticalPlayer Rights
Operators must allow the player to set a maximum session duration. Once the limit is reached the platform must end the session and prevent further play until a defined cooling period elapses.
Requirements
Offer the session-time tool with the deposit-limit tool
End the session automatically when the limit is reached
Prevent immediate re-login that would defeat the limit
Log session-limit triggers for RG analytics
Coljuegos — loss limit
Player-set net-loss limit
RG CriticalPlayer Rights
The responsible-gambling toolkit includes a player-set loss limit applied over a defined period (typically day, week, month). Once the limit is reached the platform must block further wagering for the remainder of the period.
Requirements
Surface the loss-limit option in the same flow as the deposit limit
Apply reductions immediately and increases with a delay
Block further wagering when the loss limit is reached
Capture loss-limit utilisation in the player-risk model
Coljuegos — wager (apuesta) limit
Player-set wager-amount limit
RG CriticalPlayer Rights
Operators must also offer a wager-amount limit, defined as the total amount the player may wager in a given period. The wager limit is independent of deposit and loss limits and supports players who wish to bound exposure even when funds remain available.
Requirements
Offer the wager-limit tool alongside deposit and loss limits
Apply the wager limit at bet placement, not only at session end
Reset the counter at the start of each period
Log wager-limit triggers in the RG audit trail
Coljuegos — reality-check notifications
Periodic time and spend notifications during play
RG CriticalPlayer Rights
The platform must display reality-check notifications to the player at defined intervals during a session, summarising elapsed time and net position. The player can adjust the cadence of reality checks within ranges defined by the operator.
Requirements
Display the first reality check no later than one hour into a session
Show elapsed time and net win or loss in the notification
Allow the player to adjust the cadence within published ranges
Log reality-check displays for supervisory review
Markers of harm and customer interaction 8
Coljuegos — markers-of-harm detection
Operator detection of problem-gambling markers
RG CriticalPlayer Rights
Operators must monitor for markers of harm in player behaviour, including escalation of deposits, loss-chasing patterns, session length above thresholds, late-night activity spikes and complaints. Detected markers must trigger a graduated interaction with the player.
Requirements
Maintain a written set of markers-of-harm thresholds and update annually
Trigger an interaction with the player when a marker is detected
Document interactions, outcomes and any limit changes that follow
Report aggregate marker-of-harm data to Coljuegos on request
Coljuegos — interaction protocol
Graduated customer-interaction protocol
RG CriticalPlayer Rights
The interaction protocol defines a graduated response to markers of harm: informational message, dedicated agent contact, signposting to support resources and, where necessary, application of operator-initiated limits or referral to self-exclusion. Each step must be documented in the player record.
Requirements
Define a graduated protocol with at least three escalation levels
Document the trigger, action and outcome of every interaction
Train customer-facing staff on the protocol annually
Audit a sample of interactions every quarter
Coljuegos — problem-gambling resources
Signposting to recognised support resources
RG CriticalPlayer Rights
The platform must signpost players to recognised problem-gambling support resources, including the Toma el Control programme that Coljuegos promotes and external clinical resources where available.
Requirements
Display the Toma el Control reference on every page of the responsible-gambling area
Provide contact details for at least one external support resource
Refresh the resource list at least annually
Track click-through on signposted resources
Coljuegos — RG training for staff
Annual responsible-gambling staff training
RG Critical
Operators must train customer-facing and risk-team staff on responsible-gambling principles and the operator's interaction protocol. Training must be refreshed at least annually and captured in personnel records.
Requirements
Deliver an initial RG training to all customer-facing staff
Refresh training at least once per calendar year
Capture training records in HR or compliance files
Test understanding with a short post-training assessment
Resolución Coljuegos 20244000022654/2024
Consolidated responsible-gambling guidelines for all authorised modalities
RG CriticalPlayer Rights
Resolution 20244000022654 of 16 October 2024 repeals Resolution 20214000036784 of 2021 and all resolutions modifying it, and consolidates the responsible-gambling regime applied to managers and operators of authorised games of chance. Scope covers localised games, novel games, internet-operated novel games and national raffles. Operators must lodge their responsible-gambling programme in PDF in the first fifteen business days of January 2025, approved by the legal representative, and must adopt the risk-factor identification test created by Coljuegos as the single official screening tool. Self-exclusion is defined as a player-initiated alternative through which the player removes themselves from the possibility of placing bets or buying credits, and operators must operate the channel and keep the self-exclusion register.
Requirements
Adopt the Coljuegos risk-factor identification test as the only official screening tool and surface it on every player-facing channel
Submit the responsible-gambling programme in PDF, signed by the legal representative, in the first fifteen business days of January 2025 and at any contract renewal thereafter
Operate a self-exclusion channel and keep the player register that records every exclusion event
Apply the consolidated regime across localised, novel, internet-operated novel and national-raffle modalities; do not rely on the repealed 2021 baseline
Implement adjustments to the responsible-gambling programme by 31 December 2024 for internet-operated novel-game operators with live contracts
Report annually to Coljuegos on the results obtained from the implemented responsible-gambling measures
The resolution is the new responsible-gambling spine for the Colombian market and supersedes the chain of 2021, 2022 and 2024 prior resolutions. The Coljuegos risk-factor test must be live before the deadline; legacy in-house screening tools no longer satisfy the rule.
Resolución Coljuegos 20244000007624/2024
First extension of the 2021 responsible-gambling implementation deadline
RG Critical
Resolution 20244000007624 of 16 April 2024 modified Resolution 20214000036784 of 2021 to extend the implementation deadline for the responsible-gambling regime to 1 August 2024. It was published in Diario Oficial 52.730 of 17 April 2024 and was later repealed by article 14 of Resolution 20244000022654 of 16 October 2024 alongside the rest of the 2021 chain.
Requirements
Treat Resolution 20244000007624 as superseded by Resolution 20244000022654 of 16 October 2024
Do not rely on the 1 August 2024 deadline for any current obligation; apply the January 2025 deadline fixed by the 2024 consolidated resolution
Keep the historical reference when reviewing compliance evidence produced between April and August 2024
The instrument has historical relevance only; it documents the interim deadline that bridged the 2021 baseline and the consolidated 2024 framework.
Resolución Coljuegos 20244000016054/2024
Second extension of the 2021 responsible-gambling implementation deadline
RG Critical
Resolution 20244000016054 of 2024, published in Diario Oficial 52.836 of 2 August 2024, extended once more the implementation deadlines of Resolution 20214000036784 of 2021 as previously modified by Resolution 20224000032324 of 2022. It was repealed by article 14 of Resolution 20244000022654 of 16 October 2024.
Requirements
Treat Resolution 20244000016054 as superseded by Resolution 20244000022654 of 16 October 2024
Apply the consolidated 2024 regime rather than any deadline set by this resolution
Retain the historical reference for compliance evidence produced between August and October 2024
Like its April 2024 predecessor, this resolution is no longer operative and is included for chain-of-amendment traceability.
Resolución Coljuegos 20244000018094/2024
Third extension of the 2021 responsible-gambling implementation deadline
RG Critical
Resolution 20244000018094 of 2024 once again extended the timelines of Resolution 20214000036784 of 2021 as modified by Resolution 20224000032324 of 2022. The instrument was issued during the period in which Coljuegos was preparing the consolidated 2024 framework and was repealed when Resolution 20244000022654 of 16 October 2024 entered into force.
Requirements
Treat Resolution 20244000018094 as superseded by Resolution 20244000022654 of 16 October 2024
Apply the consolidated 2024 regime rather than any deadline set by this resolution
Retain the historical reference for the September to October 2024 compliance window
Included for full traceability of the 2024 chain of deadline extensions on responsible gambling.
5
Theme 5
Self-exclusion register
Self-exclusion in Colombia is a player-initiated, irreversible bar on play for a chosen period. Operators must apply the bar at the document level (cédula, cédula de extranjería or passport) so the player cannot bypass it by opening a second account.
8 standards8 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Letting a self-excluded player re-register under a similar e-mail or device
Continuing to send commercial communications during self-exclusion
Reversing self-exclusion before the stated period has elapsed
Self-exclusion lifecycle 5
Coljuegos — self-exclusion right
Player right to self-exclude at any time
RG CriticalPlayer Rights
The player has the right to request self-exclusion at any time. The request is irreversible for the period chosen by the player and cannot be cancelled or shortened by either the player or the operator during that period.
Requirements
Offer the self-exclusion tool from the responsible-gambling area without friction
Make the bar irreversible for the period chosen by the player
Refuse any reversal request before the period elapses
Confirm the self-exclusion to the player in writing
Coljuegos — minimum and maximum self-exclusion periods
Defined periods for player-chosen self-exclusion
RG CriticalPlayer Rights
Operators must offer self-exclusion periods consistent with Coljuegos guidance, typically including short-term (for example 24 hours, 7 days, 30 days), medium-term (3 months, 6 months) and long-term (1 year and indefinite) options.
Requirements
Publish the available self-exclusion periods in the responsible-gambling area
Offer at least one option longer than six months
Default to the period the player selects without persuading otherwise
Re-prompt the player thirty days before any fixed-term self-exclusion ends
Coljuegos — block enforcement at document level
Block must apply to all accounts tied to the same document
RG CriticalPlayer Rights
The self-exclusion block must be applied at the identity-document level (cédula de ciudadanía, cédula de extranjería or passport) so that the player cannot open a second account on the same platform during the self-exclusion period.
Requirements
Index the self-exclusion register on the identity-document number
Reject any new registration tied to a document already on the register
Detect and close duplicate accounts opened in breach
Refund deposits made on a duplicate account within two business days
Coljuegos — refund of unplayed balances
Return of unplayed balances at self-exclusion
RG CriticalPlayer Rights
On self-exclusion the operator must return any unplayed balance to the player's verified withdrawal method. Bonus balances may be voided per the operator's published terms.
Requirements
Return cash balances within five business days of self-exclusion
Disclose the treatment of bonus balances clearly at sign-up and in the RG area
Confirm the refund to the player in writing
Hold balances pending where AML or judicial freezes apply
Coljuegos — suspension of marketing during self-exclusion
Bar on commercial communications to self-excluded players
RG CriticalPlayer RightsBonus & Ads
Operators must suspend all direct-marketing communications to the self-excluded player for the duration of the exclusion period. This includes e-mail, SMS, push and bonus offers.
Requirements
Suppress the self-excluded player from every direct-marketing list
Validate the suppression with a marketing-tech audit each quarter
Treat any breach as a high-severity RG incident
Resume communications only after the player re-opts in post-exclusion
Cooling-off, operator-initiated bars and reinstatement 3
Coljuegos — cooling-off period
Short voluntary break from play
RG CriticalPlayer Rights
Beyond self-exclusion, operators must offer a shorter cooling-off period (for example 24 hours or 72 hours) that blocks play without the irreversibility of self-exclusion. The cooling-off period supports players who want to step back without committing to a longer ban.
Requirements
Offer at least two cooling-off durations shorter than thirty days
Apply cooling-off immediately and prevent reversal during the period
Confirm cooling-off to the player in writing
Log cooling-off events for the RG analytics dataset
Coljuegos — operator-initiated bar
Operator-initiated bar where risk indicators justify it
RG CriticalPlayer Rights
Where risk indicators justify it, the operator may impose a bar on play even without a player request. Operator-initiated bars should be documented in the player record, communicated to the player and reviewed periodically.
Requirements
Document the trigger for any operator-initiated bar
Communicate the bar and reasons to the player promptly
Review operator-initiated bars at defined intervals
Treat the bar as equivalent to self-exclusion for enforcement purposes
Coljuegos — reinstatement after self-exclusion
Player-initiated reinstatement after the bar ends
RG CriticalPlayer Rights
Reinstatement after self-exclusion requires a positive player action; the account does not reactivate automatically. The operator should use the reinstatement moment to re-test RG limits and reaffirm the support resources available.
Requirements
Require a positive reinstatement request after self-exclusion ends
Re-prompt the player on RG limits at reinstatement
Refresh KYC if it has aged beyond the operator's policy
Document the reinstatement in the player record
6
Theme 6
Advertising, marketing and promotions
Coljuegos regulates JOSAO marketing through dedicated resoluciones (notably Resolución 20231000019054/2023, in force from 1 January 2024). Advertising must be honest, non-misleading, age-gated and accompanied by responsible-gambling messaging. Sponsorships, influencer marketing and bonus offers are tightly scoped.
13 standards13 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Targeting minors or self-excluded players in advertising
Running promotions without the mandatory responsible-gambling disclosure
Engaging influencers without verified-operator references
Advertising standards 5
Resolución Coljuegos 20231000019054/2023
Comprehensive advertising and sponsorship rules
Bonus & AdsPlayer Rights
Resolución 20231000019054 of 24 October 2023 (effective 1 January 2024) consolidates the advertising, sponsorship, promotion and commercial-communication regime for JOSAO operators. It caps annual advertising spend at the lower of 20 percent of BCIP (GGR minus 15 percent derechos de explotación minus 1 percent gastos de administración) or 11,000 SMMLV, requires every comm to carry the brand and the words "autorizado por Coljuegos", and prohibits cash-prize advertising, winner testimonials and ad placements in health centres or in school spaces that target minors. Non-compliance attracts a fine equal to 1.5 percent of the concession-contract value per breach; a third breach triggers unilateral termination of the concession.
Requirements
Treat Resolución 20231000019054 as the marketing baseline for every campaign
Map every commercial communication to a specific provision of the resolution
Refresh internal marketing-approval procedures to reflect the resolution
Brief external agencies and affiliates on the resolution before campaign launch
Operators must remit an annual investment plan to Coljuegos by 31 January each year, including the version of their risk-behaviour detection protocol and the count of risk-behaviour users detected in the prior year (art. 16 g). Credit-card recharges are restricted to single-instalment payments; third-party credit cards are expressly prohibited (art. 16 c-d). The 2023 instrument applied to the 16 JOSAO operators in force at issuance.
Coljuegos — truthful and non-misleading advertising
Advertising must be truthful and non-misleading
Bonus & AdsPlayer Rights
Advertising must accurately reflect the products and odds being marketed. Misleading promises of winnings, suggestions that gambling is a viable income source or claims of skill being sufficient to win are prohibited.
Requirements
Substantiate every factual claim in advertising before publication
Avoid any implication that gambling is a reliable income source
Disclose key terms (such as wagering requirements) clearly and prominently
Maintain a record of pre-clearance for every campaign
Coljuegos — minor-protection in advertising
Bar on advertising directed at minors
RG CriticalBonus & Ads
Advertising must not be directed at minors. Imagery, voice, music, placement and channel selection must avoid material attractive to under-eighteens, and the eighteen-plus restriction must be clearly stated.
Requirements
Exclude any imagery, voice or music with primary appeal to minors
Avoid placements with audiences predominantly under eighteen
Display a visible eighteen-plus warning on every creative
Document audience-composition analysis for each placement
Every commercial communication must include a responsible-gambling message warning of the risks of problem gambling and referencing the support resources available. The message must be visible, legible and not subordinated to commercial copy.
Requirements
Include the RG message in every creative regardless of channel
Use legible type sizes and contrast for the message
Reference at least one support resource (such as Toma el Control)
Audit creatives quarterly for compliance
Coljuegos — verified operator disclosure
Authorised-operator disclosure on every creative
Bonus & AdsPlayer Rights
Each commercial communication must identify the operator and disclose its Coljuegos authorisation, supporting consumer recognition of legal versus illegal offers.
Requirements
Display the Coljuegos authorisation reference on every creative
Use the operator's registered commercial brand consistently
Refresh creatives if the authorisation reference changes
Train agencies on the disclosure requirement
Sponsorships, influencers and affiliates 4
Coljuegos — sports sponsorship rules
Sponsorship of teams, leagues and athletes
Bonus & Ads
Operators may sponsor sports teams, leagues and athletes subject to the advertising standards. Sponsorships must not feature minors and must not exploit imagery that targets under-eighteen audiences.
Requirements
Apply the same advertising standards to sponsorship assets
Avoid placements on shirts or assets directed at junior teams
Include responsible-gambling messaging in sponsorship activations
Disclose sponsorship details in the operator's transparency reporting
Coljuegos — influencer marketing
Influencer endorsements and disclosure
Bonus & AdsAffiliate Rules
Influencer engagements must disclose the commercial relationship and must reference the operator's Coljuegos authorisation. Influencers cannot promote unauthorised operators or imply that gambling is a path to success.
Requirements
Require a written contract with every influencer engaged for paid promotion
Mandate disclosure of the commercial relationship in every post
Reference the Coljuegos authorisation in influencer content
Audit influencer activity weekly for breaches
Coljuegos — affiliate registration and conduct
Conduct rules for affiliate marketers
Affiliate RulesBonus & Ads
Affiliates promoting JOSAO operators must follow the same advertising standards as the operator and must not promote unauthorised operators to Colombian players. The operator is responsible for the conduct of its affiliates.
Requirements
Maintain a register of affiliates and their channels
Require contractual compliance with Coljuegos advertising rules
Audit affiliate creatives at least quarterly
Terminate affiliates who promote unauthorised operators
Coljuegos — illegal-affiliate enforcement
Sanctions against affiliates promoting illegal sites
Affiliate Rules
Coljuegos has opened sanctioning processes against affiliates and influencers promoting unauthorised operators, including raffles and promotional games operated through social media without authorisation. Operators must avoid any commercial relationship with affiliates that mix legal and illegal promotion.
Requirements
Screen affiliates for any presence on Coljuegos illegal-operator lists
Avoid commercial relationships with affiliates that mix legal and illegal offers
Cooperate with Coljuegos sanctioning processes when affiliates breach
Document the screening at affiliate onboarding
Bonuses and promotions 4
Coljuegos — bonus disclosure
Clear and prior disclosure of bonus terms
Bonus & AdsPlayer Rights
Bonus offers must disclose the principal terms clearly and prior to player acceptance: wagering requirement, eligible games, time limits, maximum conversion and any restrictions. Hidden or post-acceptance terms are not enforceable against the player.
Requirements
Publish the full bonus terms on the offer page before player acceptance
Summarise key terms (wagering, time limit, max conversion) above the fold
Honour the published terms even where the back-end record is different
Audit bonus pages quarterly for clarity
Coljuegos — bar on bonuses to self-excluded or RG-flagged players
No bonus offers to high-risk players
RG CriticalBonus & AdsPlayer Rights
Bonus offers must not be sent to self-excluded players or to players flagged for markers of harm. Bonus targeting lists must be filtered against the self-exclusion register and the RG-risk model.
Requirements
Filter every bonus list against the self-exclusion register
Exclude RG-flagged players from bonus targeting
Audit list-filtering controls in the marketing-tech stack quarterly
Treat any breach as a high-severity RG incident
Coljuegos — free-bet and welcome-offer governance
Welcome-offer and free-bet conditions
Bonus & AdsPlayer Rights
Welcome offers and free bets must be conditioned on KYC verification before any conversion to cash. Conversion ceilings, wagering requirements and time limits must be reasonable and clearly disclosed.
Requirements
Condition cash conversion on completed KYC
Cap conversion at a level disclosed in the bonus terms
Limit the validity window and disclose it before acceptance
Disable the offer if the player fails KYC
Coljuegos — promotional games rules
Promotional games (juegos promocionales) under Coljuegos rules
Bonus & Ads
Promotional games (sweepstakes and similar tied to product purchase) are a distinct Ley 643 category and require Coljuegos authorisation. Operators must not pass off a JOSAO bonus mechanic as a promotional game to escape the JOSAO regime.
Requirements
Distinguish bonus mechanics (inside JOSAO) from promotional games (separate authorisation)
Obtain a separate authorisation before launching a promotional game
Disclose the legal nature of the offer to participants
Maintain audit trails for both categories
7
Theme 7
Technical standards & platform integrity
Coljuegos sets the technical baseline for the JOSAO platform: certified RNG, secure data flows, encrypted transactions, audit logs, time-stamped events and a supervisory data feed to Coljuegos. Resolution 1785 of 2014 and subsequent resolutions detail the requirements.
12 standards12 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Running platform changes without re-certification
Breaking the supervisory data feed without immediate notification
Storing player data outside the agreed jurisdictional and security perimeter
Platform requirements 8
Resolución Coljuegos 1785/2014
Foundational technical requirements for JOSAO platforms
Game Design
Resolución 1785 of 2014 sets the foundational technical requirements for technical gambling systems operating under the JOSAO regime. It covers RNG quality, security of communications, integrity of transactions, audit logging and certification by accredited laboratories.
Requirements
Treat Resolución 1785 as the canonical technical baseline
Map every platform component to the relevant Resolución 1785 requirement
Re-certify components after material changes
Retain certification artefacts for the duration of the contract
Resolución Coljuegos 8304/2020
Lab-certification validity extension during COVID-19 emergency
Game Design
Resolución 8304 of 15 April 2020 is a narrow COVID-era measure. It extends the validity of existing lab-issued certifications over JOSAO game systems, platforms and integrations for the duration of the national sanitary-economic emergency plus six months, after which annual recertification resumes on the standard cadence. It also instructs Coljuegos staff to prioritise JOSAO game-type and game-addition authorisation requests while localised-games concession contracts remain suspended. Does NOT establish the technical-platform / RNG / RTP baseline; that lives in earlier technical resolutions and in Resolución 20224000026034/2022.
Requirements
Update technical documentation to reflect Resolución 8304
Re-certify components affected by the update
Refresh supervisory-feed configuration to current parameters
Brief the technical team on the updated guide
Used as a defensive precedent in 2020 by operators whose lab certifications would otherwise have lapsed during the GLI, BMM and eCogra travel restrictions imposed by COVID-19. Largely spent by late 2021 once certifiers resumed in-person audits.
Coljuegos — certified random-number generator
RNG with independent-laboratory certification
Game DesignPlayer Rights
All games whose outcome depends on a random-number generator must use an RNG certified by a Coljuegos-accredited laboratory. The certification must address statistical randomness, unpredictability, non-repeatability and resistance to reverse engineering.
Requirements
Certify the RNG with an accredited laboratory before launch
Re-certify after any algorithmic or seed-source change
Retain certification artefacts and test data for audit
Disclose RNG provider details to Coljuegos on request
Coljuegos — RTP disclosure and integrity
Player return percentage disclosure and floor
Game DesignPlayer Rights
Operators must disclose the return-to-player (RTP) of each game and maintain RTP at or above the certified percentage. For internet novel games operated by internet the exploitation-rights regime treats games with an RTP equal to or above eighty-three per cent on a particular fee track.
Requirements
Publish the RTP of each game in the help or rules area
Maintain RTP at or above the certified percentage over the long run
Apply the eighty-three-per-cent threshold where the exploitation regime depends on it
Investigate and document any sustained deviation
Coljuegos — supervisory data feed
Real-time or near-real-time supervisory data feed
Game DesignPlayer Rights
Operators must transmit a supervisory data feed to Coljuegos, containing the events that Coljuegos requires to oversee the operation. Loss of feed must be notified immediately and remediated quickly.
Requirements
Operate the supervisory feed at the cadence Coljuegos requires
Monitor feed health on a continuous basis
Notify Coljuegos of any feed interruption within the deadline set
Document each interruption and its remediation
Coljuegos — change-control on platform components
Change-control for any material platform change
Game Design
Material changes to the platform (game release, RNG change, security architecture, supervisory feed) must follow a change-control procedure including testing, certification where required and notification to Coljuegos.
Requirements
Maintain a documented change-control procedure with defined gates
Recertify components where the change touches a certified element
Notify Coljuegos in advance for changes that require it
Capture change-control artefacts for the duration of the contract
Coljuegos — audit logs and integrity
Comprehensive audit logging across the platform
Player RightsGame Design
The platform must capture audit logs across registration, deposits, bets, prizes, withdrawals and administrative actions. Logs must be tamper-evident, retained for the period required and made available to Coljuegos on request.
Requirements
Log every player and administrative event with a tamper-evident method
Retain logs for at least five years
Provide log access to Coljuegos on request within the agreed deadline
Audit log integrity at least annually
Resolución Coljuegos 20244000025304/2024
Super Astro technical-requirements annex
Game Design
Resolution 20244000025304 of 2024 issues the technical-requirements annex for the Super Astro novel game and repeals Resolution 20201000009494 of 17 June 2020. The annex sits beneath Acuerdo 09 de 2024 and fixes the platform, random-number generator, certification and operational-control parameters under which Super Astro may be operated. Drafts were opened to industry comment between 8 and 15 October 2024 and again between 26 October and 1 November 2024.
Requirements
Operate the Super Astro platform under the technical baseline fixed by the 2024 annex; the 2020 annex is repealed
Apply the random-number generator, certification and audit controls listed in the annex before going live
Document compliance against each section of the annex when filing technical-system updates with Coljuegos
Keep the annex synchronised with the substituted Title 3 approved by Acuerdo 09 de 2024
Retire any internal mappings that still cite Resolución 20201000009494 of 2020
The technical annex is the operational complement to Acuerdo 09 de 2024 and is binding on the Super Astro concessionaire and any accredited testing lab supporting the certification.
Information security and data protection 4
Coljuegos — encryption of communications
End-to-end encryption of player communications
Player RightsGame Design
The platform must encrypt communications between the player and the operator using current cryptographic standards. Certificates must be valid and renewed before expiry.
Requirements
Apply current transport-layer encryption standards across the platform
Renew certificates before expiry and document each renewal
Scan for weak ciphers at least quarterly
Block any non-encrypted endpoint accessible to players
Coljuegos — information-security management
ISO 27001-aligned information security
Player RightsGame Design
Coljuegos requires operators to operate an information-security management system aligned with international standards (notably ISO 27001). Annual reviews and remediation plans must be documented.
Requirements
Operate an ISMS aligned with ISO 27001 principles
Conduct an annual security review and document findings
Remediate high-risk findings within the documented SLA
Brief executive leadership on the ISMS status annually
Ley 1581/2012 — Habeas Data
Personal-data protection under the Habeas Data regime
Player Rights
Ley 1581 of 2012 is Colombia's personal-data protection law (Habeas Data). JOSAO operators are data controllers and must register with the Superintendencia de Industria y Comercio (SIC) and apply the lawful basis, transparency, security and rights principles.
Requirements
Register the data-processing activities with the SIC
Maintain a written data-processing policy and privacy notice
Honour player rights (access, rectification, deletion) within the legal deadlines
Apply security measures appropriate to the sensitivity of the data
Coljuegos — data localisation expectations
Player data within the agreed jurisdictional perimeter
Player Rights
Operators must keep player data within the jurisdictional and security perimeter disclosed in the platform documentation. International transfers must follow Habeas Data conditions and notify Coljuegos where required.
Requirements
Document the jurisdictional perimeter for player-data hosting
Apply Habeas Data conditions to any international transfer
Notify Coljuegos of material changes to the hosting topology
Retain transfer-impact assessments for audit
8
Theme 8
Game certification & accredited testing labs
Every game and every material platform component must be certified by a laboratory accredited by Coljuegos. The accredited-labs list is published on coljuegos.gov.co and includes the international testing houses (GLI, BMM, iTech Labs, eCogra and equivalents).
7 standards7 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Launching a game without a current accredited-laboratory certificate
Letting the certificate of a deployed component lapse without re-certification
Using a laboratory not on the Coljuegos-accredited list
Certification regime 7
Coljuegos — accredited-laboratory list
Coljuegos-accredited testing-lab register
Game DesignPlayer Rights
Coljuegos publishes a register of accredited testing laboratories on coljuegos.gov.co. Only laboratories on the register are recognised for the purposes of certifying components and games for the JOSAO regime.
Requirements
Use only laboratories on the current Coljuegos-accredited register
Verify the accreditation status before each certification engagement
Re-check the register before re-certification
Capture the accreditation reference in the certification record
The current Coljuegos-accredited laboratory roster published on the regulator's portal lists Gaming Laboratories International (GLI), BMM Test Labs, and the Slovenian Institute of Quality and Metrology (SIQ) as endorsed certification bodies for games of chance and luck systems. eCOGRA has also been authorised as an independent certification laboratory for the Colombian market. Operators must select a laboratory from the published list; certifications issued by non-listed bodies are not accepted by Coljuegos. The Coljuegos portal section is the authoritative source and must be checked before contracting a laboratory.
Coljuegos — platform certification
Initial certification of the technical platform
Game DesignPlayer Rights
Before commencing operations, the operator must submit the technical platform for certification by an accredited laboratory. The certification covers the platform architecture, security, integrity, audit logging and supervisory feed.
Requirements
Engage an accredited laboratory at the start of the certification process
Submit the full documentation set in Spanish
Address every laboratory finding before final certification
File the final certificate with Coljuegos before launching
Initial platform certification is issued by a Coljuegos-accredited laboratory before the operator can go live. The certification confirms compliance with the technical-requirements catalogue (currently anchored in Resolución 8304 of 2020 and the supplementary connection-system specification SCLM+ in Resolución 20241200014754 of 11 July 2024). The certification opinion, the laboratory's accreditation evidence, and the test report are filed with Coljuegos as part of the contract-execution dossier.
Coljuegos — game certification
Game-by-game certification
Game Design
Each game offered to Colombian players must be certified. Certification addresses game rules, RTP, RNG integration where applicable and any specific responsible-gambling features (such as autoplay restrictions or display of net position).
Requirements
Certify every game before launch in Colombia
Retain the game certificate and supporting data for the operating life of the game
Re-certify after any change to rules, RTP or RG features
Disclose the certification reference on the help or rules page
GLI-19 — Interactive Gaming Systems standard
International standard for interactive gaming systems
Game Design
GLI-19, Standards for Interactive Gaming Systems, is widely accepted across regulated jurisdictions and provides a common technical reference for interactive gaming systems. Coljuegos-accredited laboratories typically test JOSAO platforms against GLI-19 alongside Coljuegos-specific requirements.
Requirements
Align the platform with GLI-19 baseline expectations
Document the GLI-19 control map alongside Coljuegos-specific requirements
Re-test against the current GLI-19 revision after material changes
Brief the engineering team on GLI-19 changes annually
Coljuegos — re-certification triggers
Triggers for component or game re-certification
Game Design
Re-certification is required after material changes to certified components, including changes to the RNG, RTP, rules, security architecture or supervisory-feed integration. Re-certification must be completed before the changed component is exposed to players.
Requirements
Document the change-impact analysis for every material change
Pause exposure to players while re-certification is in progress
Capture the re-certification reference in the change-control record
Notify Coljuegos where the change triggers a notification duty
Coljuegos — laboratory independence
Independence of the testing laboratory
Game Design
The testing laboratory must be independent of the operator and of any related-party supplier whose component it is certifying. Documented conflicts of interest are grounds for rejecting a certification.
Requirements
Verify and document the laboratory's independence from the operator
Avoid related-party arrangements that compromise independence
Treat any conflict disclosure as a stop-the-line event
Engage a second laboratory where independence is in doubt
Coljuegos — surveillance audits
Periodic surveillance audits by laboratories
Game Design
Beyond initial certification, certified components may be subject to periodic surveillance audits by the laboratory or by Coljuegos directly. Surveillance audits verify ongoing compliance with the certified baseline.
Requirements
Plan for periodic surveillance audits in the operating budget
Maintain change logs to support surveillance audit findings
Remediate audit findings within the agreed timetable
Disclose surveillance results to Coljuegos on request
9
Theme 9
Payments and player-funds protection
JOSAO payments flow through PSE (Pagos Seguros en Línea), credit and debit cards, and the digital wallets Nequi and Daviplata. Withdrawals must return to a verified instrument; cash-out via informal channels is not permitted.
9 standards9 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Routing withdrawals to instruments not verified against the registered player
Allowing third-party deposits or withdrawals on behalf of the player
Failing to segregate player funds from operator working capital
Deposits and withdrawals 6
Coljuegos — PSE as the dominant deposit rail
Pagos Seguros en Línea (PSE) deposits
Player Rights
PSE is the dominant deposit channel for JOSAO operators. PSE supports near-instant deposits from any Colombian bank account, integrates with the major digital wallets and offers low-friction authorisation through the player's banking app.
Requirements
Offer PSE as the default deposit channel for Colombian players
Authenticate the deposit through the player's banking app
Reconcile PSE deposits to the player wallet in near real time
Investigate any PSE deposit that fails to settle within the bank SLA
Coljuegos — Nequi and Daviplata wallets
Digital-wallet deposits and withdrawals
Player Rights
Nequi (Bancolombia) and Daviplata (Davivienda) are widely supported digital wallets that act both as deposit instruments (typically via PSE) and withdrawal destinations. Wallet limits apply (Nequi imposes monthly transaction caps for standard accounts).
Requirements
Support Nequi and Daviplata for deposits and withdrawals where commercially viable
Disclose wallet caps and any operator-side limits to the player
Validate that the wallet is registered in the player's name before allowing withdrawal
Block withdrawals to wallets not linked to the verified player
Coljuegos — credit and debit card payments
Card payments under Coljuegos rules
Player Rights
Credit and debit card payments are accepted with caveats: the card must be in the player's name and 3D-Secure or equivalent authentication should be used. Operators must monitor for card-testing fraud and chargeback patterns.
Requirements
Require 3D-Secure or equivalent for card payments
Reject payments from cards not in the registered player's name
Monitor for card-testing patterns and block accordingly
Manage chargebacks within the card-scheme deadlines
Coljuegos — withdrawal to verified instrument only
Withdrawals only to a previously verified instrument
RG CriticalPlayer Rights
Withdrawals must be paid to an instrument previously verified against the registered player. Withdrawals to third parties, anonymous accounts or cryptocurrency wallets are not permitted.
Requirements
Restrict the withdrawal destination to verified instruments only
Refuse third-party withdrawal requests
Refresh instrument verification after long periods of inactivity
Log every withdrawal authorisation event
Coljuegos — withdrawal processing timetable
Reasonable withdrawal processing times
Player Rights
Operators must process withdrawal requests within a reasonable timetable, communicated to the player in advance. Withdrawal delays beyond the published timetable must be explained and documented.
Requirements
Publish the withdrawal-processing timetable in the help area
Process withdrawals within the published SLA absent a regulatory hold
Communicate any delay to the player promptly
Audit withdrawal-SLA performance monthly
Coljuegos — bar on cryptocurrency rails for payments
Cryptocurrency not accepted as a JOSAO payment instrument
Player Rights
Cryptocurrency rails are not recognised as JOSAO payment instruments. Deposits or withdrawals routed through crypto-to-fiat off-ramps must be screened and blocked.
Requirements
Reject deposits sourced from cryptocurrency rails
Block withdrawals to cryptocurrency wallets
Screen payment-processor flows for crypto-related risk
Refer suspicious crypto-related flows to the AML team
Player-funds protection 3
Coljuegos — segregated player-funds account
Segregation of player funds in dedicated accounts
RG CriticalPlayer Rights
Player funds must be held in a dedicated account, separate from the operator's working capital. The segregation supports recoverability of player balances in an insolvency scenario.
Requirements
Operate a dedicated bank account for player funds
Reconcile player liabilities to the segregated balance daily
Disclose the segregation arrangement to Coljuegos
Audit segregation at year end with the external auditor
Coljuegos — financial reserves
Minimum financial reserves to support liabilities
Player Rights
Operators must maintain financial reserves to support payment of prizes and player liabilities. Reserves must be evidenced in the audited financial statements and replenished promptly after any drawdown.
Requirements
Maintain reserves at or above the published floor at all times
Replenish reserves quickly after any drawdown
Evidence reserves in audited financial statements
Notify Coljuegos of any sustained reserve breach
Coljuegos — prize payment guarantees
Guaranteed payment of valid winning bets
Player Rights
Operators must pay all valid winning bets in line with the published game rules. Disputes over the validity of a bet must be handled through the operator's dispute-resolution channel and escalable to Coljuegos.
Requirements
Pay all valid winning bets without unjustified delay
Operate a documented dispute-resolution channel for bet disputes
Escalate unresolved disputes to Coljuegos as required
Log dispute outcomes for trend analysis
10
Theme 10
AML / SARLAFT / SIPLAFT
JOSAO operators are obliged parties under Colombia's AML regime. Resolución Coljuegos 20195100044514/2019 (and predecessors) implements SIPLAFT (now styled SARLAFT for the gambling sector) and UIAF resolutions govern suspicious-operation reporting.
11 standards9 player-flagged
82%
player-flagged
Regulatory risks this theme addresses
Failing to file ROS reports within the UIAF deadlines
Operating without a tested SIPLAFT or SARLAFT programme
Missing the no-suspicious-operation reporting cycle
AML programme and UIAF reporting 8
Resolución Coljuegos 20195100044514/2019
SIPLAFT / SARLAFT for gambling-sector concessionaires
Player Rights
Resolución 20195100044514 of 31 December 2019 establishes the requirements for the adoption and implementation of the Sistema de Prevención y Control del Lavado de Activos, la Financiación del Terrorismo y la Financiación de la Proliferación de Armas de Destrucción Masiva (LA/FT/FPADM) for gambling companies holding concession contracts with Coljuegos.
Requirements
Implement a SIPLAFT or SARLAFT programme aligned with Resolución 20195100044514
Appoint a compliance officer registered with UIAF
Conduct an annual AML risk assessment of the operation
Document the programme, training and testing in an annual review
The SIPLAFT system must be documented in a manual approved by the board of the concessionaire and reviewed at least annually. A dedicated compliance officer (oficial de cumplimiento) must be designated, registered with Coljuegos within the deadline set by the resolution, and have direct reporting line to the board. The officer cannot hold operational responsibilities that create a conflict of interest. The manual must cover customer-risk segmentation, transaction monitoring rules, escalation thresholds, training programme, and the UIAF SIREL reporting procedure.
Resolución Coljuegos 260/2013
Earlier SIPLAFT instrument (historical)
Resolución 260 of 2013 was the earlier SIPLAFT instrument, requiring implementation of the prevention-and-control system across the gambling sector by 30 June 2013. It remains relevant as the historical baseline that Resolución 20195100044514 of 2019 modernised.
Requirements
Treat Resolución 260 of 2013 as the historical baseline for the SIPLAFT programme
Retain historical SIPLAFT documentation for audit continuity
Apply the current Resolución 20195100044514 going forward
Brief the AML team on the regulatory evolution
UIAF — suspicious-operation reporting (ROS)
Reporting suspicious operations to the UIAF
Player Rights
Obliged operators must report suspicious operations to the Unidad de Información y Análisis Financiero (UIAF). A suspicious operation is one whose number, amount or characteristics does not fit normal sector practice and cannot be reasonably justified.
Requirements
Document the criteria used to qualify a suspicious operation
File the ROS through the UIAF system without delay
Retain ROS evidence and supporting analysis for at least five years
Train customer-facing and risk-team staff to spot ROS indicators
Reportes de Operación Sospechosa are filed to UIAF via SIREL immediately upon detection. There is no batching or monthly window: the moment the compliance officer concludes the operation meets the criterio de sospecha, the report must be transmitted. Internal documentation supporting the decision must be retained for at least five years and made available to UIAF and Coljuegos on request. ROS filing is confidential and the operator must not tip off the customer.
UIAF — no-suspicious-operation report
Negative ROS filing within ten calendar days
Player Rights
Where no suspicious operations were detected in the preceding month, the obliged operator must report this fact to the UIAF within the first ten calendar days of the following month. The negative-report duty is independent of the positive-ROS duty.
Requirements
Calendar the negative ROS filing for the first ten days of each month
Document the analysis that supports the negative report
Track the cumulative ROS and negative-ROS history
Brief senior management on AML metrics quarterly
The negative ROS report (reporte de ausencia de ROS) is filed monthly within the first ten calendar days of the month following the reporting month, via SIREL, even when no individual ROS was lodged during the period. Failure to file the negative confirms a SIPLAFT control breach.
UIAF — large-transaction reports
Reporting of transactions above defined thresholds
Player Rights
Beyond ROS, obliged operators must report transactions above the thresholds set by UIAF (historically gambling operations above COP 5 million and prizes above COP 5 million). Thresholds are periodically updated by UIAF resolution.
Requirements
Configure the AML system to flag transactions above the current UIAF threshold
File the large-transaction report within the UIAF deadline
Update thresholds whenever UIAF revises them
Reconcile filings to the AML transaction-monitoring log
Cash and cash-equivalent transactions are reported to UIAF through SIREL: RTI individual for movements equal to or above COP 5,000,000 per person, and RTI múltiple for cumulative monthly movements equal to or above COP 15,000,000 per person. Prize-winner reports follow a parallel logic: individual reporting at COP 5,000,000 per prize and cumulative at COP 8,000,000 per month per person. All filings are due within the first ten calendar days of the month following accrual. Negative reports are mandatory when no qualifying transaction occurred.
UIAF — terrorism-financing risk
Specific controls against terrorism financing
Player Rights
The SIPLAFT regime covers both money laundering and the financing of terrorism (LA/FT). Operators must apply specific controls to detect terrorism-financing risk, including sanctions-list screening and politically exposed persons (PEP) due diligence.
Requirements
Screen players against the relevant sanctions lists at registration and periodically
Apply enhanced due diligence to PEPs
Re-screen on material change to the sanctions environment
Document the screening methodology in the SIPLAFT manual
UIAF — proliferation-financing risk
Controls against proliferation financing (FPADM)
Player Rights
The SIPLAFT regime also covers the financing of the proliferation of weapons of mass destruction (FPADM). Controls broadly mirror the LA/FT controls but require attention to UNSC and other proliferation lists.
Requirements
Include FPADM-specific sources in the sanctions-screening configuration
Brief the AML team on FPADM typologies
Document the FPADM control set in the SIPLAFT manual
Update the configuration after UN Security Council list changes
UIAF SIREL calendar 2026
UIAF SIREL reporting calendar and thresholds 2026
JOSAO concessionaires file all UIAF reports through the SIREL platform. Monthly reports (RTI individual, RTI múltiple, prize-winner individual, prize-winner cumulative, and the three negative reports) are due within the first ten calendar days of the month following accrual. Suspicious-operation reports (ROS) are event-driven and transmitted immediately on detection, not batched into the monthly cycle.
Requirements
File RTI individual for any cash or cash-equivalent transaction equal to or above COP 5,000,000 per person
File RTI múltiple for cumulative monthly cash flows equal to or above COP 15,000,000 per person
File individual prize-winner report for prizes equal to or above COP 5,000,000
File cumulative prize-winner report for monthly prizes equal to or above COP 8,000,000 per person
File the corresponding negative report when no qualifying transaction or prize occurred in the reporting month
Transmit ROS immediately upon detection through SIREL, with confidential treatment and no tipping-off
File negative ROS each month within the first ten calendar days even when no individual ROS was lodged
Retain supporting documentation for at least five years and make it available to UIAF and Coljuegos on request
Build the SIREL calendar into the compliance officer's recurring calendar with a hard cut-off on day eight of each month, leaving two calendar days of contingency before the day-ten statutory deadline. Treat negative reports as mandatory positives: missing a negative ROS or negative RTI is itself a SIPLAFT control breach. ROS workflow must support twenty-four-hour escalation paths because the resolution and UIAF circulars expect immediate filing on detection.
KYC, EDD and risk-based controls 3
Coljuegos — risk-based KYC
Risk-based KYC across the relationship
Player Rights
KYC is risk-based across the relationship, with enhanced due diligence (EDD) applied to higher-risk players (PEPs, sanctions-list adjacents, unusual flows). KYC is not a one-time event; periodic refresh is required.
Requirements
Apply EDD to players flagged as higher risk
Refresh KYC periodically across the player base
Capture the rationale for any EDD application
Audit a sample of EDD files quarterly
Coljuegos — source-of-funds checks
Source-of-funds verification on high-value flows
RG CriticalPlayer Rights
Operators must verify the source of funds where flows exceed defined thresholds or where risk indicators suggest abnormality. Source-of-funds evidence may include bank statements, payslips or other documentary support.
Requirements
Apply source-of-funds verification on flows above the published threshold
Accept only documentary evidence consistent with AML good practice
Refuse continued play where source-of-funds evidence cannot be obtained
Document each source-of-funds review
Coljuegos — UBO and ownership transparency
Ultimate beneficial owner transparency
Player Rights
Operators must keep ultimate beneficial owner records up to date and disclose them to Coljuegos on request. Ownership changes that affect control or beneficial-ownership composition must be notified.
Requirements
Maintain a current UBO register at the corporate level
Notify Coljuegos of material changes to UBO composition
Re-test suitability when ownership changes
Disclose UBO records to Coljuegos and UIAF on request
11
Theme 11
Taxation & fiscal contributions
JOSAO operators contribute through three main channels: derechos de explotación (exploitation rights) at fifteen per cent of GGR on the standard track, gastos de administración (administrative expenses) at one per cent, and the ordinary tax obligations (corporate income tax, VAT and withholding on prizes) managed by the DIAN.
10 standards5 player-flagged
50%
player-flagged
Regulatory risks this theme addresses
Mis-calculating derechos de explotación for games above the RTP threshold
Failing to withhold the twenty-per-cent ganancia ocasional on prize payouts above the UVT threshold
Treating the regime as a corporate-tax-only regime and ignoring the rentistic transfers
Rentistic transfers 5
Ley 643/2001 art. 8 — derechos de explotación
Exploitation rights as the core rentistic contribution
Player Rights
Article 8 of Ley 643 sets exploitation rights (derechos de explotación) as the percentage of gross income from each game payable to the monopoly. For internet-operated novel games with RTP equal to or above eighty-three per cent, the rate is a minimum of fifteen per cent on gross income less prizes paid (the GGR base).
Requirements
Calculate derechos de explotación on GGR (gross income less prizes paid)
Apply the fifteen-per-cent rate to JOSAO operations meeting the RTP threshold
File and pay derechos within the Coljuegos calendar
Reconcile the filing to the supervisory data feed
For JOSAO operations the derechos de explotación are calculated at 15 percent of gross gambling revenue (ingresos brutos menos premios pagados). Liquidation is monthly. The declaration and payment fall within the first ten business days of the month following accrual, filed through the Coljuegos Operator Portal using the form approved by the Consejo Nacional de Juegos de Suerte y Azar. The printed receipt is the binding declaration of the concessionaire for all purposes. Late payment triggers default interest and may trigger the póliza de cumplimiento. Payment-plan facilities are available for up to six monthly instalments through acuerdosdepago@coljuegos.gov.co.
Ley 643/2001 art. 9 — gastos de administración
Administrative expenses on top of exploitation rights
Article 9 sets administrative expenses (gastos de administración) as an additional one per cent of the GGR base. The combined fifteen-plus-one model is the distinctive Colombian rentistic-transfer architecture.
Requirements
Add the one-per-cent gastos de administración to the derechos de explotación filing
File and pay within the Coljuegos calendar
Reconcile to the supervisory feed
Document the basis used in the monthly filing
The administrative-expenses contribution is liquidated alongside the derechos de explotación on the same monthly form, at one percent of the same gross-gambling-revenue base. Same deadline (first ten business days of the next month), same channel (Operator Portal), same enforcement consequences if missed.
Coljuegos — payment plan mechanism
Payment-plan facility for rentistic obligations
Coljuegos has issued resoluciones permitting payment-plan facilities (acuerdos de pago) for rentistic obligations under defined conditions, including financial-distress scenarios. Plans must be formally approved and serviced.
Requirements
Apply for a payment plan only through the formal Coljuegos procedure
Provide the financial evidence Coljuegos requires
Service the plan strictly to avoid contractual default
Disclose any payment-plan status in management reporting
The payment-plan facility (acuerdo de pago) is available for derechos de explotación and gastos de administración liabilities. The application is filed by the legal representative or attorney-in-fact via acuerdosdepago@coljuegos.gov.co. The plan cannot exceed six monthly instalments. The printed liquidation receipt for the underlying obligation must accompany the request. Default on an acuerdo de pago accelerates the full balance and may trigger the póliza de cumplimiento.
Coljuegos — health-system destination of revenue
Constitutional destination of net rentistic income
Player Rights
Net rentistic income is constitutionally earmarked for the SGSSS public health system. Coljuegos transfers proceeds to ADRES and, depending on the modality, to departmental health funds. The transfers are visible in Coljuegos transparency reporting.
Requirements
Treat rentistic transfers as constitutionally earmarked health funding
Cooperate with ADRES and Coljuegos transfer-related queries
Disclose the destination of transferred proceeds in stakeholder communications where appropriate
Retain transfer evidence for audit
UVT y SMLMV 2026 (claves operativas)
UVT and SMLMV reference values 2026
Two annually-recalibrated benchmarks drive most of the COP-denominated thresholds in the Coljuegos compliance suite. The UVT (Unidad de Valor Tributario) for 2026 is COP 52,374, fixed by DIAN Resolution 000238 of 15 December 2025 with a 5.18 percent increase over the 2025 value. The SMLMV for 2026 is COP 1,750,905, fixed by Decrees 1469 and 1470 of 29 December 2025 and ratified by Decree 0159 of 19 February 2026 after a Consejo de Estado interim suspension. The transport allowance is COP 249,095.
Requirements
Recompute every UVT-anchored threshold each year using the new DIAN value (for 2026: COP 52,374 per UVT)
Recompute every SMLMV-anchored threshold each year using the new minimum-wage decree (for 2026: COP 1,750,905 per SMLMV)
Apply the 48 UVT ganancias-ocasionales withholding floor at COP 2,513,952 in 2026
Update internal compliance manuals, calculator spreadsheets, and SARLAFT system parameters with the new 2026 values before the first reporting cycle of the year
Document the source instrument (DIAN Resolution 000238/2025 and Decree 0159/2026) in the compliance manual to evidence annual recalibration
Coljuegos rules are dense with UVT and SMLMV references because both indices update automatically every January, sparing the regulator from amending instruments to keep up with inflation. The operational risk is local: any spreadsheet, parameter table, or BI dashboard hard-coding 2025 values produces a stale threshold that may under-withhold tax, under-report SIPLAFT operations or miscompute minimum-capital adequacy. Treat the annual UVT and SMLMV update as a fixed compliance calendar event for January.
Article 317 of the Estatuto Tributario taxes occasional income from lotteries, raffles, bets and similar at twenty per cent. The DIAN treats operator-paid prizes as occasional income for the player.
Requirements
Apply the twenty-per-cent ganancia ocasional treatment to prize payouts
Issue tax certificates to players where required
Reconcile prize-tax data to DIAN filings
Brief tax counsel on any DIAN interpretive guidance
Twenty-per-cent ganancias ocasionales tax applies on prizes from lotteries, raffles, bets and the like. For 2026 the operator withholds at source when the individual prize equals or exceeds 48 UVT, which is COP 2,513,952 (UVT 2026 = COP 52,374 per DIAN Resolution 000238 of 15 December 2025). Withholding is reported and paid to DIAN monthly through the standard withholding-agent return. The operator must issue the certificado de retención to the player.
Estatuto Tributario — withholding at source on prizes
Withholding at source on prizes above forty-eight UVT
Player Rights
Withholding at source on prize payments to players is twenty per cent of the payment, applied where the individual prize exceeds forty-eight UVT (COP 2,513,952 for 2026, calculated as 48 × COP 52,374; UVT fixed by Resolución DIAN 000238 del 15 de diciembre de 2025).
Requirements
Configure the payment system to withhold twenty per cent on prizes above the UVT threshold
Recalibrate the threshold each year as UVT changes
Remit withheld amounts to the DIAN within the legal deadline
Provide players with a record of withheld amounts for their tax return
For the 2026 tax year the 48-UVT threshold equals COP 2,513,952. Update payment-system withholding rules each January as DIAN publishes the new UVT resolution (typically in the second half of December for the following year).
DIAN — VAT (IVA) on internet games
Nineteen-per-cent VAT regime on internet-operated games
Indirect taxation on internet-operated games of chance is in flux as of mid-2026. The 19% IVA regime extended by Decreto 1474 of 2025 is currently UNENFORCEABLE: on 9 April 2026 the Constitutional Court declared Decreto 1390 of 2025 (the underlying economic-emergency declaration) unconstitutional, suspending the effects of Decreto 1474 pending a final ruling. In parallel, a separate 16% impuesto nacional al consumo on GGR (total bets less prizes paid, bimonthly base) was created by Decreto 0240 del 12 de marzo de 2026 (added as numeral 4 al art. 512-1 del Estatuto Tributario for 2026 only) and remains in force. Operators should configure for the 16% INC on GGR and treat the 19% IVA as suspended pending the Court's final review.
Requirements
Apply the nineteen-per-cent VAT regime where the DIAN treats the activity as VATable
File and remit VAT through the DIAN system
Reconcile VAT filings to internal commercial reporting
Track DIAN interpretive guidance and reforma tributaria changes
IVA on internet-operated games of chance is 19 percent, applied to the value of the bet or participation. The operator is the responsable de IVA, filing the IVA return on the cycle assigned by DIAN (bimensual or cuatrimestral depending on prior-year gross income). The IVA base and the derechos-de-explotación base differ: IVA applies on bet value, derechos de explotación on gross gambling revenue (bets minus prizes paid).
DIAN — corporate income tax
Corporate income tax on JOSAO operator profits
JOSAO operators pay corporate income tax on profits under the general Estatuto Tributario regime. The corporate-tax burden is separate from rentistic transfers and from the player-side ganancia ocasional.
Requirements
File and pay corporate income tax under the general Estatuto Tributario regime
Reconcile commercial and tax accounts at year end
Apply transfer-pricing rules to intra-group cross-border flows
Disclose tax positions in audited financial statements
Corporate income tax (impuesto sobre la renta) applies at the general rate of 35 percent on the operator's taxable profit, calculated under the Estatuto Tributario after IVA, derechos de explotación and gastos de administración have been recognised. Annual return is filed on the corporate calendar published by DIAN each year (vencimientos por último dígito de NIT).
Decreto 0175 de 2025
19 per cent VAT on online games of chance under conmoción interior
Player Rights
Decreto 0175 of 14 February 2025, issued by the Presidency under the conmoción interior declared for the Catatumbo region, temporarily suspends the exception that had kept online games of chance outside the scope of value-added tax under article 420 of the Estatuto Tributario. Online games of chance operated exclusively by internet, whether from inside Colombia or from abroad, are subject to 19 per cent IVA between 22 February 2025 and 31 December 2025. The tax is collected on the deposit made by the player, so a COP 100,000 deposit yields approximately COP 84,033 of playable balance after the IVA is deducted. For foreign-domiciled operators the tax accrues when the player is fiscally resident, domiciled or has their economic seat in Colombia. The collected resources are earmarked for the conmoción interior response.
Requirements
Charge 19 per cent IVA on every deposit made by a player resident in Colombia between 22 February and 31 December 2025
Apply the tax irrespective of whether the operator is licensed in Colombia or providing services from abroad
Disclose to the player the IVA deduction at the deposit moment and the resulting playable balance
Remit the collected IVA to the DIAN under the rules of the Estatuto Tributario as activated by Decreto 0175
Build the calculation as deposit divided by 1.19, not as a surcharge on top of the deposit
Track parallel decrees (e.g. Decreto 1474 de 2025) that may extend, modify or replace the IVA regime
The decree is the most consequential 2025 fiscal change for the Colombian online-gambling market. It is temporary by its own terms but has triggered constitutional and operational litigation; compliance teams must monitor the conmoción-interior measures suite for extensions and the position of the Procuraduría and DIAN doctrine.
12
Theme 12
Supervision, sanctions & illegal-site enforcement
Coljuegos supervises JOSAO holders through inspections, the supervisory data feed and sanctions procedures. It also runs the illegal-site URL-blocking programme jointly with MinTIC, and refers criminal conduct to the Fiscalía under arts. 312 and 313 of the Código Penal.
25 standards24 player-flagged
96%
player-flagged
Regulatory risks this theme addresses
Operating in Colombia without an active Coljuegos concession
Treating URL-blocking as a temporary nuisance rather than a permanent perimeter
Mis-managing a sanctioning process by failing to respond within the procedural deadlines
Inspection and sanctions 11
Coljuegos — inspection and supervisory powers
Inspections, requests for information and on-site audits
Player Rights
Coljuegos has powers to inspect operators, request information and conduct on-site audits across the JOSAO regime. Operators must facilitate access and respond to requests for information within the deadlines set.
Requirements
Maintain documentation accessible for Coljuegos inspections at all times
Respond to requests for information within the legal deadline
Treat any obstruction of inspection as a high-severity compliance breach
Capture inspection findings in the corrective-action log
Coljuegos — administrative sanctioning procedure
Due process in administrative sanctions
Player Rights
Sanctioning procedures follow the administrative due-process rules of the Código de Procedimiento Administrativo y de lo Contencioso Administrativo (Ley 1437 of 2011 / CPACA). Operators have rights of defence, evidence-presentation and appeal.
Requirements
Respond formally to any pliego de cargos (charging brief) within the legal deadline
Present evidence and arguments under the CPACA procedure
Exhaust internal administrative appeals before judicial review
Document the procedural history of every sanctioning process
Ley 1393 of 2010 supports a sanctions ladder for unauthorised gambling operation. For internet games, Coljuegos can impose sanctions of up to three hundred SMMLV per establishment, point of sale or vendor, on top of asset seizure and forfeiture proceedings.
Requirements
Recognise unauthorised internet operation as exposed to fines of up to 300 SMMLV per channel
Anticipate forfeiture proceedings against assets used in illegal operation
Cooperate with seizure orders affecting illegal equipment
Disclose sanction risks in due-diligence packs
Coljuegos — sanctions against influencers and affiliates
Sanctioning processes against illegal-promotion intermediaries
Affiliate Rules
Coljuegos has opened sanctioning processes against influencers, affiliates and companies operating raffles and promotional games illegally through social media. Intermediaries cannot rely on absence of a direct operating contract to escape responsibility.
Requirements
Screen affiliates and influencers against the Coljuegos sanctions records
Avoid commercial relationships with sanctioned intermediaries
Cooperate with Coljuegos sanctioning queries on intermediaries
Treat intermediary breaches as direct operator risk
Multa de COP 7,188 million for 11 establishments operating 101 unauthorised METs and 15 online-betting modules
Player Rights
On 25 March 2019 Coljuegos, working with the Policía Nacional, executed simultaneous operativos in Aracataca (Magdalena), Itagüí (Antioquia) and Cartagena (Bolívar). The intervention seized 101 unauthorised máquinas electrónicas tragamonedas (METs) and 15 online-betting modules across 11 commercial establishments (5 in Aracataca, 6 in Itagüí, 3 in Cartagena). Coljuegos announced administrative fines totalling COP 7,188 million against the establishment owners, applied under art. 44 of Ley 643 of 2001 as modified by art. 20 of Ley 1393 of 2010 (80 SMMLV per unauthorised machine). The seized equipment was destined for destruction and the owners were exposed to a five-year inhabilidad to operate juegos de suerte y azar. The case remains the largest publicly announced multi-site MET-and-online-module operativo of the 2019-2024 period.
Requirements
Treat operation of any MET or internet-betting module outside an active Coljuegos concession as exposed to a per-machine fine of 80 SMMLV under art. 44 Ley 643/2001 modificada por art. 20 Ley 1393/2010
Anticipate parallel decomiso and destrucción of the equipment used in unauthorised operation
Brief commercial counterparties that hosting unauthorised METs in their premises exposes them to the same sanctioning ladder
Capture the per-machine 80 SMMLV exposure in the enterprise risk register
This precedent fixes the working multiplier for multi-site illegal-MET operativos at 80 SMMLV per machine and demonstrates that Coljuegos pursues the establishment owners, not only the machine operator. Operators acquiring portfolios should walk every site before close.
Precedente — Marsbet / Atlético Bucaramanga sponsorship declared illegal
Coljuegos declaration of illegal sponsorship: Marsbet on Atlético Bucaramanga shirt (2023)
Bonus & Ads
On 27 September 2023 Coljuegos publicly declared illegal the sponsorship of Atlético Bucaramanga by the English betting brand Marsbet, on the basis that Marsbet held no Coljuegos concession or authorisation. Coljuegos had first sent a formal oficio to Dimayor on 14 August 2023 requesting review of the shirt advertising to avoid alertas, bloqueos o sanciones, and reiterated the oficio on 2 October 2023. Marsbet did not appear in the JOSAO authorised-operator list of 16 holders current at the date of the comunicado. The case is the first documented Coljuegos enforcement against shirt sponsorship by an unauthorised offshore brand in Colombian professional football and was used to justify subsequent URL-blocking and Dimayor-side compliance instructions.
Requirements
Confirm any sports-sponsorship counterparty appears in the current Coljuegos authorised-operator list before signing or activating the deal
Treat shirt or perimeter sponsorship by an unauthorised brand as a publicidad breach exposed to URL-blocking and sanctioning processes
Brief clubs, leagues and federations on the Coljuegos position that absence of a direct contract does not shield intermediaries
Build the authorised-operator check into the sponsorship-onboarding workflow
This precedent extends Coljuegos enforcement perimeter from the operator itself to the receiving club and the league administrator. After Marsbet, sport-property sales teams cannot treat offshore-operator approaches as commercially safe.
Precedente — Consejo de Estado anula sanción Coljuegos por caducidad CPACA
Consejo de Estado annuls Coljuegos sanction over breach of three-year CPACA caducidad limit
Player Rights
On 13 February 2025 a Colombian administrative court annulled a sanction imposed by Coljuegos on a localised-games operator over differences in derechos de explotación. The court held that Coljuegos had exceeded the three-year caducidad limit of art. 52 of the CPACA (Ley 1437 of 2011) for the initiation of sanctioning action, ordered the return of the sums paid by the affected operator, and reaffirmed that the regulator cannot impose sanctions outside the legal inspection deadline. The precedent has been read by specialist counsel as opening the door for similar claims by operators previously sanctioned over historical derechos-de-explotación differences.
Requirements
Track the date of the alleged conduct and challenge any pliego de cargos served more than three years later under art. 52 CPACA
Preserve evidence of the date of the regulator's first formal knowledge to fix the caducidad clock
Where a sanction has already been paid on a stale claim, evaluate a recovery action in light of this precedent
Update the litigation playbook to reflect the three-year ceiling as a first-line defence
Operators should not assume that long delays by Coljuegos waive its sanctioning power; they enliven it. The three-year ceiling is the cleanest procedural defence available.
Precedente — Coljuegos sanción multiplier por declaración omisiva de derechos de explotación
Sanction multiplier for under-declaration (160%) and total omission (200%) of derechos de explotación
Player Rights
Coljuegos applies a sanction equivalent to 160% of the difference where a concessionaire omits or includes inaccurate information in its private declaration of derechos de explotación that produces a lower payment, and 200% of the value where the concessionaire omits the declaration and payment in full. This multiplier is the working enforcement standard for revenue-reporting breaches under the JOSAO regime and is reflected in Coljuegos communicados and operator-facing guidance.
Requirements
Reconcile GGR, derechos de explotación and gastos de administración to the cent before the monthly declaration
Treat any rounding or aggregation methodology as a control owned by the compliance officer, not by finance
Maintain audit trails sufficient to rebut any allegation of omisión or inexactitud
Provision for the 160% / 200% sanction in the breach-cost model used by management
These multipliers make revenue under-declaration the single most expensive administrative breach in the JOSAO regime per peso of underlying conduct.
Precedente — Operativo Bogotá 246 elementos COP 28,000 millones (Abr 2025)
Bogotá operativo: 246 illegal gaming elements seized, COP 28,000 million in annual health-system revenue recovered
Player Rights
On 3 April 2025 Coljuegos and the Policía Metropolitana de Bogotá executed a coordinated operativo across 12 establishments in the capital. The action seized 246 illegal gaming elements, including 57 internet-betting modules valued at approximately COP 100 million, and was characterised by Coljuegos as one of the largest illegal-gambling operativos ever conducted in Bogotá. The operativo was framed as recovering approximately COP 28,000 million per year in revenue that would otherwise have escaped the health-system transfer obligation. Cumulatively during the current administration, authorities had seized 5,291 illegal elements and destroyed 8,678 items representing more than COP 250 billion per year in foregone health-sector revenue.
Requirements
Treat the internet-betting module category as a priority target — module per-unit value at COP 1.75 million signals industrial supply chains
Recognise that operativos increasingly quantify the foregone health-sector contribution, exposing operators to political and reputational pressure beyond the fine
Walk every Bogotá site of a portfolio for evidence of internet-betting modules at acquisition due diligence
Brief management on the cumulative 5,291 / 8,678 / COP 250 billion baseline so the scale of the enforcement programme is internalised
Internet-betting modules are physically embedded in localised establishments and are now the principal driver of operativo seizures. Operators relying on third-party point-of-sale infrastructure should map every module to a legal source.
Bogotá operativo San Bernardo: 21 unauthorised tragamonedas seized and one capture (September 2023)
Player Rights
On 26 September 2023 Coljuegos, with the Fiscalía and the inspection sub-direction of Cundinamarca, executed an operativo at a single establishment in the San Bernardo neighbourhood of central Bogotá. 21 unauthorised máquinas tragamonedas were seized and one person was captured and turned over to the Fiscalía. The case is the cleanest small-footprint single-establishment precedent of the 2023 cycle and illustrates that even isolated venues with double-digit machine counts can trigger inter-agency capture.
Requirements
Treat any single establishment with more than a handful of unauthorised machines as exposed to inter-agency operativo with criminal capture
Brief on-site managers that operativo presence triggers immediate cooperation duties
Build the per-establishment machine-count threshold into the compliance monitoring of any localised-games portfolio
Anticipate Fiscalía presence — not only Coljuegos and Policía — in any operativo of this kind
The San Bernardo precedent confirms that even modest-scale unauthorised METs trigger Fiscalía capture. The threshold for criminal escalation is low.
Precedente — Valle del Cauca 66 capturas y 779,100 boletas rifa decomisadas 2023
Valle del Cauca 2023 cycle: 66 captures, 779,100 illegal raffle tickets and 67 unauthorised gambling elements seized
Player Rights
During calendar year 2023 the joint Coljuegos / Policía / departmental enforcement programme in Valle del Cauca produced 66 captures of persons operating illegal juegos de suerte y azar, the seizure of over 779,100 illegal rifa tickets and 67 unauthorised gambling elements. The figures were communicated in the inter-institutional ratification of the anti-illegal-gambling commitment between the Gobernación del Valle, the Alcaldía de Cali and Coljuegos. The Valle del Cauca cycle is the most fully quantified departmental enforcement baseline published by Coljuegos.
Requirements
Treat the rifa channel as an enforcement priority — the 779,100 ticket figure shows the scale of the unauthorised offer
Brief commercial counterparties in Valle del Cauca on the visible per-year capture rate
Build the rifa-counterparty screen into affiliate, sponsorship and CSR onboarding for any operation in Cali and surrounding municipalities
Anticipate continued joint Gobernación / Alcaldía / Coljuegos operativos in the region
The Valle del Cauca cycle shows that departmental-level political support meaningfully changes Coljuegos' operational footprint. Operators should expect similar quantified cycles in any department that adopts the inter-institutional ratification model.
URL-blocking and illegal-operator programme 8
Coljuegos — illegal-site URL-blocking programme
Blocking of illegal-gambling URLs through MinTIC and ISPs
Player Rights
Coljuegos publicly reported the issuance of 14,570 blocking orders against illegal online betting sites over the four-year window ending March 2024, and announced a further milestone of 10,000 illegal websites and social-media profiles blocked in the year to 3 February 2025 (Boletín 004 / 2025) — the highest annual figure in the entity's history. Brand-specific 2025 takedowns include 141 sites linked to 1Win, 242 to 1XBET, 19 to BBRBET and 3 to Pinnacle, plus 289 social-media profiles via Meta and the Centro Cibernético Policial.
Requirements
Monitor the Coljuegos illegal-site list and avoid any commercial overlap
Detect circumvention attempts (mirror sites, VPN-routed offers) and report them
Cooperate with MinTIC and ISP technical contacts on blocking measures
Brief management on the perimeter shift each quarter
URL-blocking is governed by MinTIC Circular Externa 0017 of 2025, which implements Decreto 0175 of 2025. Coljuegos uploads the list of URLs to a credentialed MinTIC platform on a weekly cadence. ISPs must consult the platform daily and execute the blocks identified, without case-by-case judicial order, under the framework of Ley 643 of 2001. The Coljuegos presidency has reported 8,500+ blocks since July 2024, approaching half of all blocks executed since the programme launched in 2017. Authorised operators should monitor the public list to confirm that their own brand-protection requests have been actioned.
Coljuegos — IP and domain enforcement against 1Win, 1XBET, Pinnacle and similar
Targeted blocking of major illegal brands
Player Rights
Coljuegos has intensified actions to block the URLs of major illegal brands such as 1Win, 1XBET and Pinnacle, including domain rotations and social-media profiles used to direct Colombian players to the unauthorised offer.
Requirements
Avoid any commercial overlap with brands listed by Coljuegos as illegal
Detect player-acquisition channels that originate from blocked brands
Report mirror domains observed in player-funnel analysis
Treat referrals from blocked brands as high-risk for AML purposes
MinTIC Circular Externa 017 de 2025
MinTIC URL-blocking procedure for unauthorised gambling sites
Player Rights
Circular Externa 017 of 23 April 2025, issued by MinTIC in coordination with Coljuegos and the National Police, defines the procedure for requesting, assigning, tracking credentials, uploading and blocking websites, applications and digital channels identified as exploiting, operating, selling, paying, advertising or marketing unauthorised games of chance. Coljuegos is the sole requesting authority. Internet service providers must consult the Coljuegos URL list daily and execute the blockages indicated. The Circular operationalises the URL-blocking pillar of Decreto 0175 de 2025.
Requirements
Recognise Coljuegos as the only competent authority that may transmit URL-blocking instructions under the Circular
Operate a daily check of the Coljuegos URL list and apply blockages within the timeframe set by the Circular
Keep audit logs of every URL blocked, the request reference and the implementation timestamp
Do not block any URL absent a formal Coljuegos requirement transmitted under the Circular
Coordinate complaints and unblock requests through the channel defined by MinTIC for legitimate sites incorrectly listed
The Circular is the live operational rulebook for the URL-blocking programme that has produced more than 26,600 blockage orders. Authorised operators should also track it because it provides the only legitimate channel to dispute an erroneous listing.
Under the Circular Externa 017 framework, Coljuegos publishes a weekly URL list on a digital platform from which internet service providers download the blocklist. By mid-2025 the cumulative number of issued blockage orders exceeded 26,600. Coljuegos has also formally requested Meta to block accounts of named Colombian influencers, including those publicly known as La Liendra, Epa Colombia and Yeferson Cossio, for promoting illegal betting platforms.
Requirements
Treat the Coljuegos weekly URL list as the authoritative source of unauthorised gambling sites in Colombia
Block listed URLs at the access layer and document the block within the audit window required by the Circular
Take down any affiliate creative or sponsorship promoting a listed operator and notify the affiliate of the takedown
Cooperate with Coljuegos and the Centro Cibernético Policial on social-media takedown requests targeting influencer accounts promoting illegal play
Avoid commercial relationships with any influencer the Coljuegos public register has flagged for unauthorised-gambling promotion
The blocklist programme is the most operationally visible enforcement vector in 2024-2025 and creates downstream obligations for licensed operators and affiliates, not only for ISPs and platforms.
Blocking of 409 portals associated with 1Win, 1XBET, BBRBET and Pinnacle (February 2025)
Player Rights
On 21 February 2025 Coljuegos announced the blocking of 409 portals associated with four offshore brands operating in Colombia without authorisation: 1Win (141 portals), 1XBET (242 portals), BBRBET (19 portals) and Pinnacle (3 portals). The action was executed jointly with the Ministerio de las TIC and the Policía Nacional. Coljuegos paired the blocking with an explicit consumer warning that players depositing on these brands risk losing their funds and personal data. The action is the most detailed brand-by-brand URL-blocking breakdown published by Coljuegos to date and consolidates 1XBET and 1Win as the priority targets of the illegal-site programme.
Requirements
Avoid any commercial relationship — affiliate, payment, technical or sponsorship — with 1Win, 1XBET, BBRBET or Pinnacle in Colombia
Treat referrals from these brands as high-risk for AML and account-onboarding purposes
Detect domain rotations of the four brands in player-funnel analysis and report them to Coljuegos
Brief the marketing team that media buys overlapping these brands carry derivative URL-blocking and sanctioning risk
The 1XBET-heavy distribution (242 of 409 portals) signals that the brand is being run through industrial-scale mirror-and-rotation tactics; operators should expect repeat enforcement waves rather than a single clean-up.
Precedente — 289 perfiles de Meta bloqueados por rifas y promoción ilegal (Dec 2024)
Coljuegos requests Meta to block 289 Facebook and Instagram profiles for illegal raffles and unauthorised betting promotion
Affiliate Rules
On 10 December 2024 Coljuegos publicly requested Meta to block 289 Facebook and Instagram profiles operating illegal rifas, bingos and promotional games, or promoting unauthorised betting houses. A further 35 administrative proceedings were already underway and 79 profiles were under investigation. The named accounts include high-reach Colombian influencer profiles (Lechoneitor, Epa Colombia, La Liendra, Yeferson Cossio, Motormanía Colombia, Javier Arias Stunt) and the 1XBET brand profile. Coljuegos cited art. 312 of the Código Penal and a penalty exposure of up to 100 SMMLV. Coljuegos estimates the illegal rifa channel removes approximately COP 70 billion per year from the health sector.
Requirements
Screen every paid-influencer counterparty against the public Coljuegos illegal-promotion enforcement records
Treat any mixed promotion (legal operator and illegal raffle from the same profile) as disqualifying for the affiliate programme
Document the screening at affiliate or influencer onboarding and on each material renewal
Brief the marketing team that art. 312 exposure attaches to the intermediary, not only to the operator
The Coljuegos position is that intermediaries cannot escape responsibility on the basis of absence of a direct operating contract. After this precedent, influencer due-diligence is non-negotiable.
Precedente — bloqueo cumulativo 10,000 sitios y 28,100 solicitudes 2025
Cumulative URL-blocking baseline: 10,000 sites in 2024 and 28,100 blocking requests by September 2025
Player Rights
Coljuegos has consolidated its illegal-site URL-blocking programme as the primary perimeter tool against offshore operators. By year-end 2024 the cumulative blocking exceeded 10,000 sites and social-media profiles, and by 30 September 2025 Coljuegos had requested blocking of 28,100 sites in 2025 alone, with a projected 3,000 additional requests still to come. Only 14 operators held legal authorisation for online gaming at the date of that figure. The programme is jointly executed with MinTIC and the Policía Nacional.
Requirements
Treat the 28,100 figure as the working scale of the unauthorised channel — perimeter monitoring must be industrialised, not manual
Maintain a mirror-domain detector that flags rotations of brands already on the Coljuegos block list
Integrate the Coljuegos block list into the AML transaction-monitoring rules to flag deposits and withdrawals routed through blocked brands
Brief management on quarterly perimeter shifts using the latest Coljuegos blocking-volume figures
Volume alone does not solve the perimeter problem: 1XBET-style brand rotation means new blocked URLs replace old ones at the same rate. Build the detection for what is being added next.
Precedente — Polymarket bloqueo apuestas electorales en cripto (Sep 2025)
Coljuegos requests blocking of Polymarket over crypto-denominated electoral betting ahead of 2026 elections
Game Design
On 30 September 2025 Coljuegos requested the blocking of Polymarket, a cryptocurrency-denominated prediction-market platform, on the basis that it operated electoral betting (including bets on Colombian presidential elections) without authorisation. Coljuegos applied its three-element gambling test — riesgo patrimonial, expectativa de premio y resultado dependiente de un evento incierto — to confirm that the platform fell within the monopoly perimeter. The action is the first publicly documented Coljuegos enforcement against a crypto-prediction-market platform and the first against electoral-event betting.
Requirements
Treat prediction-market platforms denominated in stablecoins or other crypto as in scope of the Coljuegos monopoly perimeter where the three-element test is met
Avoid any structural overlap (payments, liquidity, affiliate, white-label) with prediction-market platforms targeting Colombian players
Anticipate political-event betting as a Coljuegos enforcement priority around the 2026 presidential cycle
Document the three-element analysis for any borderline product before launch in Colombia
The crypto-denominated wrapper does not insulate the operator from the monopoly perimeter. Operators piloting prediction-market features for Colombia should obtain prior Coljuegos guidance.
Criminal enforcement 6
Código Penal art. 312
Illicit exercise of the rentistic-monopoly activity
Player Rights
Article 312 of the Código Penal punishes the illicit exercise of monopoly activity with imprisonment of six to eight years and a fine of five hundred to one thousand SMMLV. The penalty is increased by one third where committed by a contracted concessionaire and up to one half where committed by a public official.
Requirements
Treat any operation outside a Coljuegos concession as exposed to criminal liability under art. 312
Train senior management on the personal-liability dimension of art. 312
Capture art. 312 risk in the operator's enterprise risk register
Cooperate with Fiscalía enquiries through legal counsel
Código Penal art. 313
Evasion of monopoly rents
Player Rights
Article 313 punishes the concessionaire, legal representative, administrator or authorised entrepreneur that fails to transfer monopoly rents owed to health and education with imprisonment of five to ten years and a fine of up to 1,020,000 UVT. The same penalty applies to the failure to declare the income received.
Requirements
Pay derechos de explotación and gastos de administración in full and on time
Declare all gambling income to Coljuegos and the DIAN accurately
Treat any under-declaration as a high-severity compliance event
Document the calculation methodology used for each filing
Coljuegos — coordination with Fiscalía
Referral of criminal conduct to the Fiscalía General
Coljuegos coordinates with the Fiscalía General de la Nación to refer criminal conduct, including illegal operation under art. 312 and rent evasion under art. 313. The Fiscalía is the agency that pursues criminal proceedings.
Requirements
Maintain a documented Fiscalía-referral procedure
Cooperate with Fiscalía requests for information through legal counsel
Capture referral metrics in supervisory reporting
Disclose referrals affecting senior management to the board
Precedente — Coljuegos remite 366 casos a Fiscalía (Nov 2024)
Coljuegos transfers 366 illegal-operation cases to the Fiscalía General de la Nación (November 2024)
RG Critical
On 13 November 2024 Coljuegos announced the transfer of 366 cases to the Fiscalía General de la Nación for criminal investigation of natural and juridical persons for the unauthorised operation of juegos de suerte y azar. The package comprised 312 cases previously archived for more than three years that Coljuegos chose to unarchive and 57 new cases opened during the prior year. The investigated conduct included unauthorised operation of máquinas tragamonedas, internet-betting modules and other games without payment of derechos de explotación, with potential connected offences of lavado de activos, concierto para delinquir and enriquecimiento ilícito. The legal basis cited is art. 312 of the Código Penal.
Requirements
Recognise that historical archiving of a Coljuegos administrative file does not extinguish the criminal exposure under art. 312
Maintain documentary defences for at least the criminal-law prescription term, not the administrative one
Brief senior management on the personal criminal-liability dimension of unauthorised operation
Cooperate with Fiscalía enquiries through specialist criminal counsel
The unarchiving of 312 historical files signals a policy shift: dormant administrative files can be reactivated as criminal referrals. Operators with legacy exposure should not assume time has cured the risk.
Fiscalía 'Argenta' strategy seizes 22 properties used for illegal gambling in Cesar and Magdalena (January 2024)
Player Rights
In January 2024 the Fiscalía General de la Nación, under the Argenta strategy directed by then-Fiscal General Francisco Barbosa Delgado, seized 22 properties used for the illegal commercialisation of juegos de suerte y azar. The properties were located in Valledupar (Cesar), Ciénaga and Santa Marta (Magdalena) and were preliminarily valued at COP 2,000 million. The Argenta strategy is positioned as a financial-disruption tool against organised crime, narcotrafficking and illegal gambling, and the action is the largest documented single-strategy real-estate seizure tied to unauthorised juegos de suerte y azar in the 2020-2025 window.
Requirements
Anticipate extinción de dominio against any real estate used for the operation of unauthorised juegos de suerte y azar, in addition to administrative fines and criminal sanctions
Walk every site in a portfolio acquisition for evidence of historical illegal operation
Build the extinción de dominio risk into the due-diligence pack for any localised-games asset transaction in the Caribbean region
Cooperate with Fiscalía through specialist criminal counsel where a property is named
The Argenta strategy targets the asset, not only the operator. Real-estate counterparties hosting unauthorised METs are at material risk of seizure regardless of their formal lease arrangements.
Precedente — Fiscalía desmantela red Eje Cafetero y Valle del Cauca (Nov 2024)
Fiscalía dismantles illegal-gambling network with COP 10,000 million in revenue across Eje Cafetero and Valle del Cauca
RG Critical
In November 2024 the Fiscalía General de la Nación dismantled a criminal network that commercialised illegal juegos de suerte y azar in the Eje Cafetero and Valle del Cauca regions, generating revenue in excess of COP 10,000 million. 18 persons were captured in the operation, which also produced seizures of cash and forged documents. The case is one of the largest single-network captures publicly announced in the 2020-2025 window and ties unauthorised gambling operation to broader criminal-organisation activity.
Requirements
Treat regional concentration of unauthorised METs as a marker of organised-network activity, not isolated operators
Recognise that participation in a network operating illegal juegos exposes individuals to concierto para delinquir, not only art. 312
Cooperate with Fiscalía network-mapping enquiries where the operator's commercial counterparties overlap with the named investigation
Build the network-exposure scenario into the AML risk register
Operators with regional commercial relationships in Caldas, Risaralda, Quindío and Valle del Cauca should expect Fiscalía requests for counterparty information.
13
Theme 13
Integrity, sports betting & event manipulation
Sports betting carries its own integrity risks. Coljuegos cooperates with sports federations and international integrity bodies to detect and respond to suspicious betting patterns, match-fixing intelligence and event-manipulation indicators.
8 standards8 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Failing to detect or report suspicious-betting patterns to integrity bodies
Continuing to offer markets on events under integrity investigation
Allowing prohibited bettors (athletes, officials, insiders) to wager on related markets
Sports-integrity controls 4
Coljuegos — suspicious-betting reporting
Reporting of suspicious betting patterns
Player RightsGame Design
Operators must detect and report suspicious betting patterns to Coljuegos and to the relevant sports-integrity bodies. Suspicious patterns include unusual stake concentration, late-money movements and asymmetric odds movements.
Requirements
Operate a suspicious-betting-pattern detection capability
Report patterns to Coljuegos and to the relevant integrity body promptly
Suspend markets where integrity concerns are raised
Retain pattern-detection evidence for audit
Coljuegos — prohibited-bettor lists for sports
Bar on bets by athletes, officials and insiders
Player Rights
Athletes, officials and insiders with influence over the outcome of an event are prohibited from betting on related markets. Operators must operate the lists provided by sports federations and integrity bodies.
Requirements
Integrate athlete and official lists into the registration and bet-placement controls
Block bets by prohibited persons on related markets
Refresh the lists at the cadence the integrity body provides
Document refusals and escalations
Coljuegos — market-suspension procedures
Suspension of markets under integrity concern
Player RightsGame Design
Operators must have documented procedures to suspend markets when integrity concerns arise, including void-bet handling and player communications. Coordination with international monitors (such as IBIA, Sportradar) supports timely action.
Requirements
Maintain a documented market-suspension playbook
Void bets in line with published rules when integrity action requires it
Communicate suspensions to affected players within the published SLA
Capture suspension outcomes in supervisory reporting
Coljuegos — international integrity cooperation
Cooperation with international integrity organisations
Player Rights
Coljuegos and JOSAO operators cooperate with international integrity organisations (IBIA, Sportradar, INTERPOL where relevant). Cooperation supports cross-border detection and response to match-fixing networks.
Requirements
Maintain channels with at least one international integrity organisation
Share suspicious-pattern data through the channels available
Cooperate with cross-border investigations on request
Brief executive leadership on integrity-cooperation metrics
Player-facing complaint and dispute handling 4
Coljuegos — player-complaint channel
Operator complaint channel and SLA
Player Rights
Operators must provide a player-complaint channel reachable through the platform. Complaints must be acknowledged and resolved within the published SLA; unresolved complaints can be escalated to Coljuegos.
Requirements
Publish a clear complaint channel with multiple contact methods
Acknowledge complaints within the published SLA
Resolve or escalate within the published SLA
Retain complaint records for at least five years
Coljuegos — escalation to the regulator
Player escalation to Coljuegos
Player Rights
Where the operator complaint channel does not resolve the dispute, the player may escalate to Coljuegos. Coljuegos can request information from the operator and intermediate the resolution.
Requirements
Inform players of the right to escalate to Coljuegos
Respond to Coljuegos escalations within the legal deadline
Document the escalation outcome in the player record
Capture escalation metrics in supervisory reporting
Coljuegos — dispute-evidence preservation
Preservation of evidence pending dispute resolution
Player Rights
Operators must preserve evidence relating to disputed transactions, including game logs, session data and KYC artefacts, while the dispute is being resolved. Destruction of evidence during a live dispute is a serious breach.
Requirements
Apply a litigation-hold mechanism on disputed records
Preserve game logs and session data for the duration of the dispute
Document the evidence preserved in the dispute record
Audit the litigation-hold mechanism annually
Coljuegos — consumer-protection coordination
Coordination with SIC consumer-protection authority
Player Rights
The Superintendencia de Industria y Comercio (SIC) has consumer-protection competence and Habeas Data oversight. JOSAO operators may face complaints through the SIC alongside Coljuegos escalations.
Requirements
Track SIC complaints separately from Coljuegos escalations
Coordinate responses where the same matter is raised in both forums
Update internal procedures based on SIC rulings affecting the sector
Brief legal counsel on SIC trends quarterly
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