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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.
Comprehensive coverage
162 Standards
666 Requirements
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5 Categories
Showing all 162 standards
1
Theme 1

Constitutional & monopoly framework

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 standards 4 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
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 standards 18 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
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.
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.
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.
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 standards 11 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
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 Critical Player 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 Critical Player 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 Critical Player 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 Critical Player 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
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
  • Report unclaimed balances per Coljuegos guidance
Acuerdo Coljuegos 04/2016 — voluntary account closure

Player right to close the account at any time

RG Critical Player Rights

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 Critical Player 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
Coljuegos — minors prohibition

Prohibition of play by persons under eighteen

RG Critical Player 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 Critical Player 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
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 standards 13 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
Coljuegos — daily, weekly and monthly deposit limits

Player-set deposit limits with asymmetric application

RG Critical Player 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 Critical Player 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 Critical Player 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 Critical Player 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 Critical Player 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
Coljuegos — markers-of-harm detection

Operator detection of problem-gambling markers

RG Critical Player 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 Critical Player 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 Critical Player 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 Critical Player 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 standards 8 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
Coljuegos — self-exclusion right

Player right to self-exclude at any time

RG Critical Player 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 Critical Player 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 Critical Player 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 Critical Player 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 Critical Player Rights Bonus & 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
Coljuegos — cooling-off period

Short voluntary break from play

RG Critical Player 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 Critical Player 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 Critical Player 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 standards 13 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
Resolución Coljuegos 20231000019054/2023

Comprehensive advertising and sponsorship rules

Bonus & Ads Player 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 & Ads Player 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 Critical Bonus & 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
Coljuegos — mandatory responsible-gambling message

Every campaign must carry an RG message

RG Critical Bonus & Ads Player Rights

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 & Ads Player 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
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 & Ads Affiliate 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 Rules Bonus & 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
Coljuegos — bonus disclosure

Clear and prior disclosure of bonus terms

Bonus & Ads Player 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 Critical Bonus & Ads Player 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 & Ads Player 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 standards 12 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
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 Design Player 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 Design Player 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 Design Player 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 Rights Game 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.
Coljuegos — encryption of communications

End-to-end encryption of player communications

Player Rights Game 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 Rights Game 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 standards 7 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
Coljuegos — accredited-laboratory list

Coljuegos-accredited testing-lab register

Game Design Player 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 Design Player 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 standards 9 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
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 Critical Player 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
Coljuegos — segregated player-funds account

Segregation of player funds in dedicated accounts

RG Critical Player 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 standards 9 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
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.
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 Critical Player 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 standards 5 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
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.
Estatuto Tributario art. 317 — ganancias ocasionales

Twenty-per-cent ganancias ocasionales on prizes

Player Rights

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 standards 24 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
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 1393/2010 — illegal-operation sanctions ladder

Sanctions for unauthorised gambling operation

Player Rights

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
Precedente — Coljuegos / Policía Nacional, 11 establecimientos (Aracataca, Itagüí, Cartagena)

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.
Precedente — Operativo Bogotá San Bernardo 21 tragamonedas captura (Sep 2023)

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.
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.
Coljuegos URL blocklist programme — 2024-2025 escalation

Coljuegos URL-blocking operational programme

Affiliate Rules Player Rights

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.
Precedente — 1Win, 1XBET, BBRBET, Pinnacle bloqueo de 409 portales (Feb 2025)

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.
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.
Precedente — Fiscalía estrategia Argenta incautación 22 bienes (Ene 2024)

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 standards 8 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
Coljuegos — suspicious-betting reporting

Reporting of suspicious betting patterns

Player Rights Game 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 Rights Game 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
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