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Spain Upholds €750,000 Fine Over Influencer-Linked Car Raffle

Regulators said the promotion used sales of a €1 digital wallpaper to grant entries and therefore required prior gambling authorization.

Overview

  • The Ministry of Social Rights, Consumer Affairs and 2030 Agenda confirmed a €750,000 administrative fine against EBR Management SLU for running an unauthorized online raffle.
  • Spanish authorities concluded the promotion was a raffle subject to the Law of Regulation of Gambling after the Dirección General de Ordenación del Juego opened a sanctioning file under article 39.a).
  • The offer, run through EBR’s website, gave one entry per €1 digital wallpaper purchase and recorded 376,850 purchases for a luxury car that reporting links to influencer TheGrefg and a customized Tesla Model S Plaid.
  • EBR appealed arguing the activity was an advertising random combination rather than a raffle, but the Ministry rejected the appeal and denied requests to reduce the sanction.
  • The decision highlights growing regulatory scrutiny of influencer-led promotions and the legal risk of using low-cost digital sales to grant entry to prize draws that are open to Spanish IP addresses.