App-store distribution is available for DGOJ-licensed operators. Ad-platform restrictions are shaped by RD 958/2020 (as partially annulled): social and search advertising to over-18s is now permitted following the 2024 Supreme Court ruling, but sponsorship and the broadcast time-window persist. Affiliates do not require a licence of their own and may only promote licensed operators, but they remain directly exposed to enforcement under RD 958/2020 in their own right rather than only through the operators they promote. Counsel confirms both limbs: no affiliate licence, and direct enforcement exposure.
Jurisdictions › Spain › Distribution and platforms
Spain · Question 09 of 11
Distribution and platforms: Can we ship through apps and platforms?
Mixed · Probable · Expert approved · In expert review scope · Back to full Spain report →
Key section parameters
| Jurisdiction | Spain (ES) |
|---|---|
| Regulator | DGOJ |
| Favourability | Mixed |
| Confidence | Probable |
| Review status | Expert approved · In expert review scope |
| Last collected | 18 Oct 2026 |
Summary answer
App-store distribution is available for DGOJ-licensed operators. Ad-platform restrictions are shaped by RD 958/2020 (as partially annulled): social and search advertising to over-18s is now permitted following the 2024 Supreme Court ruling, but sponsorship and the broadcast time-window persist. Affi…