EBR Management SLU must pay €750000 after 376850 digital-wallpaper purchases opened access to a luxury-car draw without the authorization required under Spanish gaming law.
The raffle ran from 24 December 2024 to 6 January 2025 through EBR Management SLU's website. Spanish IP addresses could enter, while the promotion spread through the social-media accounts of the influencer who owned the car.
The vehicle’s owner was identified as David Cánovas Martínez, the Spanish YouTuber known as TheGrefg, who lives in Andorra.
The numbers explain why regulators took notice.
Participants bought a digital wallpaper rather than a conventional lottery ticket. Each €1 purchase also delivered one entry into the draw for a luxury vehicle. The owner said the car had cost €120000. It was a personalized Tesla Model S Plaid styled after the character Rayo McQueen, with reports putting its mileage at about 2500 kilometres. At the time of the raffle, authorities valued it at more than €75000.
EBR Management SLU recorded 376850 wallpaper purchases. Media reports estimate revenue at roughly €380000, putting the fine at about twice the amount generated by sales. That comparison does not alter the legal issue identified by the authorities: the draw required prior authorization, and the company never applied for it.
The Ministry of Social Rights, Consumer Affairs and Agenda 2030 classified the conduct as a very serious administrative infringement under article 39.a of the law regulating gambling. That provision covers gambling activity carried out without the required authorization.
EBR Management argued that the promotion was an advertising ‘random combination’ rather than a regulated lottery. The ministry rejected that interpretation because paying €1 for the digital wallpaper also created paid access to the chance of winning the car.
The regulatory process began before the final penalty. The Directorate General for the Regulation of Gambling opened sanction proceedings after concluding that the company's conduct could amount to a very serious breach. The final decision came from the Directorate General for Consumer Affairs, as reported in El País and other Spanish media.
EBR Management SLU challenged the penalty. The ministry rejected the appeal and refused to reduce the amount imposed.
The dispute turns on the link between the product and the prize. EBR Management sold a digital item for one euro, yet that payment also created access to a draw involving a high-value vehicle. Authorities therefore assessed the promotion under the rules governing games and raffles, rather than treating it solely as an ordinary online sale. La Razón described that economic connection as central to the ministry's decision.
The financial scale is clear from the reported figures. A total of 376850 purchases at €1 each produced transaction volume of that size, while the prize was valued at more than €75000. A separate earlier mortgage analysis dealt with household borrowing rather than raffles. This case likewise shows how a small individual payment can become significant across a large online operation.
A digital product labelled as a wallpaper does not remove gambling-law obligations when its purchase grants entry to a prize draw. For companies using influencers to promote expensive prizes through digital sales, the authorization requirement applies before the promotion begins. The €750000 decision followed the company's failure to seek that permission.
