Ukraine's recent lottery license tender was somewhat unexpected yet reasonable — only the existing three old players submitted applications, with no new faces seen. This was confirmed by the newly established regulatory body PlayCity, stating that M.S.L., Ukrainian National Lottery (UNL), and PJSC Patriot all submitted their documents before the deadline. Essentially, this tender was to legalize the lottery businesses that had been operating without licenses for several years.
All existing operators submitted applications
According to the announcement by PlayCity, the only three domestic lottery operators participated in this license competition. PlayCity's head Hennadiy Novikov had previously dampened expectations, stating that due to strict existing regulations, it was unlikely to attract new companies. He explained that the current regulatory framework makes it difficult for new operators (including international companies) to meet the entry thresholds. Now, as predicted, the market structure seems unlikely to change for the time being.
Special policies for special times
The licenses issued this time are not the usual 10-year validity. Novikov said, the license period is linked to the martial law order, which can be extended for one more year after the end of martial law, but the total duration shall not exceed three years. This temporary measure is mainly to give the Ukrainian Ministry of Digital Transformation and the parliament time to revise lottery regulations and establish new rules. Perhaps in the future, when conditions are ripe, a larger-scale re-issuance could be organized. This is a temporary solution and also paves the way for long-term regulated development.
High application thresholds
To obtain this temporary license, the conditions are quite numerous, testing both operational and technical capabilities. Main requirements include:
Establishing independent branches in every city with a population over 500,000.
Having lottery sales points in all areas with a population over 5,000.
The total number of national sales points must not be less than 5,000.
Must have at least 5,000 electronic betting terminals and operate an electronic betting acceptance system.
Need to own a website with a .UA domain and prove at least three years of cumulative experience in organizing and operating national lotteries.
Industry urgently needs standardization
Novikov emphasized the significance of this tender, as the lottery operators have not paid license fees for over a decade. The licenses previously issued by the Ministry of Finance expired in 2013 and 2014, and since then, everyone has continued to operate without an updated framework. Starting from February 2025, the national gambling policy will be coordinated by the Ministry of Digital Transformation, followed by the establishment of PlayCity by the cabinet in March as the new central executive body, officially replacing the former Gambling and Lottery Regulatory Commission on April 1.
This tender is a key step in regulating Ukraine's lottery market and filling the regulatory void. For more information on global lottery licenses and regulatory trends, visit the PASA official website for in-depth analysis. Although the market is currently dominated by old players, this issuance is expected to end the long-term disorderly state and lay the foundation for a healthier, more transparent market in the future.
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