An end to uncontrolled millions: how the Ministry of Digital Transformation is restarting the lottery market
17 November 2025 21:12
The new regulator under the coordination of the Ministry of Digital Transformation is preparing to issue licenses to lottery market operators according to updated requirements. This was reported by "Komersant Ukrainian" with reference to the article by Forbes Ukraine.
The goal of the initiative is clear: to take the sector out of the gray zone, make it transparent, competitive, and controlled by the state. The draft of the new license conditions has been discussed publicly since September 2025, has already passed the government committee and will soon be submitted to the Cabinet of Ministers.
Today, only three operators are formally authorized to conduct lotteries in Ukraine:
- MSL,
- “Ukrainian National Lottery, and
- “and Patriot.
At the same time, the current regulation – the Law “On State Lotteries ” of 2012 – is long outdated and does not provide real control levers, the Ministry of Digital Transformation notes. Since 2013, there have been no clear requirements for operators, rules, reporting control, player protection, or electronic systems. As a result, the market continues to operate under transitional provisions, operators have been working under minimal supervision for many years, and their distribution network is not monitored by the state, which creates risks of tax avoidance and abuse.
Key problems of the current regime:
- the license field is “loose” – the state checks only the operator itself, but not the network of distributors;
- there is no transparent accounting of turnover;
- there are almost no grounds for license revocation;
- lottery websites often contain elements close to gambling (slots, bets), although lotteries are not formally covered by the gambling law.
All this limits the entry of new market players, especially foreign ones.
The new licensing conditions are the first but important step. It is estimated that their implementation will bring approximately UAH 67.2 million to the budget annually from three operators, strengthen control over tax payments, and give the regulator tools to inspect, fine, and block practices that disguise casinos or betting services as lotteries. The Ministry of Digital Transformation proposes to introduce conditions for a transitional period – for the period of martial law plus one year, but not less than three years, with the law being finalized in parallel. The Ministry of Digital Transformation does not support the idea of issuing licenses for 10 years, as this would consolidate the monopoly, according to experts of the specialized ministry.
It will be possible to obtain a license only following an open tender held by the PlayCity public service. Participants can be Ukrainian and foreign legal entities subject to proper legalization of documents. A mandatory criterion is at least three years of lottery launch experience. Applicants are required to disclose the ownership structure, confirm the origin of capital, and submit transparent financial statements. The verification will take place through state registers and databases of tax and law enforcement agencies. Relationships with residents of the aggressor country, criminal convictions or active criminal cases for key persons will be grounds for non-admission to the competition.
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Technical requirements include the availability of an own electronic betting system, a “.ua” domain and, if available, a mobile application. The package of documents will be formalized by a Cabinet of Ministers resolution; applications can be submitted in person, by mail or electronically. All decisions on the issuance and revocation of licenses will be publicly available in the PlayCity registry.
The winners will be selected based on a point system: under normal conditions, a maximum of 70 points, during martial law – up to 50 (due to restrictions on the development of the distribution network). The experience, qualifications of the management, availability of a website and application, the size of the authorized capital, and other criteria will be evaluated. The minimum authorized capital is UAH 30 million. The annual license fee for an existing operator is calculated at 2,800 minimum wages, with a clear procedure and payment terms.
Control over the fulfillment of the conditions will be ensured by the obligation of operators to conduct all transactions through an electronic system, which gives the regulator access to real-time data on sales and payments. In addition to scheduled and unscheduled inspections, sanctions are envisaged: fines, suspension or revocation of the license.
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