UKRAINE REGULATION
process by allowing applicants to submit documents online without paper filings or personal visits to PlayCity. 7 This is a positive procedural reform, but its real value will depend on whether digitalization is accompanied by predictable review standards, consistent interpretation of licensing requirements and transparent publication of regulatory decisions. The most notable development for the market has been the presentation and partial rollout of the State Online Monitoring System. Under the law, this system is intended to ensure continuous interaction between the gambling operators and the regulator, including the collection and processing the data from the market. 8 According to official communications, PlayCity launched the system in test operation in April, 2026, while the Ministry of Digital Transformation described it as a tool that will support market transparency, automated data collection for taxation and reduced risks of manipulation or concealment of licensed operators’ activity. 9 The system appears ambitious. It is expected to process information on deposits, bets, winnings and payouts across licensed operators. Through a dedicated technical platform, data are to be transmitted from operators’ online systems to the state monitoring system for analysis and processing. The State Tax Service is also expected to receive access to relevant data for taxation purposes, including tax on winnings and gross gaming revenue calculations. 10
that regulatory oversight will focus on reported information rather than actual operator activity. This is particularly important because Ukraine still lacks comprehensive technical standards for the gambling sector. Without certification of the state system itself and of all operator online systems connected to it, expectations regarding the system’s effectiveness for regulatory, supervisory and tax-control purposes should be tempered. The ultimate test of the system will not be the fact of its launch, but whether it produces reliable, auditable and enforcement-ready data. A restart of the lottery market The past year has also been significant for the lottery market. For many years, Ukraine’s lottery market could not be fully formed because the necessary licensing conditions had not been approved. The Government subsequently adopted a framework for lottery licensing, and PlayCity issued the first lottery licences in more than a decade. According to PlayCity, three operators received licences and the state budget received more than UAH 72 million from the first lottery licensing process. 11 This is an important institutional restart. However, the primary legislation governing lotteries in Ukraine still requires substantial reform. PlayCity itself has described the current stage as transitional, noting that licence terms during martial law differ from the standard ten-year model and that further legislative amendments are being prepared to remove barriers and create conditions for a more competitive model. The lottery market therefore remains in a formative stage rather than a fully settled regulatory environment.
At the same time, the launch of the State Online Monitoring System should not be mistaken for the completion of Ukraine’s regulatory modernization. The core challenge is that any monitoring system can only be as reliable as the data it receives. Without independent certification, audit mechanisms and technical standards governing data generation, transmission and integrity, there remains a risk 7 Ministry of Digital Transformation, “Gambling business licences can be issued through Diia”, 24 December 2025. https://thedigital.gov.ua/ news/business/litsenziyi-dlia-hralnoho-biznesu-mozna-bude-oformyty-cherez-diiu 8 Cabinet of Ministers Resolution No. 171 “On approval of the Procedure for functioning of the State Online Monitoring System”, 16 February 2024. https://zakon.rada.gov.ua/go/171-2024-%D0%BF 9 Ministry of Digital Transformation, “Control of the gambling market 24/7: the Government made the final step toward launching the State Online Monitoring System”, 14 January 2026. https://thedigital.gov.ua/news/technologies/kontrol-hralnoho-rynku-247-uriad-zrobyv-ostan- niy-krok-do-zapusku-derzavnoyi-systemy-onlayn-monitorynhu-azartnykh-ihor 10 Ministry of Digital Transformation, “PlayCity launched DSOM in test operation”, 10 April 2026. https://thedigital.gov.ua/news/technologies/ playcity-zapustylo-dsom-u-testovu-ekspluatatsiiu-derzava-vpershe-otrymaye-dani-pro-rynok-azartnykh-ihor-u-realnomu-chasi 11 PlayCity, “The state budget received more than UAH 72 million from the first lottery licensing in 12 years”. https://playcity.gov.ua/news/derzh- biudzhet-otrymav-ponad-72-mln-vid-pershoho-za-12-rokiv-litsenzuvannia-operatoriv-loterei-msl-patriot-ta-unl-otrymaly-litsenzii
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IMGL MAGAZINE | JUNE 2026
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