UKRAINE
amid military aggression – the gambling market continued to function, paying licensing fees and taxes. It also went through the difficult process of removing operators linked to the aggressor state, as well as dealing with a number of major upheavals and scandals. From 2021 to 2025, the Commission issued 7,217 licenses, contributing nearly UAH 7 billion UAH (US$167 million) into the state budget. It’s also worth noting the increase in taxes paid by legal operators to the state during the period of military aggression. The Commission established and maintained the Register of Persons Restricted from Gambling Participation, which currently includes over 13,300 individuals. Efforts to combat illegal operators and their unlawful advertising were also initiated. Judged by these achievements, the first five years of the Gambling and Lottery Regulation Commission’s work can be considered a success. The Commission undoubtedly established a legal gambling market in Ukraine and laid a foundation that must now be further developed and strengthened in response to current challenges and the evolving needs of the market, society, and the state. As of now, the Ukrainian gambling and lottery market is regulated by the PLAYCITY Agency. Unlike the Commission, this body has a single-head structure, which is a significant advantage, as the collegiate decision-making model of the Commission proved inefficient, making rapid regulatory decision making difficult, while also diluting accountability. Now, the functions of policymaking and policy implementation in the gambling and lottery sector have been separated. The Ministry of Digital Transformation of Ukraine will be responsible for developing policy and approving regulatory acts and licensing conditions. The PLAYCITY Agency will implement this policy by issuing and revoking licenses, conducting inspections, imposing fines, and more.
Positioning the regulator under the authority of the Ministry of Digital Transformation of Ukraine may offer significant benefits for the newly formed body. The Ministry possesses extensive resources and experience in implementing large- scale digital projects across various sectors of the economy. This could be a great support for PLAYCITY making it more likely to achieve the objectives set for it. Main goals and challenges for the new regulator The primary challenge for the new regulator is the creation and implementation of a state online monitoring system. This was mandated under the main gambling law since 2020 but was never established by the Commission for the Regulation of Gambling and Lotteries. This failure was one of the main sources of criticism against the former regulatory body. The development and operation of such a system appears to be technically complex and potentially financially costly, especially when considering how the system is defined by current legislation. Concerns have been raised over its effectiveness and alignment with the goals it is meant to serve. It is worth noting that no jurisdiction with highly developed control systems for gambling operators has a system similar to the one mandated by Ukrainian law. According to the law, the system must collect, process, aggregate, and analyze in real time all the data — including information on all deposits, bets, winnings, and payouts — generated by the online systems of both online and land- based gambling operators. Managing and analyzing such an enormous volume of data to detect violations and anomalies appears to be an extremely ambitious task. While it may be technically possible to build such a system using the latest digital technologies, whether it will result in a truly functional regulatory tool that ensures a transparent and secure gambling market remains uncertain. International
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IMGL MAGAZINE | JUNE 2025
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