The Ukrainian land-based gambling market remains tightly regulated, and operators must undergo a complex licensing process before opening a casino. Since 2025, the regulatory landscape has changed significantly: the Commission for the Regulation of Gambling and Lotteries (KRAIL) was dissolved, and its functions were transferred to a new state authority under the Ministry of Digital Transformation. Alongside this institutional reform, new advertising restrictions and compliance measures have come into force, increasing the requirements for market entry.
Main Steps to Obtain a Casino License in Ukraine (2025)
1. Company Registration and Compliance
- The operator must establish a Ukrainian legal entity with the appropriate gambling-related business codes (KVEDs).
- Beneficial owners and shareholders must undergo background checks to confirm no criminal record and no ties to sanctioned jurisdictions.
- The minimum authorized capital remains 30 million UAH (approx. €700,000), usually paid in stages.
- A compliance officer (separate from the CEO) must be appointed, as gambling companies are classified as primary subjects under AML legislation.
- Additional transparency requirements apply: companies with outstanding tax debts or unclear ownership structures are no longer eligible for licensing.
2. Premises Approval
- Applicants must provide a valid ownership or lease agreement for the venue.
- Ownership chains must be fully documented and transparent.
- The technical passport and floor plan must clearly identify the gaming area.
- Land-based casinos may operate only in certified 4–5 star hotels. All documents must meet Ukrainian standards (DSTU).
3. Licensing of Gambling Equipment
- Gambling equipment must be certified through authorized laboratories.
- Certification is still based on outdated DSTU standards, but a new technical regulation is under development and expected to raise the bar for compliance.
- The licensing of B2B suppliers was introduced in 2025: only certified Ukrainian-resident providers may supply software and equipment to operators.
4. Documentation for License Application
Operators face frequent rejections due to:
- Incorrectly filled forms (missing mandatory fields, mismatched data).
- Incomplete documentation packages, as the regulator may request additional papers beyond the law.
- Insufficient information, such as missing banking details, brand names, or trademarks.
While refusals are published, explanations remain vague. Appeals are rare, and most applicants simply resubmit corrected documentation.
New Challenges in 2025
1. Regulatory Transition
The replacement of KRAIL with a new authority has created temporary uncertainty in procedures and timelines. Consultation mechanisms remain limited, and many decisions are left to regulator interpretation.
2. Advertising Restrictions
The new law imposes strict limits:
- Gambling ads may appear only between 23:00 and 06:00 on TV and radio.
- Online advertising is allowed only on platforms where the audience is verified to be 21+.
- The use of patriotic imagery, references to war, celebrities (except athletes), or fictional characters is strictly prohibited.
- Sponsorship is permitted only in sports.
3. Compliance and Player Protection
- Operators must implement player activity limits (time and spending caps), as well as mandatory breaks during play.
- A “mystery shopper” inspection system with video recording has been introduced to monitor compliance.
- The self-exclusion system has been digitized and is now available directly through the Diia app.
4. Capital and Financial Monitoring
- When forming capital through loans, the regulator may request loan contracts, bank statements, and source of funds documents, even if not explicitly listed in the law.
- AML procedures are becoming more demanding, increasing compliance costs and administrative workload.
Conclusion
Opening a land-based casino in Ukraine in 2025 is still possible but requires thorough preparation, strict compliance, and significant investment. Operators must be ready for detailed scrutiny of ownership, financing, and documentation, alongside adapting to the new regulatory authority and B2B licensing rules.
Success in the Ukrainian market now depends not only on meeting the basic legal requirements but also on anticipating additional regulator demands, complying with stricter advertising restrictions, and implementing advanced player protection tools.
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