Ukraine Relaunches Gambling: Licensing & Monitoring Update
On 1 September 2025, the Cabinet of Ministers of Ukraine has adopted Resolution No. 1117, which approved new licencing conditions for gambling organisers (hereinafter – organisers). This decision restarts the suspended licencing process in the gambling sector and introduces additional requirements for organisers.
For the current licencees, a two-month period (until 12 November 2025) has been set for submitting a package of documents confirming the licencee’s compliance with the new requirements to the PlayCity State Agency (PlayCity – Ukraine’s gambling regulator). Failure to comply with the latest requirements may result in fines or licence revocation.
Key changes
Strengthening of financial control and identification. The new licencing rules strengthen control over financial transactions and transparency of transactions:
any non-cash payments (including online) are allowed to be carried out exclusively through current accounts opened in Ukrainian banks;
for all cash and/or non-cash transactions, the use of cash registers is mandatory;
players are prohibited to use more than one personal account and more than one personal bank account for carrying out all transactions; and
organisers are prohibited from accepting bets or replenishing gaming balances from third parties, and players are prohibited from using third-party accounts to carry out transactions or receive payments.
Expansion of responsible gaming requirements. All organisers (both offline and online) are now required to prevent players from participating in games without first setting limits on their expenses and time, and to inform players of the need to comply with these limits.
Organisers of online gambling shall pay a player included in the Register of persons with restricted access to gambling establishments their remaining balance and/or winnings within 5 days of the request, after which they must block the account and make it impossible to replenish the balance.
Increase in market transparency. From now on, the licencing authority, PlayCity, is obliged to publish the documents submitted by the licence applicant on its official website. Publication will take place after the decision to issue a licence has been made and in compliance with the requirements for protecting confidential information.
State Online Monitoring System (SOMS). The implementation of SOMS has entered its active phase. On 11 September 2025, a tender was held for the development of the system, and the final review of the company’s documents is currently underway, with the submission of the best proposal. According to PlayCity’s plan, the first phase of the SOMS will be launched for trial operation by the end of 2025. This stage is expected to cover 60% of the functionality, including the monitoring of financial flows. This will enable the State Tax Service of Ukraine to effectively administer tax obligations in the gambling industry, including corporate income tax, personal income tax and military tax on winnings (a wartime tax measure in Ukraine). The National Bank of Ukraine will also have access to the SOMS within the scope of its powers.
In addition, the functionality of the SOMS has been expanded. A new function of the SOMS is to monitor the actions of players and control the compliance of gambling organisers with the principles of responsible gaming, as well as to control the implementation of requirements to combat severe gambling addiction (ludomania). At the same time, the possibility of remotely disabling slot machines has been excluded from the SOMS’s functionality.
Conclusions
The key vectors of the updated rules are increased financial transparency and the implementation of additional responsible gaming mechanisms. The launch of the first phase of the SOMS may be a key step towards improving the effective monitoring of organisers. Market participants now need to review their internal rules to ensure compliance with the new requirements within the established two-month period.