Since August 2020, Ukraine has taken a significant step towards legalizing the gambling business by adopting Law No. 768-IX. This has opened up opportunities for operators, especially in the online casino and electronic gambling segment, but also set strict requirements. In this article, we analyze the key aspects of licensing and how to avoid risks when entering the market.
🔹 Legislative framework
The main law on this issue is “On state regulation of activities related to the organization and conduct of gambling”.
The licensing conditions are established by the Resolution of the Cabinet of Ministers of Ukraine No. 1341 dated 12/21/2020.
🔹 Who regulates?
The PlayCity is responsible for licensing and supervision of gambling.
🔹 Which games require a license?
In general, the following areas of gaming activity that are subject to licensing can be identified:
- Online casinos (including live casinos),
- Poker rooms,
- Video slots and other online gambling games,
- Betting platforms (bookmakers) (online and offline),
- Software providers (software license).
- Slot machines.
- Online lotteries.
🔹 Key conditions for obtaining a license:
- The legal entity must be registered in Ukraine: Founders and beneficiaries must pass a reliability check (no criminal record, no connections to offshore companies);
- The share capital of a legal entity is from UAH 30 million;
- Payment of license fee;
- Guarantees of financial stability;
- Certification of equipment and software;
- AML/KYC compliance check.
- Mandatory connection to the online monitoring system – control of bets and winnings in real time.
- AML/CTF Compliance – a license is not issued without an internal policy to combat money laundering and terrorist financing.
- Verification of sources of funds.
- Licenses are now provided only if you have a domain in the .UA zone.
🔹 Important aspects of the activity
For admitting minors, AML violations – fines up to ₴10 million and loss of license.
The regulator has the right to close a resource without a court decision for illegal activity.
Lack of transparency in reporting leads to additional charges and penalties.
To prevent unwanted situations:
- Implement KYC/AML systems with age and source of funds verification.
- Use White-Label solutions with already certified software.
- Enter into an agreement with a licensed payment provider (for example, Portmone, Fondy).
🔹 Taxation
Since 2022, a flat tax rate on gross revenue (GGR) has been in effect: 10% of revenue minus payments to players + 18% income tax.
🔹 International structuring
To protect assets and optimize taxation, a popular combination is:
Operating company in Ukraine + holding/ licensing structure abroad (Cyprus, Estonia, Malta).
You can read about choosing a jurisdiction for a foreign company in our publication at the link.
❗ Why is legal support important?
Without proper preparation:
- you may not get a license,
- lose money on fines,
- block activities by order of a court or regulator.
🔹 How we can help:
- Preparation of documents for obtaining a PlayCity license;
- Consulting on tax and corporate structuring;
- Development of AML/KYC policies, user agreements, privacy policy;
- Legal support: protection in disputes with regulators, challenging blockings.
- AML compliance: process audit, employee training.
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