Gambling license requirements in Finland

The Finnish government has submitted a bill to Parliament that would dismantle the current state monopoly on betting and online casino games, replacing it with a licensing model set to launch in January 2027. Once the new Gambling Act enters into force, the license is required to operate betting and online casino games legally in Finland.

Companies could start submitting applications for gambling licenses at the beginning of 2026, with licensed gambling starting at the beginning of 2027. Game software license applications could be submitted from 2027 onwards. Following a transition period, the requirement to use only licensed game software for running gambling games will take effect at the beginning of 2028.

We encourage companies interested in the Finnish gambling market to thoroughly review the licensing requirements and criteria and begin preparing for the application process once the new act is enacted.

To make this easier, we’ve outlined the key requirements and documentation needed to obtain a gambling license under the proposed Gambling Act.

Criteria for applicants

In addition to the general requirements (applicant being a natural person or a company), the applicant must meet certain fitness and propriety criteria to obtain a license. These requirements are diverse, and so it is essential that the license applicants ensure that they meet all the requirements for the license before submitting the application. 

According to the proposal, an applicant will be deemed unfit to meet the fitness and propriety requirements for a gambling or gambling software license if any of the following conditions are met:

• Criminal convictions: The applicant has been convicted of a prison sentence or corporate fine within the past five years, or of a fine within the past three years for a crime that indicates clear unsuitability to operate gambling activities or handle gambling software.

• Bankruptcy or financial Inability: The applicant is bankrupt or financially incapable of managing operations and fulfilling legal obligations.

• Debt collection issues: The applicant has debts in enforcement that exceed minor amounts or debts returned due to insolvency.

• Tax and payment negligence: The applicant has had repeated or significant failures in fulfilling tax or statutory payment obligations during the current year or the previous three calendar years.

• Business prohibition: The applicant is subject to a business prohibition or temporary business prohibition. 

• License revocation: The applicant has had a license under the new gambling law revoked in the past three years, unless it was voluntarily requested.

• Sanctions for illegal gambling: The applicant has received a prohibition decision or penalty fee in the past three years for operating or marketing gambling without a license.

• Recent violations of lotteries act: The applicant has received a prohibition decision or penalty fee after September 1, 2024, for violating the Lotteries Act (1047/2001).

• False or missing information: The applicant has provided materially false information or failed to provide required information to the supervisory authority.

• Sanctions or freezing orders: The applicant is subject, directly or indirectly through ownership or control, to sanctions under sanction regulations or national asset freezing decisions.

License application requirements

The licenses are submitted electronically which is expected to both expedite and facilitate the licensing process. The following information must be included in both the gambling and gambling software license applications unless information is already available to the authority:

• Applicant's identification details such as name, VAT number, and other identifying and contact details,
• Legal form of the applicant
• Ownership and control structure of the organization
• Financial status of the applicant (e.g. balance sheet and income statement)
• Information on business prohibitions, if any
• Articles of association, bylaws, or other description of the applicant’s purpose
• Description of the applicant’s operations (e.g. annual report)
• Requested license duration
• Criminal and fine record extract for natural person applicants
• Criminal and fine record extract for significant owners and executive management

In addition to these requirements, the following application requirements apply to the gambling license application only:

• Description of planned gambling operations
• Information on gambling software providers to be used
• Marketing plan
• Representative information for applicants based outside the European Economic Area (EEA)
• Details of agents used by the applicant
• Procedures and staffing for handling disputes, complaints, and other gambling-related issues, including measures to detect and prevent manipulation
• A report on compliance with obligations under regulations concerning the prevention of money laundering and terrorist financing, including customer due diligence, Investigation and reporting duties, Risk assessment and management methods.

The supervisory authority, which is yet to be established, would have the right to issue more detailed provisions regarding the content, format, and attachments of the license application. The authority could e.g. specify how an applicant should describe their financial situation or the nature of their operations, and what supporting documents are required.

Foreign applicants should also note that, while registration for a Finnish VAT number is not required at the application stage, it must be completed and reported to the authority no later than three months after starting the operations.

Technical requirements

Before starting its gambling operations, gambling license holders must submit to the supervisory authority a report and approval from a third-party assessment body regarding the game systems, drawing devices, and drawing methods they use, in order to ensure their reliability and the randomness of the draws. The third-party assessment body must be approved by the supervisory authority.

The proposed Act reserves a right for the supervisory authority to issue more detailed provisions on the technical requirements as well as on the format and content of the report and approval provided by the third-party assessment body, and the conditions that the third-party assessment body must meet in order to be approved by the authority. Further rules and guidance are therefore still expected to become available on the technical requirements as well as on the technical assessment bodies.

We would welcome such clarifications, as the proposed Act leaves room for interpretation. License applicants must have a clear understanding of all technical and legal requirements to be able to enter the market promptly and commence their betting and gambling operations. The shift from strict monopoly regulation to a freely competitive gambling market requires clear rules and guidelines to ensure that the market can function as intended in the proposed legislation.

Going forward

If you need legal support or advice on any issues related to the new Finnish Gambling Act, including assistance with the license application procedure, our team at DLA Piper Finland is happy to assist. Our legal advisors have extensive experience on advising companies within the existing legal framework (the Lotteries Act 1047/2001), and have been following the reform closely.

Read more about the key aspects of the Finnish gambling reform here, and gambling legal issues across the globe in our updated Gambling Laws of the World Guide available here. Further details can be found in the government’s proposal (in Finnish), available here.