Lawyer
Expert in corporate and international corporate law. Has extensive experience in supporting the acquisition of financial licenses in Ukraine, as well as business incorporation in the EU, the United Kingdom, Switzerland, the UAE, and key Asian jurisdictions.
Extension of gambling licenses in Ukraine
The gambling business in Ukraine has undergone significant changes in 2025: the state has reformed the regulatory system, resumed the licensing process and tightened the requirements for gambling operators. We work every day with operators and investors who seek to maintain and extend their licenses on legal grounds. In this article, we will examine in detail the legal mechanisms for extending gambling licenses in Ukraine, key legislative innovations in 2025, the requirements of the state regulator – Play City, as well as practical risks and recommendations for business.
Change of regulator: from KRAIL to Play City
In 2025, Ukraine completed the transformation of the regulatory body that exercises control over the gambling sector. Previously, this function belonged to the Commission for the Regulation of Gambling and Lotteries (KRAL), but due to a number of scandals and corruption risks, its activities were terminated. Instead, the State Agency for the Control of Gambling and Lottery Business – Play City was created, which aims to digitalize the licensing process, increase market transparency and eliminate the human factor in making decisions on the issuance, extension or cancellation of licenses.
Play City began to actively issue new licenses and confirm existing ones since the fall of 2025. According to the state body, almost UAH 50 million in additional revenue to the budget from payments for issuing licenses was received at the beginning of the licensing cycle alone, which indicates real interest of investors in operating activities in the regulated gambling market.
What does a license extension entail?
The procedure for extending a gambling license in Ukraine today is a complex legal process that includes several key elements:
- Submission of a package of documents within a specified period: existing licensees must submit to Play City documents confirming compliance with the updated requirements within the period established by the Cabinet of Ministers.
- Compliance with new criteria: the licensee must demonstrate impeccable business reputation, lack of ties with aggressor jurisdictions and full compliance with the requirements for the implementation of responsible gaming measures.
- Financial transparency and technical standards: operators must confirm the availability of appropriate financial mechanisms, including control over payments and transparent reporting.
After submitting documents, Play City conducts an inspection in accordance with the approved procedure. If the operator has successfully confirmed compliance with the requirements, the license is extended or confirmed taking into account the requirements for responsible gaming, consumer protection and anti-money laundering.
Play City also adopted new technological requirements for online monitoring and control of operators’ activities. Particular attention was paid to digitalization – in particular, the automation of the process of submitting, paying for and checking licenses through state services.
According to the analysis of Play City’s activities and open sources, in 2025:
- the state budget received more than UAH 1.4 billion from license fees;
- more than 2,500 illegal online casinos were blocked;
- Play City issued 10 new B2B licenses for software providers, while simultaneously canceling seven licenses due to non-compliance with the requirements and lack of response to the regulator’s requests.
These indicators indicate an active stage of market cleansing and transition to a working legal regime.
Legal risks and recommendations for licensees
To successfully renew a gambling license in Ukraine, companies should consider a number of important legal aspects:
- Compliance and internal policies – companies must have proper documentation on anti-money laundering, responsible gaming, customer identification mechanisms, as well as corporate standards of transparent activity.
- Updating the ownership structure – checking the company’s beneficial structure for compliance with the new Play City criteria.
- Timely submission of documents – the deadlines set by the regulator are mandatory: late payment may result in fines or license cancellation.
- Legal support – for the comprehensive preparation of a package of documents and representation before the regulator, it is critically important to have professional support.
Our team helps operators avoid common mistakes and minimize legal risks, which is especially important in conditions of constant changes in the regulatory environment.
Preliminary legal and compliance audit
At the first stage, we conduct a comprehensive analysis of the current state of the licensee, including:
- checking the compliance of the ownership structure with the updated requirements of the legislation;
- analyzing the beneficiaries, directors and key officials for business reputation;
- assessing the presence of risks associated with jurisdictions of increased control or aggressor countries;
- checking internal policies (AML/KYC, Responsible Gambling, Data Protection).
Such an audit allows us to identify weaknesses in advance that may be grounds for refusing to renew the license.
Preparation and updating of a package of documents
Our specialists prepare or update all documents required for submission to Play City, taking into account the current practice of the regulator, in particular:
- applications and cover letters;
- corporate documents;
- confirmation of financial capacity;
- compliance policies and internal procedures;
- explanatory memoranda in the case of a complex business structure.
We are not limited to the formal filling of documents, but adapt them to the client’s specific business model, which significantly increases the chances of a positive decision.
Support for interaction with Play City
A separate area of our work is direct support for communication with the regulator:
- submission of documents and monitoring compliance with deadlines;
- responding to Play City’s requests and comments;
- preparing legal positions in the event of additional inspections;
- supporting procedures for confirming or extending a license.
Thanks to practical experience in interacting with regulatory authorities, we help clients avoid delaying procedures and reduce regulatory risks.
Risk management and protection of the licensee’s interests
In the event of a dispute, our team:
- analyzes the grounds for possible license denials or suspensions;
- prepares legal opinions and objections;
- accompanies administrative procedures and, if necessary, legal protection of the client’s interests.
We pay special attention to situations where the license is under threat due to changes in legislation or regulatory approaches.
Strategic consulting for the gambling business
In addition to the direct extension of licenses, the Law Firm “Prikhodko and Partners” provides strategic consultations on:
- the optimal corporate structure of the gambling business;
- entry of foreign operators into the Ukrainian market;
- integration of fintech solutions and payment instruments;
- preparing the business for future regulatory changes.
This approach allows our clients not only to maintain their license, but also to build a stable, scalable and legal model of activity in the Ukrainian gambling market.
Contact us and we will help you avoid misunderstandings and ensure the successful functioning of your business.
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