Head of International Corporate Law and Fintech Practice
Expert in fintech, crypto, and international corporate law with over 20 years of experience. Specializes in crypto licensing (VASP/CASP), iGaming business support, and international structuring, asset protection, and OSINT analytics for risk assessment and due diligence.
License for gaming machine halls
The gambling business in Ukraine continues to develop rapidly after the reforms of 2024–2025, which put the activities of establishments with slot machines under a new legal regime. For operators who seek to operate legally and with minimal risks, a license for a slot machine hall has become not only a formal requirement, but also a key condition for accessing the market on transparent terms. The law firm “Prikhodko and Partners” daily supports Ukrainian and international players in the field of gambling in matters of licensing, compliance and interaction with state regulators around the world.
Regulator: Play City and requirements for licensees in 2025
After the reform of the gambling regulatory system in early 2025, the main functions of control, licensing and supervision were transferred to the State Agency for Control of Gambling and Lottery Business – Play City. This body is responsible for issuing licenses, monitoring the activities of licensees and ensuring compliance with the legal regime, including anti-money laundering requirements, responsible gaming measures and financial transparency.
According to the results of the first three quarters of 2025, Play City issued almost 180 licenses of various types, of which more than 45 licenses were for slot machine halls throughout the territory of Ukraine. At the same time, the regulator carried out more than 600 unscheduled inspections, using suspicions of non-compliance or financial requirements as the basis for which. Such indicators indicate the state’s desire not only to legalize the market, but also to make it transparent and responsible.
Among the key requirements that Play City puts forward to license applicants:
- absence of ties with aggressor jurisdictions or companies with a dubious reputation;
- confirmed financial capacity;
- appropriate AML/KYC policies;
- internal procedures for responsible gaming;
- technical requirements for machine equipment and software.
Special attention is paid to methods of controlling players, recording bets and payouts, which actually brings the standards of the Ukrainian market closer to European ones.
Legal procedure for obtaining a license
The process of obtaining a license for a slot machine hall consists of several steps, each of which is critical for a successful outcome:
- Preparation of corporate and financial documentation. Including confirmation of funding sources, ownership structure, confirmation of the integrity of the founders and beneficiaries.
- Formation of a compliance package. This includes not only AML/KYC policies, but also internal procedures for responsible gaming, player rights protection, IT security and reporting.
- Submission of a package of documents to Play City. After this, the stage of formal and actual verification by the regulator begins.
- Interaction with the regulator during inspections. Play City may require clarification of documents, additional explanations or correction of individual deficiencies.
- Obtaining a positive decision and issuing a license. In case of approval by Play City, the operator receives a document that gives the right to open and operate the hall in accordance with a specified list of conditions.
It is worth noting that in 2025 the procedure became clearer than in previous years, and the terms of document review were significantly reduced due to the automation of processes.
Advantages of legal activity in Ukraine
The legal activity of a slot machine operator has a number of undeniable advantages:
- Legality and business protection. The license provides legal protection for the operator in interaction with customers and state authorities.
- Access to financial services. Banking institutions and payment services are more likely to cooperate with licensees, as this reduces the risks of non-payment.
- Reduced risk of reprisals from law enforcement agencies. Having a license minimizes the chance of administrative or criminal sanctions.
- Scalability. Licensees can apply for other types of gambling activities, including online products, subject to compliance with the requirements.
Legal risks without a license
Starting an activity without a license or with an expired document threatens with serious consequences:
- fines up to UAH 1.2 million;
- confiscation of gambling equipment;
- blocking of online services;
- criminal liability in case of systematic violations.
According to Play City, in the first half of 2025 alone, more than 85 fines were imposed on operators for violating license conditions.
Comprehensive legal support from “Prikhodko and Partners”
The law firm “Prikhodko & Partners” has deep expertise in corporate law, fintech regulation and licensing in the gambling sector. We support clients at all stages of interaction with government agencies, including Play City, to ensure that obtaining and renewing licenses is as predictable and legally secure as possible.
Preliminary audit and compliance assessment
We start with a legal and compliance audit to identify:
- risks associated with the business’s ownership structure;
- non-compliance with AML/KYC requirements;
- gaps in internal policies and procedures.
Such an audit allows you to draw up an individual action plan and minimize uncertainties.
Preparation of a full package of documents
Proper registration of applications and supporting documentation is the key to successfully obtaining a license. We:
- draw up all corporate and technical documents;
- form AML/KYC policies and responsible gaming procedures;
- we prepare business memoranda and legal justifications for the regulator.
Representation before the regulator
We undertake:
- submission of documents to Play City;
- responses to the regulator’s inquiries and comments;
- preparation for inspections and explanatory sessions.
Our experience allows us to go through all stages of communication with the regulator with minimal time.
Risk management and legal protection
If controversial situations or risks of license revocation arise during inspections, our team:
- develops a legal position;
- prepares objections;
- represents the client’s interests in administrative or judicial instances.
This is critically important in the conditions of dynamically changing legal landscape of the gambling market.
Ongoing support and compliance services
A license is not a one-time piece of paper: it requires constant compliance with the conditions. We provide:
- regular compliance audit;
- updating policies in accordance with changes in legislation;
- consulting on financial monitoring, IT security and player rights protection.
A slot machine hall license in Ukraine in 2025 is not only a permit to operate, but also a long-term legal and reputational guarantee for the business. The new Play City requirements set high standards, but at the same time create transparent rules of the game in the market. Regardless of the complexity of the business structure or the scale of the project, it is important to have an experienced legal partner on your side.
We work to ensure that your business is not only legal, but also protected from legal risks at every step.
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