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.

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OBTAINING LOTTERY LICENSE

OBTAINING LOTTERY LICENSE

The lottery market in the world is one of the most regulated segments of gambling. Public and private operators are expected not only to comply with legislation, but also to build a transparent system of control, AML/KYC policies, data protection and financial responsibility. This process has become significantly more complicated due to increased regulation and attention to compliance.

Top 10 jurisdictions for lottery licenses

Different countries approach the lottery market differently: some allow private operators to operate online, others retain a state monopoly. However, some jurisdictions offer favorable conditions for starting an international business:

  • Malta (MGA) is one of the most popular regulatory regimes for gambling, including lotteries. Supports access to the EU market.
  • United Kingdom (UKGC) — The UK Gambling Commission has a separate category for lotteries, which includes both online and offline segments.
  • Spain (DGOJ) — clear rules and requirements for operator compliance.
  • Italy (ADM) — licenses and controls a wide range of lotteries.
  • Denmark (DGA) — a stable market with clear requirements for licensees.
  • France (ANJ) — a strict regulatory system, but a large gambling market.
  • Netherlands (KSA) — an integrated system of control of all types of gambling.
  • Curacao — one of the most accessible jurisdictions with wide opportunities for online operations.
  • Gibraltar — a prestigious license suitable for international brands.
  • Ukraine (Play City) — is developing rapidly, in particular in the online lottery and poker segment.

This rating is based on a combination of regulatory transparency, global access, compliance requirements and investor profitability.

It will also be useful: How to transport more than $10 000?

What is required: legal requirements

Below are the key requirements for licensees operating in leading jurisdictions:

Malta (MGA)

  • The applicant must meet fit & proper standards (personality, integrity).
  • Confirmation of capital and financial stability.
  • AML/KYC policies, responsible gaming policies.
  • IT infrastructure certification.
  • Legal framework: Gaming Act (Chapter 583).

United Kingdom (UKGC)

  • Requirements for financial capacity and corporate governance.
  • Ensuring player protection and AML control.
  • Legal framework: Gambling Act 2005.

Spain (DGOJ)

  • Detailed requirements for mechanisms for controlling and recording bets.
  • Mandatory reports and interaction with the regulator.
  • Legal framework: Ley 13/2011.

Ukraine (Play City)

  • Transparent ownership structure.
  • AML/KYC and financial monitoring in accordance with the laws on gambling and financial monitoring.
  • Technical solutions must be safe and reliable.
  • Legal basis: Law of Ukraine “On State Regulation of Activities Concerning the Organization and Conduct of Gambling”.

Key requirements for a potential owner

Regardless of jurisdiction, regulators focus on the following aspects:

Transparent ownership structure

  • Full disclosure of beneficiaries.
  • Absence of ties to jurisdictions with increased risk.

Good financial standing

  • Confirmation of the origin of funds.
  • Minimum capital (varies depending on jurisdiction).
  • Financial stability of the company.

Compliance and responsibility

  • AML/KYC procedures.
  • Responsible Gaming policy.
  • Data protection (GDPR for the EU, local requirements in other jurisdictions).
  • Reporting to regulators.

Technical capacity

  • Secure IT systems.
  • Transaction control and audit.
  • Risk monitoring system.
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Lottery License Procedure and Timeframes

The licensing process consists of several main steps:

Preliminary Assessment

Legal Audit of the Business Model, Structure, Compliance and Technical Architecture.

Document Preparation

This includes:

  • Company Articles of Association;
  • Business Plan;
  • AML/KYC Policies;
  • Financial Statements;
  • Technical Descriptions of Systems.

Regulator Submission

Documents are submitted to the relevant regulators (UKGC, MGA, DGOJ, Play City, etc.).

Review and Assessment

The regulator conducts a formal and expert review.

In 2025, the average application processing time was:

  • UKGC: 12–24 weeks,
  • MGA: 10–18 weeks,
  • Curacao: 4–8 weeks,
  • Play City (Ukraine): 30–60 business days.

Obtaining a decision

After a positive review, the company receives a license with which it can officially launch and operate lottery activities.

How much does a document package relevance analysis cost?

It is important to conduct a thorough analysis of the documents before submitting them to the regulator. This minimizes the risk of the package being returned for revision or rejection.

The approximate cost of such an analysis is from €2,500 to €7,000, depending on the jurisdiction, volume of documents, company size and complexity of the business model.

Such an analysis allows you to assess:

  • compliance with AML/KYC policies;
  • compliance with the ownership structure;
  • technical risks;
  • financial capacity.

Returning the package for revision can cost significantly more.

Key difficulties in obtaining a lottery license

Obtaining a license involves a number of challenges:

Incomplete document package

Lack of technical descriptions or financial confirmations is one of the most common reasons for a return.

Ineffective compliance

Without proper AML/KYC policies, the risk of rejection increases.

Structural issues

A vague corporate structure or opaque beneficiaries can be an obstacle.

Technical risks

Lack of certification of IT systems, weak monitoring and data protection mechanisms.

Find out the cost of legal support

How do we help you obtain a lottery license?

The law firm “Prikhodko & Partners” has deep expertise in international corporate law, gambling regulation and compliance. Our specialists provide a full range of legal services for the successful obtaining and maintenance of licenses:

Audit and project assessment

We analyze all key aspects:

  • ownership structure;
  • financial model;
  • AML/KYC procedures;
  • technical architecture.

This allows us to identify risks even before submitting an application.

Preparation of a package of documents

Our lawyers prepare:

  • business plans and memoranda;
  • corporate documents;
  • compliance policies;
  • technical descriptions and certificates;
  • financial confirmations.

We form a package that meets the specifications of the regulator.

Interaction with the regulator

We undertake:

  • submission of the application;
  • responding to inquiries;
  • compliance with regulatory requirements;
  • support for audits and inspections.

This reduces review times and minimizes the risk of returns.

Post-license support

Obtaining a license is just the beginning.
We:

  • conduct regular compliance audits;
  • adapt policies in accordance with changes in legislation;
  • advise on fintech integrations.

Obtaining a lottery license is a multi-component and responsible process that requires understanding regulatory requirements, compliance and technical aspects. Choosing the right jurisdiction, preparing documents and interacting with the regulator determine success. In 2025, the global lottery market continues to grow, and companies operating in this segment must ensure full compliance with standards.

The law firm “Prikhodko and Partners” provides full legal support: from project evaluation to obtaining a license and further support. We help clients choose a jurisdiction, prepare a high-quality package of documents and go through the procedure as efficiently as possible and without unnecessary risks.

Calculate the cost of services

1 question

Do you need a company registration in the jurisdiction where you want to get a license?

Yes
No

2 question

Do you need advice on choosing a jurisdiction for gambling?

Yes
No

3 question

Do you need advice on the taxation system of such a business?

Yes
No

4 question

Can you confirm the legality of the origin of the funds for the purchase of the license?

Yes
No

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