The First Draft of the Finnish Gambling Regime Has Been Published – Outlook on the Blue-White Gambling System

Written By

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Pia Ek

Partner
Finland

I am a partner and co-head of our Tech & Comms Group as well as Commercial Group, based in our Helsinki office. I have over 20 years of experience in cross-border digital transformation projects, outsourcing, cloud services, ICT and IP-driven transactions as well as in IoT, licensing and e-commerce assignments.

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Katia Duncker

Partner
Finland

As a partner in our Helsinki office and head of our Competition & EU Law group in Finland, I specialise in complex competition and corporate matters.

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Maria Karpathakis

Associate
Finland

I am an associate in our international Competition & EU Law team, advising on Finnish and EU competition law as well as Finnish FDI regulation and Finnish gambling law.

The Finnish Government has released a draft of the legislative proposal for new legislation reforming the gambling system. The draft has been released for a public opinion round that lasts until 18 August 2024.

The proposed key changes to the gambling system are:

  • More lenient legislation on offering and marketing online gambling games
  • A new gambling licensing system for B2C and B2B operators
  • A new supervisory authority 

New licensing system

What is the timeline for the new proposal? 

The government proposal is to be submitted to Parliament during the spring term of 2025. The new gambling system would be introduced in stages. Applications for gambling licences could be submitted from the beginning of 2026 and licensed gambling operators could start offering games from the beginning of 2027. 

Veikkaus Oy would be allowed to continue its current operations as a monopoly until the end of 2026. This means that there would not be a previously discussed cooling-off period. It would also be possible to apply for a licence to provide gambling software from the beginning of 2027. 

The obligation to only procure services from a licenced software provider would apply from the beginning of 2028. In other words, B2C gambling games providers would only be allowed to provide their services to customers if the service is based on software that has been obtained from a licenced B2B gambling software provider. 

What licences would become available? 

The proposed law would establish a supervised licence system for the provision of B2C gambling games and B2B gambling software provision. The proposed licence system model would allow gambling companies to apply to the new licensing and supervisory authority for a licence to operate B2C gambling games in Finland or in B2B gambling software. B2C gambling games could be provided under an exclusive licence or a gambling games licence. B2B provision of gambling software would also require a separate licence. 

Which gambling operations could be applied for? 

A B2C gambling game licence could be applied for the operation of fixed-odds and variable-odds betting (both online and off-line), electronically provided casino games, electronic money bingo and electronically provided slot machines. A B2B licence to provide gambling games would need to be applied to manufacture, supply, install or adapt any of the gambling games software that require an exclusive or gambling games licence.  

What are the costs associated with the new system? 

Some of the fees involved in the new process are a processing fee to be paid by applicants for each licence type, as well as an annual supervision fee to be paid to the supervisory authority by licence holders. In addition, a tax of 22% calculated on the GGR would be posed on the licensed operators.

New supervisory authority

The supervision of gambling would be moved to the future Licensing and Supervisory Authority, under the Ministry of Finance. The Authority would be able to intervene in illegal activities by imposing administrative sanctions. 

What to expect going forward?

The opinion round for the proposal has begun on 3 July 2024 and will last until 18 August 2024. All individuals and organisations are welcome to participate and leave their thoughts on the proposal, which at this stage of the process is the most effective way to contribute to the drafting of the new legislation. 

Opinions can be submitted at the government-operated service Lausuntopalvelu.fi (requires authentication), where the draft bill and request for comments will be posted, or by delivering them directly to the Registry of the Ministry of the Interior by email at [email protected]. As the opinions have to be submitted in Finnish or Swedish our team would be happy to assist with the process.

Our team will be following the developments closely going forward. In the coming days, we will analyse the draft in detail and share our thoughts on the proposed legislative package soon – stay tuned for more. For more information, please contact our lawyers specialised in matters associated with gambling: Pia Ek, Katia Duncker or Maria Karpathakis.