Gambling Software Licensing Under Finland’s New Gambling Act

The Finnish gambling framework is undergoing major reform. In our previous articles we have already addressed the updated government proposal (HE 16/2025 vp) for the new Finnish Gambling Act, and the clarified application documentation.

Under the new gambling framework, the gambling markets will be opened to new gambling operators as well as gambling software providers. In this article we discuss gambling softwares, the process of applying for a gambling software license, and obligations concerning the license holders that have been granted the software license.

Gambling Software License

In the detailed rationale of the government proposal, gaming software has been described as software that is designed to be used in the operation of gambling activities or that a gambling license holder uses to provide their gambling services. Gambling software includes all applications and programs used in gambling operations, including, for example, betting software, random number generators, systems for authorizing and recording game events, determining outcomes, and calculating and paying winnings to customers’ accounts.

Per proposed Act, a gambling software license can be granted for the development, supply, installation or customization of gambling software used in the operation of licensed gambling activities. The proposed Act requires gambling operators to only use licensed gambling software. Therefore, the purpose of software licenses is to govern which gambling software is used by the gambling license holders. While the proposed Act requires gambling operators to only use licensed software, the Act also forbids licensed software providers from supplying gambling operators that have not been granted a gambling license and thus operate illegally in Finland. This means that the licensing requirements apply bilaterally, indicating that both the operator and the software provider must ensure that the other party is a licensed entity in compliance with the Finnish Gambling Act.

The supervisory authority is required to maintain a register of operators and software providers that are licensed under the new framework. Ensuring that the counterparty is a licensed entity can be done by conducting checks against the supervisory authority’s register.

The legal requirements for using licensed gambling software will take effect on January 1, 2028, as the software license can be applied for no earlier than the beginning of 2027.  As with the gambling license, the software license shall be granted for a maximum of five years at a time. Once the supervisory authority approves the license application, the provision of the software may begin immediately.

License Requirements

The requirements for approving and holding a gambling software license are primarily similar to those of a gambling license (see our previous article here). In accordance with the orders issued by the National Police Board of Finland (NPB), the documentation required for a gambling software license application mainly includes reports and descriptions of the applicant’s organizational structure, financial stability, and planned operations. It is worth noting that, unlike applications for gambling licenses, marketing is not addressed in the NPB’s orders concerning software license applications. The reason for this may lie in the nature of B2B marketing typically used by software providers, as opposed to the consumer-facing marketing of gambling operators where consumer and player protection becomes particularly important.

Granting a gambling software license requires that the applicant be reliable and suitable for developing, supplying, installing, or modifying software used in the operation of gambling services. Effectively, the same requirements apply as those for gambling license applicants, consisting of an assessment of the reliability and suitability of the software provider’s owners and management.

Unlike gambling license applications, which may be submitted to the NPB starting from the beginning of 2026 and will be processed by the NPB if submitted before the end of 2026, software license applications can only be submitted from January 1 onward. Therefore, license applications will be processed solely by the new Finnish Supervisory Agency.

Other Obligations

As previously noted, gambling software license holders may only provide, develop, or modify gambling software for operators licensed under the proposed Act. Non-compliance with this obligation may lead to the imposition of an administrative penalty fee on the software provider in breach. The amount of the penalty fee is based on the overall assessment of the breach. For legal entities, the penalty may not exceed four percent of the revenue for the financial year preceding the violation and is capped at five million euros.  

Gambling software license holders are also subject to a supervision fee, but the fee is set at a standard amount of €1,500, unlike the supervision fees regarding the gambling license, which are based on the gross gaming revenue (GGR).

Final Remarks

As Finland’s gambling market undergoes significant transformation, the new regulatory framework introduces fresh opportunities not only for licensed gambling operators but also for software providers operating within the sector.

Bilateral licensing obligations under the proposed Finnish Gambling Act require that both the gambling service operator and the software provider be duly licensed for activities in the gambling service to be fully compliant with applicable law. This applies regardless of whether an entity operates as the gambling service provider or as the party responsible for developing and supplying the software used to conduct gambling operations.

Our team at Nordic Law possesses strong expertise in the gambling industry and its legal landscape. We have extensive experience advising clients through licensing processes under both EU and Finnish regulatory frameworks. We are fully equipped to provide guidance on the forthcoming obligations introduced by the proposed Act and the operational measures necessary for regulatory compliance. We welcome any opportunity to discuss your relevant legal needs for the successful launch of gambling operations in the new era of Finnish gambling.