The Finnish Government Publishes Updated Proposal for New Gambling Legislation

On 20 March 2025, the Finnish Government published an updated draft proposal for new legislation governing online gaming and gambling (HE 16/2025 vp). The revised draft introduces several amendments to the initial version, which was released on July 7th, 2024. The reason for these changes lies in the public consultation conducted between the two versions. The feedback received during this consultation has now been reflected in the revised proposal.

The amendments primarily address four key areas:

• Gambling Licenses and Provision of Gambling Services
• Marketing of Gambling Services
• Supervision and Supervisory Fees
• Blocking Payment Transactions and Internet Access; Removal of Online Content

This article provides a concise summary of each of these key areas. You can also read our other articles on the launch of the reform project and its background.

Gambling Licenses and the Provision of Gambling Services

Firstly, the documentation required in the gambling license application has been expanded and clarified. The application must now include a detailed explanation of anti-money laundering (AML) and counter-terrorism measures, Know Your Customer (KYC) procedures, and risk management strategies. Additionally, the reporting obligations of the license holder have been clarified to cover, among other things, a detailed internal control plan and documentation relating to the duty of care.

A particularly significant amendment concerns the offering of so-called "bonus money," which would be permitted under the new regulatory framework. This change is expected to significantly impact the operational and marketing strategies of gambling operators. The decision to permit bonus money follows widespread support in the consultation responses, including practical arguments highlighted by Nordic Law in its statement.

Horse race betting has also been removed from the scope of the exclusive license and brought under the general gambling license framework.

Marketing of Gambling Services

Although some restrictions on marketing have been relaxed, marketing remains tightly regulated. The restriction that previously required license holders to advertise solely on their own behalf has been removed, as has the requirement that marketing must be considered "necessary." Under the updated version, outdoor marketing is also permitted, though subject to restrictions, such as prohibitions on placement near facilities primarily used by vulnerable groups.

Despite the support it received during the consultation, affiliate marketing remains prohibited in the updated proposal. Furthermore, the responsibilities of license holders in relation to sponsorship agreements have been clarified. License holders must ensure that gambling products are not promoted through sponsorships and that the license holder's name or logo does not appear on products or services specifically intended for individuals under 18 years of age.

Supervision and Supervisory Fees

Under the proposal, supervisory authorities would no longer have the right to conduct test purchases under a covert identity. At the same time, the obligation to technically monitor individual player behavior has been expanded. License holders are required to technically monitor player account activity and retain the corresponding documentation. This documentation must be submitted to the supervisory authority in the format specified by the authority.

Supervisory fees have generally been increased. The calculation method remains unchanged, meaning fees are still based on the gross gaming revenue (GGR) of the license holder. A new provision has been added allowing the supervisory authority to reduce fees if the amount collected exceeds total supervisory costs by more than five percent.

Blocking Payment Transactions and Internet Access; Removal of Online Content

Chapter 8 of the original draft of the Gambling Act, which proposed the blocking of payment transactions and internet access, has been completely removed from the updated draft. However, the provisions regarding removal orders have been retained and moved to Chapter 7. According to the updated provision, if the supervisory authority detects illegal gambling activities, it may order the responsible party to remove gambling services or marketing content from the web. The authority may also order domain name registrars or operators to delete the domain name from the register, making it available for others to register.

Other Notable Changes

One notable amendment is the expanded opportunity for international cooperation. A previous restriction that allowed such cooperation only with gambling service providers located in another EU or EEA member state has been removed. The updated proposal now requires that any partner has a license to offer the relevant gambling services, the right to engage in international cooperation, and does not provide gambling services illegally in Finland. Strict geographical limitations have thus been relaxed.

Although allowing gambling with crypto-assets received broad support during the consultation, the use of crypto-assets remains prohibited under the revised proposal. The lawmakers have justified the ban by citing the still-developing regulatory framework for crypto-assets (notably the MiCA regulation) and risks related to money laundering and terrorist financing. In our interpretation, this restriction remains poorly justified and contradicts the EU principle of technological neutrality.

In Conclusion

The legislative process is progressing rapidly, and the Parliament is expected to approve the changes largely as proposed. The proposal is currently under committee review, after which it will return to Parliament for the first reading. The application process for gambling licenses is expected to begin in early 2026, with licensed operators anticipated to launch their services in early 2027.

Timely preparation for the licensing process offers a clear competitive advantage to market participants. Nordic Law is closely monitoring the legislative process and analyzing the expert opinions submitted to parliamentary committees to anticipate future developments.

At Nordic Law, we combine solid gambling industry experience with expert knowledge of EU and Finnish regulatory frameworks and licensing procedures. This enables us to provide informed, strategic advice to clients navigating this complex and evolving environment.

We assist our clients throughout the entire process—from initial preparations and drafting of license applications to the lawful commencement of gambling operations. We are happy to discuss the potential requirements of Finland's evolving market and the measures necessary for effective preparation.