Application Documentation Clarified: Key Information Required Under Finland’s Upcoming Gambling Regime

On March 20, 2025, the Finnish government released an updated proposal for the new Gambling Act. Nordic Law previously explored the broader legislative developments of that government proposal in our article (available here). As mentioned, under the proposal, the National Police Board of Finland will act as the supervisory authority until the end of 2026. During this period, National Police Board of Finland will be responsible for handling all gambling and gambling software license applications submitted before January 1, 2027.

To support the transition, the National Police Board issued a new order on June 6, outlining the application procedures under the forthcoming legislation. The order sets out in detail the documentation requirements for license applicants, including the specific information and supporting materials that must be provided as part of the application process.

In this article, we take a closer look at the key points of the order and what applicants should keep in mind moving forward. As can be noted, the National Police Board has clearly drawn upon practices commonly used in the financial sector, as the required documentation in many respects corresponds to the materials typically required in, for example, a payment institution’s or a crypto-asset service provider’s application, although there are also some exceptions.

General orders regarding the applications

Applicants are subject to largely similar documentation requirements, whether applying for a gambling license or a gambling software license – while naturally the actual content of the documentation depends on the applied license type. The applications may be submitted either by using the standardized application form provided by the supervisory authority or as a free-form written application. Regardless of the format, the application must be submitted in Finnish or Swedish.

Pursuant to the Act on the Openness of Government Activities (621/1999), all documents submitted are by default public. If the application contains information that the applicant intends to remain confidential, such information must be clearly identified and labeled as confidential, along with the applicable legal basis for confidentiality. To be said, this is highly recommended. The final assessment of confidentiality is conducted by the supervisory authority. Processing fees will be determined by a separate decree by the Ministry of Interior.

Documentation related to the applicant's organization

All applications must include applicant’s identification details, including name, legal form, business identification number, and the contact information of the designated contact person. In addition, applicants must provide a clear overview of the organizational structure, including ownership and control structure of the applicant.

Pursuant to the reliability and suitability assessment of the Section 10 of the proposed Finnish Gambling Act, the applicant must provide all the members and deputy members of the board of directors, significant owners and the persons in executive management roles. For the purposes of reliability and suitability assessment the name, personal identity number and the role in the applicant’s organization of the above-mentioned persons are required.

The applicants registered abroad have an obligation for more extensive documentation regarding the license applications. For foreign entities the applications must be accompanied by an official extract from the applicable register, criminal record extract from the applicant’s beneficial owners and executive management, as well as certifications of the applicant’s and its responsible persons’ fulfillment of obligations. 

In conclusion, a detailed description of the applicant’s organizational structure and governance is required as part of the application.

Statements on financial stability

The documentation concerning the financial situation of the applicant has been specified by the order issued by the National Police board of Finland. Financial stability is assessed through most recent approved financial statements. The financial statement is now required to include an income statement, balance sheet and the notes on the financial statement. The reported financial information is obligated to contain comparative figures from the previous financial year.

Financial documents serve as the basis for evaluating financial capacity to operate gambling activities in a stable and compliant matter. Reliability and transparency of the financial situation is essential for assessing the applicant’s solvency, liquidity and ability to fulfill the license holder’s obligations towards the players and the state.

Information related to planned operations

As part of the application, applicants are required to provide detailed information concerning their planned operations, including the intended provision of gambling services, the gambling software providers to be used, and the envisioned marketing of the gambling activities. Furthermore, the application must include a statement on the number of staff trained to handle customer complaints, ensuring the protection of players’ rights and access to appropriate remedies.

In the context of gambling licenses, an applicant may apply for a gambling license covering one or more forms of gambling service operations, either by submitting a single comprehensive application or multiple separate applications. Each application will be charged separately, so to ensure the most effective and streamlined entry into the newly regulated Finnish gambling market, a single-application approach is recommended. The forms of gambling operations the applicant may seek a license to provide will be listed in Section 6 of the proposed Finnish Gambling Act.

Documentation concerning marketing shall be provided in a free-form statement outlining the intended channels, timing and locations of the planned advertising activities. In addition, all brand names intended to be used in relation to advertising shall be listed in the application. This obligation is vital to enable the authorities to supervise the marketing of gambling operations. The function of the required marketing documentation is to ensure the license holders’ compliance with the chapter 4 of the proposed Finnish Gambling Act.

Pursuant to Section 33 of the proposed Finnish Gambling Act, only licensed gambling software can be used in the gambling services offered by a gambling license holder. Thus, the identification information of the software provider used by the applicant must be provided in the gambling license applications. As software license application may not be applied for before January 1, 2027, the requirement to use a licensed gambling software provider will take effect as of January 1, 2028. Nonetheless, early preparations for this obligation are essential to ensure full compliance with the proposed Finnish Gambling Act from the start of its enforcement.

Compliance documentation

Information submitted in relation to compliance arrangements include statements on AML and CTF policies. Also, statements on detecting and preventing competition manipulation are required to be included as part of the license application.

The AML and CFT materials shall include descriptions of KYC policy, customer due diligence procedures, reporting obligations, as well as risk assessment and risk management measures pursuant to the Anti-Money Laundering Act (444/2017). The applicant shall assess the scope and scale of its intended operations in relation to compliance with the AML and the CTF requirements. By submitting a comprehensive documentation addressing the risks associated with money laundering and terrorist financing, the applicant demonstrates its knowledge and understanding of the relevant risks and the procedures necessary to mitigate them.

In addition to the initial application, procedures for detecting and preventing competition manipulation must be continuously maintained throughout the provision of gambling services. Pursuant to Section 48 of the proposed act, a report outlining these procedures must be submitted to the supervisory authority on an annual basis.

In conclusion

The proposal for the new Finnish Gambling Act is currently under parliamentary committee review during which expert opinions and statements on the proposed act will be submitted. Parliament is expected to pass the new act as proposed. As the application process is expected to begin in early 2026 preparation of the required materials is essential for entering the Finnish gambling markets among the first new license holders.

The proposed Finnish Gambling Act and the order issued by National Police Board of Finland set out extensive documentation requirements throughout the provision of gambling services including the application phase described in this article. Key success factors in the application process include the submission of thorough and well-structured documentation, as well as maintaining full transparency and open communication with the supervisory authority.

At Nordic Law, we have extensive experience in the gambling industry and navigating application processes under both the EU and Finnish legal frameworks, providing our clients with a tangible advantage throughout the licensing procedure and the establishment of fully compliant gambling operations. Our team is well prepared to provide guidance on the emerging obligations under the proposed act and the practical measures needed for compliant operations.