Where are We Now? Recent Developments in the Finnish Gambling Reform

On 9 December the Finnish Government finally passed a long-awaited legislative package reforming Finland’s gambling market. The reform, which will enter into force in stages, marks a fundamental shift in the regulatory framework governing gambling services in Finland.

At the core of the reform is the new Gambling Act, which brings an end to the decades-long monopoly held by Veikkaus, a state-owned gambling operator. Under the new framework, Finland will transition to a licensing-based system, allowing private operators to offer gambling services in Finland provided that they obtain a gambling license and comply with the applicable regulatory requirements.

Private operators may apply for two types of licenses: a gambling license and a software license. A gambling license permits the provision of gambling services to the public in Finland, while a software license is required for the development and supply of software used in licensed gambling services.

This article discusses the final amendments and clarifications made to the upcoming Gambling Act and sets out the key factors for operators considering entry into the Finnish market.

Timeline Has Been Postponed

Due to delays in the legislative process, the entry into force of certain key provisions of the new Gambling Act has been postponed. Most notably, the date from which licensed operators may commence gambling operations in Finland has been moved from 1 January 2027 to 1 July 2027. As a result, the licensing timeline has been adjusted. The National Police Board of Finland (NPB) will begin accepting applications for gambling licenses on 1 March 2026, whereas the earlier application start date was set to 1 January 2026.

At the same time, the application for gambling software licenses will be delayed, with the new application start date set for 1 July 2027. The effective date of the requirement obliging operators to use only licensed gambling software has been moved from 1 January 2028 to 1 July 2028. The substantive requirements for the grant of any license type have remained the same. These requirements are discussed in more detail in our previous article, available here. Further guidance from the NPB is expected, particularly with respect to the technical requirements applicable to gambling software used in online games.  

Licensed Gambling Products

Veikkaus Oy, as the holder of an exclusive license, will retain exclusive rights to certain game types. These include lottery games and instant lottery games, slot machine games, and casino games. As Veikkaus is not eligible to apply for a gambling license under the new framework, most game types will be opened to licensed private operators. The primary distinction between game types covered by Veikkaus’s exclusive license and those subject to the licensing regime is whether the game is offered in a physical environment or exclusively online. As an exception to this general distinction, digital lottery games will remain under Veikkaus’s exclusive license.

Only gambling license holders may offer the following game types: fixed-odds betting, variable-odds betting, virtual betting, online casino games, online money bingo, and online slot machine games. The holder of an exclusive license is not permitted to offer these types of games. Gambling license holders may also offer these products as combination games that incorporate features of different game categories. The provision of combination games requires that the operator holds a license for each individual game type included in the combination.  

For a game type to be regarded as digital, the entire playing process, including purchase, draw, and payout, must take place online. Where this condition is met and the gambling license holder has been granted authorization to offer the relevant game type, the provision of gambling services will be considered lawful.

Marketing of Gambling Services

We have previously covered the marketing provisions of the new Gambling Act on our website. The marketing regulations have mostly remained unchanged from those set out in the Government Proposal for a new gambling framework (HE 16/2025 vp), with few key clarifications. As a positive development for gambling operators, search engine advertising is now expressly included in the list of permissible marketing channels. The Government proposal alone left the permissibility of Search Ads unresolved.

Furthermore, the requirement for gambling marketing to remain moderate in its extent, scope, visibility, and frequency has also been specified. Under the updated provision, marketing cannot be regarded as moderate where an individual marketing measure or marketing activities are particularly attention-grabbing or highly visible, or occur with particular frequency across one or more marketing channels. The purpose of the moderation requirement remains the same: the new framework aims to prevent and reduce gambling-related harm, particularly among individuals who are vulnerable to gambling addiction.

Affiliate marketing remains prohibited, even when the specific provision has been removed from the final version of the Gambling Act. Under the updated Act affiliate marketing is implicitly prohibited, as it has been left out of the permitted marketing channels listed in Section 51 of the Gambling Act. The protection of underage persons and vulnerable groups remains the primary limiting factor for permitted marketing activities.  

Player Protection Framework

Pursuant to Section 1 of the Finnish Gambling Act, one of the stated purposes of the Act is to prevent and reduce gambling-related harm and abuses. For this reason, the player protection framework forms a fundamental part of the new gambling regime. The latest updates have left the player protection-specific provisions largely unchanged; however, the key elements of the protective framework cannot be overstated.  

The objective of ensuring that gambling remains responsible extends to all regulatory areas, including licensing requirements, operational obligations, and marketing activities. Players must be able to set self-exclusions and monetary betting limits. Operators are also subject to duty-of-care obligations requiring them to continuously monitor and assess players’ gambling behavior. Where a player’s behavior is suspected to indicate gambling addiction, operators must intervene and contact the player. To reinforce the level of responsibility imposed on licensed operators, each operator must ensure that effective self-exclusion and deposit-limit tools are available to players.

Licensing Expenses

In December the Finnish Government also published the proposed fees applicable to gambling license applications. The submission of a gambling license will cost EUR 29,000, and any amendments made to an already granted license will be subject to a fee of EUR 1,120.

During the maximum five-year term of a gambling license, the license holder will be subject to annual licensing fees calculated based on its gross gaming revenue (GGR). The lowest annual fee, EUR 4,000, applies to operators whose GGR remains below EUR 100,000, while operators with GGR exceeding EUR 50,000,000 will be charged an annual fee of EUR 434,000. Gambling license holders are also subject to a gambling tax of 22 % on profits.

Supervision and Sanctions

Under the original supervisory arrangement, the NPB was to act as the supervisory authority until the end of 2026, after which the new Finnish Supervisory Agency would assume responsibility. As the overall timetable for license applications and the commencement of operations has been postponed, the transfer of supervisory authority has likewise been delayed, and the Finnish Supervisory Agency is now scheduled to assume responsibility for gambling-related supervision on 1 July 2027. The main tool for the supervision will be license holders’ annual reporting obligations. License holders must provide sufficient information on their financials, marketing activities, and gambling operations on an annual basis.  

The new licensing system aims to channel players towards licensed gambling services and away from unregulated operators. To support this objective, regulatory supervision is expected to be proactive and enforcement-oriented. Sanctions available to the authorities include administrative penalty payments, blocking or removal of domains and marketing content, license revocation, and where applicable, criminal liability.

Aside from criminal liability, license revocation is the most severe sanction, as it requires the operator to cease all licensed gambling activities in Finland. In practice, license revocation is reserved for the most serious breaches of the Gambling Act. The latest legislative updates have clarified the circumstances under which a gambling license may be revoked. In most cases, revocation now requires that the license holder intentionally continues to breach its regulatory obligations after an administrative sanction has already been imposed.

Final Remarks

The Gambling Act has now been adopted, with the first provisions entering into force on 1 March 2026. Licensed gambling operators may begin their operations and marketing activities as of 1 July 2027. This date also marks the point from which gambling software applications may be submitted.  

Regardless of the type of license sought, obtaining a license requires extensive documentation demonstrating the applicant’s planned operations, governance structure, and the entities responsible for the business. A successful application process requires a comprehensive understanding of the Gambling Act as a whole. Once a license has been granted, regulatory obligations must be complied with throughout the term of the license.

The new Finnish framework creates opportunities for new commercial partnerships within the gambling market. Holding a gambling license early on signals trustworthiness and a clearly defined business strategy, both of which are central in partnership negotiations and customer communications.

Nordic Law has closely followed and participated in the legislative reform process and has in-depth expertise in the gambling industry and Finnish licensing procedures. We welcome any discussion on the new Finnish gambling market and its key regulatory considerations.