Finland’s Gambling Act Reform: A Practical Guide to the New Licensing Regime

Finland's gambling market reached a defining milestone on 1 March 2026, when certain provisions of the new Gambling Act (10/2026) entered into force ­– specifically Chapters 2 and 9, Sections 43(3), 44, 57, 63 and 64 – enabling gambling companies to begin applying for gambling licences from the National Police Board. The provision of licensed gambling services can begin on 1 July 2027, when the Act in its entirety will enter into force. The reform opens betting games, online slot and casino games, and online money bingo to competition under a licensing system. This marks a partial end to the decades-long monopoly held by Veikkaus Oy, which will retain a monopoly on lottery-type games, scratch cards, and all physical slot machine and casino games. The National Police Board will act as the licensing authority until the end of June 2027, after which the Finnish Supervisory Agency will become the competent authority.

The reform follows a path already taken by Denmark (2012) and Sweden (2019), combining monopoly and competitive market elements. The aim of the reform is to prevent and reduce gambling-related harms while improving the channelling of gambling activity within a national legislative and supervisory framework. Currently, numerous companies operating outside the Finnish monopoly system offer online gambling games to Mainland Finland that are not subject to national regulation and supervision, and whose profits are not subject to Finnish taxation.

For operators considering entry into the Finnish gambling market, this article provides a practical overview of the licensing framework, the application process, key compliance obligations, and early observations from the first wave of applications.

Since the application window opened, the National Police Board has received 41 gambling licence applications. Prior to the opening of the application window, the Board noted that similar reforms in other Nordic countries have resulted in a few dozen applications, and that corresponding numbers could be expected in Finland.¹ Other market operators have similarly estimated that the Finnish market could attract between 40 and 60 licensed gambling companies upon the market opening.²
 
Based on the application data received from the National Police Board, the majority of applicants are registered outside Finland, with Malta being the most common jurisdiction of registration. In terms of the planned gambling implementations selected by the applicants, online casino games and online slot machine games have been included in every single application reviewed by the authors at the time of this publication.
 
These early figures suggest strong commercial interest and a market that is likely to be competitive from the outset. Operators that have not yet submitted an application should bear in mind that the National Police Board’s target processing time is 3–6 months, though the Board has noted that incomplete applications may take longer. Given the 1 July 2027 operational start date, timely submission of a well-prepared application is essential.

The new gambling system introduces three types of licences:

Gambling software licence (peliohjelmistotoimilupa) is required for entities that develop, supply, install, or adapt gambling software used in licensed gambling operations. Applications will be accepted from 1 July 2027, and from 1 July 2028, licence holders may only use software from licensed gambling software providers. The licence is granted for up to five years at a time and is renewable.

Exclusive licence (yksinoikeustoimilupa) is reserved for a state-controlled limited liability company (in practice, Veikkaus Oy) and covers lottery games, scratch cards, slot machines and casino games. Granted for up to ten years.

Gambling licence (rahapelitoimilupa) authorises a natural or legal person to offer gambling services, specifically fixed-odds betting, variable-odds betting, virtual betting, online casino games (such as roulette, card and dice games), online slot machines, and online money bingo to the public in Finland. The licence is granted for up to five years at a time and is renewable.

Both gambling and gambling software licences may be granted to any natural or legal person, including non-profit organisations, provided that the applicant meets the fitness and propriety criteria set out in Section 10 of the Gambling Act. Applicants established outside the European Economic Area (EEA) must appoint a representative within the EEA, who must likewise satisfy the Section 10 criteria.

Under Section 10, an applicant must be reliable and suitable for operating gambling activities (or, in the case of a gambling software licence, for manufacturing, supplying, installing or adapting gambling software). An applicant will not be considered fit if they:

Where the applicant is a legal person, these criteria also apply to its board members and deputy members, executive management, and any person holding directly or indirectly at least 25% of the shares or corresponding voting rights, or equivalent ownership or control in entities other than limited liability companies. In assessing the fitness and propriety of the applicant's owners and management, the licensing authority may also take into account relevant circumstances relating to other companies or entities that are directly or indirectly connected to the applicant or the persons referred to above.

Gambling licence applications must be submitted in writing, in Finnish or Swedish, to the National Police Board, which acts as the supervisory authority until the end of June 2027. From 1 July 2027, the Finnish Supervisory Agency (in Finnish: Lupa- ja valvontavirasto) will assume licensing and supervisory responsibilities. Applications may be submitted via online service, by email, or by post, but submission through the Regional State Administration’s online service is recommended.

Gambling software licence applications will be accepted from 1 July 2027 by the Finnish Supervisory Agency, and the obligation to use only software from licensed gambling software suppliers will apply from 1 July 2028.

Section 11 of the Gambling Act sets out a comprehensive list of information required in the application. At a minimum, all licence applications (gambling, exclusive, and gambling software) must include:

In addition, gambling licence and exclusive licence applications specifically must include:

The supervisory authority may request additional information and may issue more detailed regulations on the content, format, and attachments of licence applications.

Once licensed, operators must comply with a comprehensive set of obligations under the Gambling Act. These span player protection, responsible gambling, marketing restrictions, anti-money laundering and KYC procedures, technical and data reporting requirements, and ongoing supervisory obligations.

Below, we provide an overview of three areas that are likely to require the most operational planning: player protection and marketing requirements, followed by the supervisory framework and sanctions regime.

Player protection is central to the new regime, and licence holders are required to offer gambling services in a manner that minimises any gambling-related harm. The legal gambling age remains 18, and every player must be registered and authenticated using strong identity verification before participating in any gambling activity.

Operators must provide players with the ability to set self-exclusion bans through a centralised system covering all licensed operators. Self-exclusion bans set for an indefinite period remain in force for at least one year. In addition to the centralised system, each licence holder must offer players the ability to set bans and restrictions on the operator's own game offering or parts thereof.

Under the duty of care set out in Section 34 of the Gambling Act, operators must ensure that social and health considerations are observed in gambling, protect players from excessive gambling, and assist them in reducing their gambling where warranted. This includes an obligation to continuously monitor and assess player behaviour, and to evaluate the risk of gambling harm through automated processing of personal data. Under Section 36 of the Act, operators are permitted to process personal data of their customers and their gambling activity where strictly necessary for ensuring players' legal protection, preventing and investigating abuse and crime, or preventing and reducing gambling harm. Where risks are identified, operators must take appropriate action to prevent and reduce harm. Notably, a decision to restrict or block a player's gambling may not be based solely on automated processing. Operators must also establish contact procedures for situations where harmful gambling is identified or suspected and must document all contacts made with players in this context.

Marketing of gambling services must be moderate in volume, scope, visibility, and frequency. The Act defines an exhaustive list of permitted marketing channels: the operator's own website and social media accounts (on a non-interactive basis), television and radio, sports and other public events, print media and equivalent digital publications, gaming premises (for games available at that location), and search engine advertising using keywords directly related to the operator or its games. Marketing through any channel not expressly listed, including affiliate and influencer marketing, is prohibited.

All direct marketing requires the explicit prior consent of the recipient, and telephone direct marketing is prohibited. Marketing may not be directed at persons who have self-excluded or who have not played the operator's games in the preceding two years.

The Act sets out an extensive list of prohibited marketing practices, including depicting gambling as desirable or as a solution to financial problems, misrepresenting winning probabilities, normalising gambling as part of everyday life, and offering games for free or at a discount. Marketing is also not allowed to target minors or persons in a vulnerable position, and must include the legal gambling age, information on responsible gambling support services, and the operator's licence and supervisory authority details.

Outdoor advertising is permitted, but gambling licence holders may not place it near schools, early childhood education premises, secondary education institutions, pharmacies, healthcare facilities, or substance abuse treatment units. Slot machines and casino games may only be marketed within their physical gaming locations.

Sponsorship is permitted but must not promote the operator's gambling products. Sponsorship agreements may not be entered into with persons under 18 or in connection with events, competitions, leagues, or similar occasions involving minors. Operators must also ensure that their name or logo does not appear on products or services specifically intended for persons under 18 and may not enter into sponsorship agreements with persons who produce content directed at minors.

As of 1 July 2027, the competent supervisory authority will be the new Finnish Supervisory Agency (Lupa- ja valvontavirasto). The National Police Board will act as the licensing authority until 30 June 2027.

The supervisory authority will have broad powers to supervise gambling services, including technical monitoring of games and player account transactions and extensive rights of access to information and inspection. Licence holders must also submit annual reports on their gambling services. All gambling licence holders will pay an annual supervision fee ranging from EUR 4,000 to EUR 434,000 based on gaming revenue. For gambling software licence holders, the fee is EUR 1,500.

The authority may impose administrative fines of EUR 1,000 to EUR 100,000 for breach or neglect of the obligations laid down in the Gambling Act, as well as penalty payments of up to 4% of the previous year's turnover (capped at EUR 5,000,000, minimum EUR 10,000) for more serious infractions. As a last resort, a licence may be revoked where an operator has intentionally continued to breach its obligations after a sanction has already been imposed. Certain violations of the Gambling Act are also punishable under the Criminal Code.

To address illegal gambling and marketing outside the licensed system, the supervisory authority may also issue injunctions enforceable by conditional fines. All decisions on injunctions against marketing or game running, administrative fines, penalty payments, and licence withdrawals will be public.

With 41 applications already filed, prospective operators should act without delay. The National Police Board's target processing time is 3–6 months, though incomplete applications may take longer. A well-prepared application submitted in 2026 is the clearest path to being operational when the market opens on 1 July 2027.

In parallel, operators should be building out their compliance frameworks, including player identification and age verification, self-exclusion register integration, responsible gambling tools, and marketing policies that meet the Act's requirements. On the technical side, operators will need to prepare for the regulator's data reporting obligations, including the OCSS cryptographic signing system required under the National Police Board's binding regulations.

The software supply chain also deserves early attention. Licensed gambling operators will go live in July 2027 using gambling software from suppliers who will not yet hold gambling software licences, as the obligation to only use gambling software provided by licensed providers takes effect from 1 July 2028. Planning ahead for that transition is advisable.

Finland represents a rare opportunity for gambling companies: a digitally mature, high-spending Nordic market opening to regulated competition for the first time. Operators that prepare thoroughly now will be best positioned to launch effectively from day one.

If you would like to discuss how the new framework applies to your business, please do not hesitate to contact our Commercial Contracts team.