Finnish Gambling System Reform — Part VII — 8 Months to Launch

Authors: Vilhelm Schröder, Joel Ettanen Read time: 5 min

As the full entry into force of the new gambling system is getting closer, we take a look at some of the recent developments in the gambling industry.

The First Gambling Licences Have Been Granted — The Window to Apply Is Still Open

The Finnish National Police Board (the “NPB”) recently granted the first gambling licences. So far, the NPB has received over 70 applications for a gambling licence, and multiple licences have already been granted. The licences will enter into force on 1 July 2027.

Applying for a gambling licence and an exclusive licence from the NPB has been possible since 1 March 2026. Depending on the application, a gambling licence can grant its holder the right to provide various gambling services such as internet casino games and betting games. Offering of certain gambling games, namely the money lottery, draw games, slot machines, and casino games, remains possible only for the holder of an exclusive licence, which can only be granted to a limited liability company operating in the gambling industry and under the control of the state of Finland. In practice, this will leave the exclusive licence for Veikkaus Oy.

All licence holders must fulfil the criteria set out in the Finnish Gambling Act; for example, to be granted either a gambling licence or an exclusive licence, an applicant must be “fit and proper”. Processing an application will take at least six to eight months, according to the NPB. Thus, gambling operators wishing to enter the Finnish market straight from the get-go in July 2027 should submit their licence applications in Finnish or Swedish to the NPB without delay, if they have not already done so.

From the beginning of July 2027, it will also be possible to apply for a gambling software licence, and the licence will be mandatory in order to offer software in gambling services from 1 July 2028. Beginning from July 2027, applications for all licences should be submitted to the Supervisory Authority.

Prohibition on the Marketing of Gambling Games Issued by the NPB

Although the new gambling system has been approved in Finland, it will not enter into force before July 2027. The current legislation and the monopoly system remains relevant for the time being. Thus, the Lotteries Act permits offering gambling only through games run by Veikkaus Oy.

As a result, the NPB issued a foreign gambling operator a marketing ban with a conditional fine of EUR 1.2 million because of targeted marketing to Finnish consumers against the Lotteries Act. Foreign gambling sites being available on the internet and in Finnish is not, in itself, prohibited if they do not target Finland. However, the NPB saw that the gambling operator’s practices indicated that the marketing of its online gambling sites targeted Finland on websites and social media.

The marketing by the gambling operator was seen to target Finland because it was done in Finnish, as Finnish is only used widely in Finland. Additionally, the marketing included references to Finland and Finnish culture. Marketing was carried out on websites with names in Finnish, a “.fi” domain, or reference to well-known people in Finland. Furthermore, the marketing mentioned payment methods used in Finland.

Unlawful marketing can potentially affect the operator’s ability to obtain a licence in the future. Under the new Gambling Act, an applicant is not considered “fit and proper” — meaning that a licence cannot be granted — if the applicant has been issued an injunction or ordered to pay a penalty payment for operating or marketing gambling without a licence in violation of the Gambling Act within the three years preceding the evaluation. A similar but slightly shorter bar applies to violations of the Lotteries Act: an injunction or penalty payment imposed for unlawful operation or marketing of gambling under that Act disqualifies the applicant if issued within the two years preceding the evaluation, provided it was issued after 1 September 2024.

FCCA and THL Express Concerns About Gambling-Related Harm

Amid the gambling system reform, the Finnish Institute for Health and Welfare (“THL”) and the Finnish Competition and Consumer Authority (“FCCA”) have expressed their concerns about the possibly rising gambling-related harms under the new system. THL and FCCA call for multiple measures to strengthen regulation to protect players against these harms, even before the new Gambling Act is fully in force. Two of these concerns are especially relevant for gambling operators and are discussed below. Other measures include, for example, raising the minimum age for gambling to 20 and introducing lower spending limits for people under the age of 24.

Prior to the gambling system reform, the law contained a provision on blocking payment transactions to operators outside the licensing system. During the legislative process, provisions on blocking online access and payment transactions to operators outside the licensing system were considered but removed in the final government proposal. According to the government proposal, the functioning of the new gambling system would be followed and the need for such provisions would be assessed later on, taking into account factors such as technical practicabilities and cost effects for banks and internet operators. FCCA and THL are now both already suggesting the addition of these very provisions to prevent gambling-related harm better. FCCA states that if gambling outside the licence system cannot be effectively controlled, the regulation aiming at reducing gambling-related harm runs the risk of directing players outside the system.

In addition, FCCA and THL propose prohibiting gambling marketing on social media. The new Gambling Act contains provisions on the marketing of gambling services but does not prohibit social media marketing in its entirety, as long as it is carried out on the licence holder’s own social media account, it is not interactive with consumers, and it is otherwise moderate in amount, scope, visibility, and frequency. Marketing carried out by third parties on social media falls outside the permitted marketing channels and is therefore prohibited. However, a complete ban is now proposed based on the fact that gambling companies do not have full control over the visibility of the content they publish on social media, as some content may reach a wide audience due to algorithmic recommendations. Thus, it is argued, they cannot ensure that the marketing they carry out on their social media accounts would remain moderate.

Our IP & Technology Team is happy to advice on issues relating to the gambling system reform.