Finnish Gambling System Reform Is Underway — Part III — How To Apply For A Licence?

We have previously published two blog posts, (here and here) where we reported that the Finnish Government is planning to reform the gambling system and open it to competition under a licence model from January 2026. A Government Bill has been published, and we now have a more detailed understanding of the proposed changes. In the Government Bill, a transition from an exclusive rights system to a licence-based model is proposed. The proposed licensing system means that, as of 1 January 2026, a licence may be applied for and, if granted, it is possible to engage in gambling activities in Finland.

There are three types of licences proposed under the new system: exclusive licence (Fi: "yksinoikeustoimilupa"), gambling game licence (Fi: "rahapelitoimilupa"), and game software licence (Fi: peliohjelmistotoimilupa").

I. Requirements for Obtaining a Licence

The requirements for obtaining a licence are based on criteria laid down in the proposed Gambling Act. If the requirements for granting a licence are met, the supervisory authority should grant the licence. The requirements emphasise the operator's reliability, technical capabilities, and financial stability.

a. Exclusive Licence

An exclusive licence may only be granted to a limited liability company under state control whose business is the operation of gambling. The exclusive licence would be granted for ten years and restricted to a single operator, meaning in practice Veikkaus Oy. With an exclusive licence, the holder may operate with money lotteries and betting games, as well as slot machines and casino games. In addition, it has been proposed that physical slot machines be included in the exclusive operating licence.

b. Gambling Game Licence and Game Software Licence

A gambling game licence and game software licence may be granted to a natural person or legal entity residing in the European Economic Area (EEA) for up to five years. If the licence applicant is located in a third country, it must have a representative in the EEA. If the licence applicant is a legal entity, the reliability and suitability requirements will also apply to the applicant's significant owners and executive management.

A gambling game licence could be granted for fixed-odds betting, pool betting, virtual betting, online casino games, online bingo, and online slot machine games.Gambling game licence holders would operate in a competitive gambling market.

A gaming software licence should be obtained by entities that develop, supply, install, or adapt gaming software. Such entities may include gaming companies, system providers, aggregators, and game studios. Gaming software is used in electronic slot and casino games, lottery games, and betting games. A holder of a gaming software licence must not supply gaming software to a gambling operator who does not have the licence required under the law.

The conditions for obtaining a licence vary depending on the type of licence applied for. The granting of an exclusive licence and a gambling game licence requires that the applicant is reliable and suitable for operating gambling games. The granting of a game software licence requires that the applicant is reliable and suitable for manufacturing, delivering, installing, or adapting gaming software used in the operation of gambling. An applicant is required to demonstrate reliability and suitability in terms of financial operating conditions. The applicant must not be bankrupt and must have sufficient assets to ensure the operation of the business and the fulfilment of its statutory obligations. The fulfilment of these requirements is assessed on the basis of, among other things, solvency and leverage. An applicant who has been convicted of a serious crime, has neglected tax or payment obligations, has previously been subject to prohibitions or penalties for gambling activities, has provided false information to the authorities, or is on a sanctions list cannot be considered reliable or suitable and can therefore lead to the application being rejected. All applicants for all types of licences must ensure that the gaming systems, drawing devices, and drawing methods used in the operation of gambling are reliable and that the results of the draws are random. In addition, the licence holder is obliged to protect players from the harmful effects of gambling, guarantee the legal protection of players, and seek to prevent abuse and crime related to gambling. These factors are taken into consideration when the supervisory authority assesses the applicant's suitability.

II. Information to Be Provided in the Application

All licences must be applied for in writing from the supervisory authority. The National Police Board of Finland will temporarily act as the supervisory authority during the transitional period until the end of 2026. Starting from 1 January 2027, the supervisory responsibilities will be transferred to the Finnish Supervisory Agency (Fi: "Lupa- ja valvontavirasto"). The application must contain comprehensive information about the applicant, on the basis of which the supervisory authority considers whether the conditions for granting a licence are met. The licence application can be submitted in Finnish or Swedish.

The information required in the application and its appendices is listed in Section 11 of the proposed Gambling Act. The licence application must contain comprehensive information about the applicant and the planned gambling operations. The application must, for example, include the applicant's identification details, legal form, ownership and management structure, financial situation, any business prohibitions, and criminal records. In addition, the application for exclusive licence or gambling game licence must describe the forms of gambling, game software providers, marketing plans, representatives if operators are outside the EEA, the use of agents, and procedures for handling customer complaints, plans on preventing competition manipulation, and plans for combating money laundering. The applications should be diligently drafted so that all required information is included.

The applicant must provide additional information if the supervisory authority requires further details on the content of the application and the attachments. The applicant should also notify the supervisory authority without delay of any changes to the information provided in the application.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.