Finnish Gambling System Reform – Part VI – Sanctions & Dispute Resolution

In our blog series regarding the Finnish gambling system reform, we have previously published five blogs (Part I, Part II, Part III, Part IV and Part V), where we reported that the Finnish Government was reforming the gambling system and opening it to competition under a licence-based model. In our last blog post, we focused on possible tax implications of the gambling reform. In this post, we turn our attention to the content of the new Gambling Act concerning sanctions and dispute resolution.

Since the publication of our latest blog, the President of the Republic of Finland has confirmed the new Gambling Act on 16 January 2026.

The new Gambling Act introduces a new framework for sanctions and dispute resolution mechanisms intended to ensure regulatory compliance while also protecting player rights. The legislation provides for different administrative sanctions including prohibition of gambling operations and marketing, licence revocation, publication of decisions, and administrative payments.

Consumer Disputes

From a consumer protection perspective, licensed operators must establish procedures for handling disputes and complaints with sufficient personnel. Exclusive and gambling game licence holders must be able to present these procedures to the Finnish Supervisory Agency upon request.

The dispute resolution process follows a (voluntary) two-tier approach. Players first approach the gaming company, which must respond within a reasonable time and provide written responses upon request. The company must process payout claims and explain either the basis for payment or reasons for refusal. According to the Government Bill, written responses should also inform players of their right to seek a resolution from the Consumer Disputes Board.

If disputes remain unresolved, players may approach the Consumer Disputes Board, an independent and impartial legal protection body. The Board provides resolution recommendations for consumer disputes, initiated by written or electronic application. During the preparation of the matter, efforts should be made to reach a settlement and, if necessary, a proposal to facilitate this should be made.

Importantly, decisions of the Consumer Disputes Board are not enforceable, lack the same legal effects as court judgments, and cannot be appealed. No fees are charged for investigation and processing at the Consumer Disputes Board. Board proceedings do not prevent matters from being brought before general courts.

Administrative Sanctions for Licensed Operators

Prohibition of Operations and Marketing

The Finnish Supervisory Agency may prohibit the marketing of gambling based on the new Gambling Act. The same applies to the provision of gambling services for reasons specified in the Act, such as providing gambling services without the required licence or failing to comply with the player registration requirements prescribed by the Act. This prohibition may be directed at:

• exclusive licence holders and gambling licence holders,
• gambling operators,
• businesses or entities that transmit participation notifications or payments related to gambling, provide, premises for the use of gambling machines, or market gambling,
• natural persons who, for financial or other benefit, market gambling or otherwise promote participation in gambling.

The prohibition is valid for a maximum duration of 12 months. The Finnish Supervisory Agency may extend the validity period of the prohibition by a maximum of 12 months at a time if the practice in the provision or marketing of gambling has not been corrected.

Additionally, the Finnish Supervisory Agency may temporarily prohibit gambling operations if player legal protection or gambling supervision would be endangered, the possibility of abuse would increase, or the reliability of draws would otherwise be compromised. In exceptional situations, a prohibition decision may be issued ex parte. The temporary prohibition may be valid for a maximum of 30 days at a time, and the Finnish Supervisory Agency must revoke it once the grounds for its validity no longer exist. The Finnish Supervisory Agency may impose a conditional fine to enforce any prohibition.

In addition to the prohibition orders discussed above, the Finnish Supervisory Agency may, if necessary to terminate activities contrary to the Gambling Act:

• order a service provider to remove online content concerning the provision or marketing of gambling,
• order a domain name registry maintainer or domain name registrar to remove a domain name from the domain name registry.

Licence Revocation

Licence revocation represents the most severe administrative measure under the Gambling Act. There are three different situations under the Gambling Act based on which a licence is revoked. The Agency shall revoke a licence if the licence holder requests it, or if the licence holder no longer fulfils the requirements set for it by the Act. Additionally, in the case of an exclusive licence holder, licence revocation occurs if the holder has not paid the statutory payment to the state for the exclusive licence.

The Finnish Supervisory Agency may, however, revoke a licence at its discretion in the following situations:

• the licence holder has repeatedly or seriously violated the provisions of the Gambling Act or regulations and orders issued under it,
• the licence holder has provided the supervisory authority with false or misleading information about a matter that was likely to materially affect the granting of the licence, or has concealed such a matter,
• the licence holder fails to pay the supervisory fee under the Gambling Act,
• the licence holder has, during the validity period of the licence, repeatedly or seriously violated provisions on preventing money laundering and terrorist financing and has been imposed an administrative sanction as a result of the violation, or the licence holder has been sentenced to a fine or imprisonment as a result of the violation.

Additionally, the provision requires that, before revoking the licence and following an administrative sanction, the licence holder has intentionally continued the prohibited practice. Furthermore, before licence revocation, the Act requires that the licence holder is given a reasonable time to correct deficiencies. As can be interpreted from the provision itself, licence revocation can be considered a measure of last resort. In practice, this means that the authority must use other administrative sanctions before licence revocation should be considered.

Punitive Administrative and Criminal Sanctions

The new legislation also introduces administrative payments and penalty payments as punitive administrative sanctions.

Administrative payments apply where violations do not require sanctions, but administrative guidance would be insufficient, targeting less serious, precisely specified violations, and are lower in amount than penalty payments. The section of the Gambling Act concerning administrative payments lists 15 different situations in which the Finnish Supervisory Agency may impose an administrative payment, provided that the licence holder or business has acted intentionally or negligently. Such situations include, among others, failure to comply with various information disclosure obligations and reporting obligations under the Gambling Act. The amount of the administrative payment to be imposed is based on a comprehensive assessment. When assessing the amount of the administrative payment, the nature, scope and duration of the practice must be taken into account. In any case, the administrative payment is at least EUR 1,000 and at most EUR 100,000.

Penalty payments, on the other hand, would apply in situations where the basis would be a violation of the Gambling Act that is not considered minor. These sanctions represent the strictest administrative punitive action for highly reprehensible acts that might even fulfil elements of criminal offenses. According to the Act, a penalty payment may be imposed on a licence holder, business, or natural person who intentionally or negligently violates or fails to comply with certain specifically listed provisions of the Gambling Act. In total, the Act lists 37 such provisions. These provisions concern, for instance, violations and omissions related to the provision of gambling, violations and omissions related to the marketing of gambling, failure to pay the supervisory fee, and violations on the Act's prohibitions against providing or marketing gambling without the licence required by said Act. It is noteworthy that according to the Government Bill, the penalty payment may also be imposed on an agent of a gambling company.

Regarding the amount, the Act requires a comprehensive assessment that takes into account:

1. the nature, scope, reprehensibility, and duration of the violation,
2. the benefit obtained from the violation, if this information is available,
3. the actions taken by the subject of the penalty payment to mitigate or remedy the damage,
4. any previous violations related to the provisions of the Act by the subject of the penalty payment.

A penalty payment imposed on a legal person may be a maximum of four percent of the turnover for the year preceding the end of the violation in question, or the corresponding turnover, however, a maximum of EUR 5 million. However, the penalty payment must be at least EUR 10,000. A penalty payment imposed on a natural person may be a maximum of four percent of their income according to the taxation carried out in the year preceding the end of the violation, however, a maximum of EUR 40,000. In any case, for a natural person, penalty payment must be at least EUR 3,000.

Additionally, a noteworthy difference to the administrative payments is that the penalty payment is determined by the Finnish Market Court upon the proposal of the Finnish Supervisory Agency.

The Gambling Act also contains a reference to the Finnish Criminal Code, pursuant to which a person may be sentenced to a fine or imprisonment for a maximum of two years for a gambling offence. The Criminal Code defines gambling offences as including, inter alia, organising gambling without a licence required under the Gambling Act and offering or marketing gambling services abroad in violation of the Gambling Act. Notably, however, pursuant to the Gambling Act, a penalty payment may not be imposed if criminal proceedings concerning the same act are pending, under prosecutorial consideration, before a court, or have resulted in a criminal conviction. Conversely, if a penalty payment proceeding is pending or has been imposed, criminal charges may not be brought nor a conviction rendered in respect of the same matter.

These regulations are included to address the need to effectively manage potential unlawful activities in the new multi-operator market, implementing the Government program's objective of strengthening supervision through clear general deterring effects.

Publication of Sanctions

The Gambling Act also requires the Finnish Supervisory Agency to publish decisions concerning administrative payments, penalty payments, licence revocations, and prohibitions. The regulation also enables delayed publication and publishing decisions without naming subjects if considerations of reasonableness or the risk of jeopardising an official investigation so require.

Appeals and Legal Remedies

The Act provides appeal mechanisms to ensure legal protection, with the general rule being appeals to administrative courts governed by the Administrative Judicial Procedure Act. Those to whom decisions are directed, or whose rights, obligations, or interests are directly affected, may appeal. Decisions of the administrative courts may be appealed to the Supreme Administrative Court if leave to appeal is granted.

However, some of the Finnish Supervisory Agency's decisions should be brought before the Market Court. These would include decisions concerning the removal of unlawful online content and domain names as referred to in the Act, as well as marketing prohibitions, combined marketing and enforcement prohibitions under the Act, and conditional fines attached to them. According to the Gambling Act, appeals against Market Court decisions concerning penalty payments must be made to the Supreme Administrative Court. Since the Market Court would decide on the penalty payment as the first decision-making instance, the appeal permission regulation does not apply to appeals concerning the imposition of penalty payments. Therefore, no separate appeal permission is required to appeal the Market Court's decision concerning penalty payments.

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.