Finland published a proposal for new gambling legislation at the beginning of July. This was followed by a period of consultation, with the conclusions announced on November 1st, with the new legislation then submitted to the EU notification process.
The EU process takes 3-4 months, after which the law will return to Finland, where any necessary changes will be made. The aim is to submit the Bill to the Finnish Parliament for consideration and decision during the Spring of 2025, with the goal of parliamentary approval before Summer 2025.
The new legislation, in which part of the industry will remain in the monopoly system and part will move to a multi-licensing system, will become law on January 1st, 2026, when the licensing process can begin, with the law then coming into practice on July 1st, 2026 at the earliest and January 1st, 2027 at the latest.
The future monopoly will be based on an exclusive license, granted to a company under the direct control of the Finnish state. An exclusive license is valid for 10 years, with a gambling license valid for only five years.
According to the updated Bill, there will now be two exclusive licenses – one entitling the operation of lottery games and scratch cards and the other for physical casino operations, including slot machines located around Finland.
Exclusive licenses can be granted to the same company, and it is assumed that, at least initially, they will be given to the state-owned, current monopoly company, Veikkaus.
A five-year gambling license can be granted for fixed-odds and pool-based betting, virtual betting, digital casino games, digital bingo and digital slot machine games. In terms of betting, a license can be granted for betting games implemented both via digital and physical sales channels. Fixed-odds and pool-based betting could also include horse betting.
The change to the earlier Bill proposal is the transfer of pool-based horse betting from a monopoly to a multi-license system. Finland has reached a solution where one gambling license can be used to operate all gambling areas included in the license, so there will be no separate licenses for product sectors.
A number of further amendments were made to operating requirements and restrictions, covering the usual areas of player protection, financial transparency, marketing, sponsorship and bonuses.
Significantly, the new Bill prohibits the use of affiliates, stating that only marketing on the license holder’s own website and social media accounts will be allowed. In addition, the licensed company must ensure that third parties do not have the opportunity to distribute or resend publications.
Proposals on payment and IP blocking have been removed from the Bill. However, the Bill does state that after the law enters into force, operation of the market will be monitored, and the need for payment and IP blocking will be assessed again.
No licenses will be granted to applicants that have had, during the two years before the assessment, been issued a prohibition order or been fined for the implementation or marketing of gambling in violation of the current Lotteries Act.
Finally, all licensees must use gambling software supplied by holders of the Game Software License. These B2B license holders must also not supply software to an operator who operates or markets gambling without a Finnish license. B2B licenses can be applied for at the beginning of 2027, and the requirement to use a B2B license will come into effect from the beginning of 2028.
Writing on behalf of Finnplay, Jari Vähänen of The Finnish Gambling Consultants says that the ban on using affiliates is a mistake: “In the new gambling system, this partner network commonly used by gambling companies remains a tool for gambling companies operating entirely without a license. “I believe that, especially in online casino operations, the channelization rate of the Finnish gambling system will, therefore, be much lower than expected.”
