Ukrainian gambling industry opposes fixed player limits

Ukraine’s gambling regulator faces warnings from industry representatives that fixed player caps could redirect 30–50% of users to illegal online casinos, many linked to Russian operators, according to the Association of Ukrainian Gambling Operators (AUGO).

The association, which represents the iGaming sector, outlined its position in a letter sent to state authorities involved in gambling oversight and enforcement. The document cautions that rigid spending and time limits for licensed casinos could move player activity away from regulated platforms.

“The proposed strict limitations for legal gambling operators will push the industry into the shadows… Regulatory changes should reduce the outflow of players to illegal operators, not the other way around,” the letter states.

The appeal was addressed to the Ministry of Digital Transformation, the State PlayCity Agency, the Ministry of Finance, the Bureau of Economic Security, the State Tax Service, and two committees of the Verkhovna Rada.

Budget exposure and market size

AUGO said the legal gambling market generates more than UAH 17 billion ($402 million) in annual budget revenue. The association warned that changes to player limits could affect tax collection if licensed operators lose users to unregulated platforms.

Based on analysis of data from licensed operators’ online systems, AUGO said the introduction of a €1,000 monthly cap per player could result in about UAH 5.6 billion in lost annual tax revenue. The association added that a significant share of displaced players could migrate to illegal casinos, many of which it said have Russian business origins and remain accessible in Ukraine.

Draft order and policy intent

The association referenced a draft order issued by the Ministry of Digital Transformation titled “On Establishing Limits on Player Spending on Gambling and Time Spent Participating in Gambling,” which was published on the ministry’s website. The stated purpose of the proposal is to address gambling addiction.

AUGO cited findings from Ukraine’s National Health Service indicating that gambling addiction does not have a widespread character in the country, despite high participation levels.

Limits model and legal basis

According to the association, spending and time limits should be personal and risk-based rather than fixed. It also called for higher weekly and monthly participation thresholds than those set out in the draft order, stating that current levels could redirect players to illegal casinos.

AUGO said the Law “On Gambling in Ukraine” does not require fixed player caps and argued that references to the law in the draft order are incorrect.

Financial monitoring approach

The Ministry of Finance has supported the draft order for financial monitoring purposes. AUGO responded that financial oversight should be addressed “through improved and proper implementation of financial monitoring mechanisms, not through administrative imposition of rigid spending and time limits on players.”

The association pointed to outcomes in other European markets where strict limits and advertising bans were adopted.

“In countries with harsh limits, the share of the shadow market has surged quickly (Germany – 60–80%, Finland – 32–35%, the Netherlands – 25–30%). Meanwhile, in countries with flexible or voluntary limit models, the shadow segment remains minimal (the UK – 1–2%, Denmark – around 9%),” the letter says.

AUGO President Oleksandr Kohut said the issue extends beyond market regulation.

“Ukraine should not break a functioning legal industry with ill-considered steps or repeat the mistakes of European countries. Otherwise, you will see 50,000–60,000 Ukrainians every quarter handing over their financial data to Russian casinos. The Russian gambling business not only operates in Ukraine but also cooperates with Russian security services to recruit Ukrainians,” Kohut said.