Ukraine lottery tender sets three-year license cap under martial law, all three current operators apply

All three current Ukrainian operators have submitted applications to participate in a new lottery licensing tender, the gambling regulator has announced. Lottery licenses issued under the competition will run for no more than three years under a temporary framework linked to martial law, according to PlayCity head Hennadiy Novikov.

The licensing competition, announced in early December by the State Agency for Gambling and Lottery Regulation of Ukraine, known as PlayCity, drew applications from all three incumbent lottery operators: M.S.L. LLC, Ukrainian National Lottery (UNL), and PJSC Patriot. No new operators submitted bids, after the application deadline expired on December 29.

License duration tied to wartime rules

Novikov said the tender will result in licenses issued for the period of martial law plus one year, with a maximum duration of three years, rather than the standard 10-year term. He said the limited timeframe is intended to allow state authorities to revise lottery market regulation.

"Therefore, licenses will be issued not for 10 years, but for the duration of martial law plus one year, though not exceeding three years,” said Novikov. “This gives the Ministry of Digital Transformation and parliament time to revise lottery market regulation, propose new rules, and relicense the market under an updated approach with the possibility of attracting international companies.”

He added that legislative restrictions make the entry of new operators unlikely under the current tender.

According to Novikov, the tender carries significance because lottery operators have effectively operated without paying license fees for more than a decade. Licenses previously issued by the Ministry of Finance expired in 2013–2014, leaving the market without updated authorizations.

Eligibility criteria remain extensive

Under the competition rules, applicants must maintain active, separate subdivisions in every Ukrainian city with a population exceeding 500,000. They are also required to operate lottery distribution points in every locality with more than 5,000 residents, with a nationwide total of at least 5,000 points of sale.

Other requirements include ownership of a domain name in the .UA domain zone, an electronic betting acceptance system, and no fewer than 5,000 operational electronic betting terminals owned by the applicant. Applicants must also demonstrate a cumulative minimum of three years’ experience in organizing and conducting state lotteries.

Since February 2025, state policy in the gambling sector has been shaped and coordinated by the Ministry of Digital Transformation. On March 21, the Cabinet of Ministers approved the creation of PlayCity as a new central executive body reporting to the ministry.

As of April 1, PlayCity replaced the former regulator, the Commission for the Regulation of Gambling and Lotteries, completing the transition to the current regulatory structure.