On Wednesday, July 3, we finally found out what kind of gambling legislation the Finnish government is planning for Finland. The published proposal has more than 400 pages, and I have only been familiar with it for a working day. So, my observations and opinions in this text are only preliminary, but I still want to share them with you. Finland has started the public hearing/consultation process, which will last until August 18. In principle, anyone can express their opinion on the bill during that time. According to the information I have received, this time, based on the consultation process, Finland is still ready to make changes to the gambling legislation. Because of this, it is not yet time to make assessments about how right the guesses I presented at the beginning of the year about the content of the law turned out to be in the end.
The schedule of the process has been specified. After the consultation process, changes are made to the law, after which the bill is sent to the EU notification process. After the EU notification, the proposal will proceed to the Finnish parliament in the spring of 2025, and the law is supposed to be approved during the next year. Part of the content of the bill will enter into force already in 2026, but in practice, Finland will switch to a partial license-based gambling system from the beginning of 2027. Some things will not be implemented until 2028, so there should be enough time for the preparation.
Monopoly and other licenses
In current Finnish legislation, Veikkaus' gambling monopoly is defined in law. In the new system, monopoly games will be granted an exclusive license for a period of ten years, which can only be given to a company under the direct control of the Finnish state, i.e., Veikkaus in practice. According to the proposal, the product areas covered by the monopoly are scratch cards (including eInstants), lottery games (e.g., lotto products and Keno), slot machines, physical casinos, and pool-based horse betting. The product areas that will be transferred to the license system are fixed odds betting (also includes horse racing), pool-based sports betting/games, digital casino games (roulette, craps, card games - poker), and digital slot machines and digital bingo. A gambling license is granted for five years.
In the list of monopoly products, pool-based horse betting, which accounts for 3-4 percent of all gambling in Finland, is the most surprising. It is not an important matter from the point of view of the whole, and therefore, keeping it within Veikkaus' monopoly is strange, especially when the horse racing industry would like to transfer the games to the licensing side. I'm sure it will be a hard-fought battle in the coming months. I guess that pool-based horse betting will eventually be moved to the license side, where pool-based sports games already are.
The price of the gambling license is tied to the size of the operator's gross gaming revenue. The minimum payment is 4000 euros, and the maximum price is 265000 euros if the GGR is over 50 M€/year. The gambling tax will be 22 % of the GGR.
B2B license in 2028
Finland also introduces the "Game software license." However, this license is not required immediately in connection with the change in the gambling system but from the beginning of 2028. The B2B license application process will be started at some point during 2027, and the license will be valid for five years. A game software license practically means that the license holder is obliged to use only the software and games of the game software license holder. The price of the license will be very affordable, i.e. only 1500 euros.
As a general rule, gambling IT systems must be located in Finland. There are two exceptions when IT systems can be somewhere else. If the supervisory authority of the country of location has a cooperation agreement with the Finnish supervisory authority, or the Finnish authority can verify the gambling IT system and its operation via a remote connection.
The supervising authority will issue all licenses. The current regulator, the National Police Board, is responsible for the legislation's practical preparation. Still, a new agency, the Finnish Supervisory Agency, will be established under the Ministry of Finance to supervise the new gambling system. The new agency will start operating at the beginning of 2027.
Marketing is allowed but limited
Gambling marketing is allowed, but there are restrictions. The law has a list of prohibited gambling marketing, such as describing gambling as a way to solve financial problems. Sports sponsorship is also allowed, but there will be restrictions related to minors.
Marketing regarding the brand gambling companies and games may only be done by the gambling company itself. The law states that no other entity may do marketing related to gambling. This will significantly complicate the position of affiliate operators. On the other hand, the definition of advertising and communication will be complex, thanks to which, at least in betting, affiliates will also find their place in the Finnish market.
Gambling services and sites must not use interactive marketing. That means companies cannot discuss gambling issues with customers on social media, and operators are not allowed to offer customers the possibility of forwarding the gambling company's publications.
Customers must give permission for direct marketing on their own initiative. The gambling terms must not automatically contain direct marketing permission, but they do require the active approval of the customers themselves.
The most interesting thing, and certainly one that receives a lot of criticism from current offshore companies, is the banning of bonuses. According to the law, gambling companies may not offer bonuses, either free games or games at a reduced price. In addition, the law has separately stated that using bonuses in all gambling marketing is prohibited.
Some other relevant matters of legislation
There is currently an option for payment blocking in Finland, which targets money transfers from Finland to gambling companies. In the new legislation, payment blocking is possible in both directions. Legislation has also specified that the blocking will also apply to cryptocurrencies, even though cryptocurrencies may not be used to pay for gambling at all. You also cannot pay for gambling with a credit card or buy it as a debt anyway. In addition to payment blocking, Finland can also implement network traffic blocking for gambling companies operating without a Finnish license.
There will be gambling company-specific money transfer limits, which the player must set (day and month) and can change. Those limits mean the amount of money that can be transferred from a bank account to a betting account. The state can set operator-specific maximum loss limits (daily, monthly, and annually) if it wishes, but this is not an automatic assumption.
The customer must have the option to set centralized prevention for all gambling, like Spellpaus in Sweden. In addition, the customer must be able to set himself a prevention for a particular gambling company's games or part of them (a specific game or group of games).
JARI VÄHÄNEN
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