Why The Ukranian Market Is Not Yet Ready For Foreign Players

The Ukrainian lottery market operated in a legal “gray zone” for 12 years, without effective oversight or license payments. The PlayCity competition radically changed the situation by selecting three operators — “M.S.L.”, “UNL.”, and “Patriot” — which have already transferred the first UAH 72 million to the state budget (on March 26, the company “Patriot” had its license revoked due to the ultimate beneficial owner not meeting legal requirements).

International companies did not participate due to fundamental barriers established by the 2012 law. It enshrines a model that allows for only three operators and requires three years of experience in conducting state lotteries specifically in Ukraine, as well as a well-developed distribution network. The competition itself did not impose restrictions - the licensing conditions were derived from the legislative framework.

Clear standards now apply to current operators: real-time electronic reporting, QR codes on every ticket and terminal, and annual payments of UAH 24.2 million. Licenses have been issued for the duration of martial law plus one year, but for no less than three years — a compromise that allows room for change without “freezing” the market. The closed format was a forced stabilization measure. After a decade of lack of control, the priority was to restore state oversight: introduce reporting, identification, and financial discipline.

Now the foundation is ready. The Ministry of Digital Transformation and PlayCity are preparing the second stage: updating the lottery law by lowering entry barriers, transitioning to open auctions, and opening the market to international competition. This is a systemic restructuring of the architecture from a closed model to a competitive environment. The lottery sector demonstrates the logic of phased reform: first stabilization, then expansion. The closed competition restored control and delivered the first payments, creating a basis for a qualitative leap. Ukraine is choosing a systemic path, avoiding the chaos of a “rapid opening.” Ahead lies a market with equal rules, where competition determines the winners and the state maximizes transparent turnover.

By Viktoriya Zakrevskaya