Industry association urges Ukrainian authorities to drop harsh limits on players, preserve legal gambling market
The Association of Ukrainian Gambling Operators (AUGO), the largest industry union representing the I-gaming sector, has appealed to state authorities to refrain from imposing strict fixed limits on players in legal casinos. The association warns that such restrictions would inevitably drive Ukrainian players en masse to illegal online casinos, many of which have Russian business origins, according to a letter sent to multiple government bodies with influence over the sector.
"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 document states. The letter, reviewed by the agency, is 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 relevant committees of the Verkhovna Rada.
According to AUGO, the market currently generates more than UAH 17 billion in annual budget revenues.
The association recalled that the introduction of player limits was included in a draft order by the Ministry of Digital Transformation, "On Establishing Limits on Player Spending on Gambling and Time Spent Participating in Gambling," published on the ministry's website. The main stated goal of introducing player limits is to combat gambling addiction, but according to the latest research conducted by Ukraine's National Health Service, despite the popularity of gambling, gambling addiction does not have a widespread character in Ukraine, AUGO asserts.
Association members argue that spending limits for players should be strictly personal and risk-based, not rigid and fixed as currently proposed. AUGO also proposes increasing the allowed weekly and monthly time limits for player participation, because the thresholds in the draft order are unrealistic and would push players toward illegal casinos.
The association believes the Law "On Gambling in Ukraine" does not require the establishment of fixed player limits or "caps," making the reference to the law in the draft order incorrect.
AUGO cites analysis of data from legal operators' online systems and claims that if a monthly limit of EUR 1,000 per player is imposed, Ukraine's budget would lose about UAH 5.6 billion in annual tax revenue, while 30–50% of players would migrate to the illegal sector, much of which is controlled by Russian entities, as many Russian gambling websites remain unblocked in Ukraine.
Regarding support for the draft order by the Ministry of Finance for financial monitoring purposes, AUGO argues that this issue 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 also states that strict limits and advertising bans in certain EU countries have led to growth of the shadow segment and rapid spread of crypto-casinos.
"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.
"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," said AUGO President Oleksandr Kohut.