Ukraine’s gambling office PlayCity has published the official compliance criteria for lotteries operating on domestic soil.
Order 99 enforces a unified official form as part of the lottery inspection act, used to document the results of scheduled and unscheduled state checks which will be assessed against a number of criteria – covering both online and land-based lotteries.
The text details a checklist of requirements, covering aspects such as financial stability, technical integrity, and identification of key stakeholders.
Also outlined in the document are specific operational restrictions, including prohibition of activities in occupied territories, and the mandatory exclusion of casino-style visual elements.
Structure of reporting
The unified audit form explicitly states that PlayCity is the main lottery regulatory body.
Inspections will record metadata relating to the business entity, such as address, risk category, participating officials, as well as the inspection’s duration, whether it is scheduled or not, and the format itself – classified as check, review or survey.
PlayCity will record all detected violations, whether it is non-compliance or irregularities in the factual evidence.
Similarly, businesses will be able to use the form to report whether officials adhered to the correct procedure, such as issuing a 10 days’ notice or providing the required identification documents. A separate section will be used to produce written objections and evaluate the audit’s integrity on a scale from one to 10.
Regarding the inspection, it will be assessed through a number of compliance questions cross-referenced with Ukraine’s gambling framework, with non-compliance categorised into three levels – high, medium, and minor.
Base charter capital required
Lottery operators will be subjected to rigorous checks.
The level of their financial stability will be assessed based on their charter capital, which must be at least UAH 30m (£501,000) – with all cash required to be from verified sources. Total equity must be held above the charter capital baseline.
A minimum of 50% of all revenues from wagers must be dedicated to the prize pool under the legal provisions. Operators are also required to maintain an insurance in place to cover unpaid prizes in the event of bankruptcy.
Clear ownership structures
All companies, including company management, such as executives, chief accountants, major shareholders and ultimate beneficial owners must abide by strict reputation criteria.
These include not being a resident, citizen, or a controlled entity of an aggressor state, nor being a subject to international or national sanctions, or terrorist registries.
Trademarks, brands, or visual signs owned or previously used by entities linked to an aggressor state are strictly prohibited.
No slot-adjacent mechanics
Lottery operators are barred from using physical equipment or software that simulates slot machines, roulette wheels, dice and card games. All physical equipment put into exploitation must first pass technical conformity tests, have tamper-evident seals, and contain clear manufacturing and hardware ID data.
Furthermore, providers of lottery games must be connected to the central electronic betting system, recording all bets, refunds and payouts in real-time.
No-go locations and rigorous consumer protections
Lottery point-of-sales will be barred from government buildings, healthcare facilities, schools, libraries, museums, venues of religious significance, and residential housing.
Everywhere else, lottery products are required to contain clear 18+ messaging across tickets, websites, mobile apps and physical point-of-sales.
At least 5,000 locations for land-based lotteries
Land-based lottery operators will be expected to maintain at least one physical location in settlements with more than 5,000 residents.
For the whole of Ukraine, this mandatory requirement equals a minimum of 5,000 physical distribution points, with at least 5,000 active physical lottery terminals owned directly by the operator.
Online play limited to one website
For online operators, lottery distribution will be limited to one official website owned and managed directly by the operator. Online sales delegated to third-party intermediaries are prohibited.
The website must also be hosted on a .ua domain, with proof of domain licensing submitted to PlayCity.
Similarly, only one mobile application will be permitted per operator – covering both Android and iOS devices. A direct download link must be provided on the operator’s .ua website.
Operators must also publish mandatory public disclosures across all of their online presence, including metadata, terms and conditions, payout rules, steps to take during a system outage, and point of support contact, such as a dedicated customer service line, telephone number and an official email address.
Websites must also contain information about the addresses of all active physical points-of-sale, alongside a ticket verification feature that allows the entry of a ticket number to confirm its validity.
Exclusive rules under martial law
The document leaves some provisions out of being officially enforced during martial law, which Ukraine currently is under due to the conflict with Russia.
For example, the one distribution point per 5,000 inhabitants rule excludes active or past combat zones and occupied territories, with the 5,000 points nationwide completely suspended.
Moreover, the requirement to maintain a permanent physical location in every city exceeding 500,000 residents is also amended during wartime to exclude the war-affected territories.
The 5,000 physical lottery terminals requirement is also suspended during martial law, with no specific baseline enforced during inspections.
The inspections themselves will only be conducted in territories that are not affected by an ongoing conflict.
All other rules remain in force.