Ukraine has closed its application window to compete for the stewardship of state-run lottery licences.

The closure was announced by PlayCity, which continues to operate as Ukraine’s gambling and lottery regulator amidst the ongoing war in the country following Russia’s 2022 invasion.

In December, the Ministry of Digital Transformation (MDT) confirmed it would begin reviewing applications to relaunch the Ukrainian lottery market, with the tender process formally managed by PlayCity. The application deadline expired on 29 December, with three incumbent operators submitting bids.

PlayCity confirmed that LLC MSL, FDI Ukrainian National Lottery (UNL) and PrJSC Patriot all applied for licences under the current competition, signalling that the process is expected to preserve market continuity rather than introduce new entrants.

However, the applications submitted by MSL (Molod’ Sport Loto) and Patriot may surprise some observers, as both operators were implicated in Russian-linked money-laundering scandals in 2015 which led the Ukrainian government at the time to suspend the lottery market and initiate a broader regulatory reset.

PlayCity Director Gennady Novikov acknowledged that current legislation limits the scope for attracting new operators at this stage. He acknowledged that the current tender is shaped by legal and wartime constraints, limiting the scope for market expansion. 

“Therefore, licences will be issued not for 10 years, but for the period of martial law plus one year, but no more than three,” Novikov said.

He added: “This gives the Ministry of Digital Transformation and Parliament time to review the regulation of the lottery market, propose new rules, and re-license the market using an updated approach, including the possibility of attracting international companies.”

The tender also represents a regulatory reset, as lottery operators have effectively operated without licence fees for more than a decade following the expiry of Ministry of Finance-issued licences in 2013–2014. 

Under the original concession terms, applicants were required to demonstrate at least three years’ operational experience in the lottery or gaming market, operate a website registered within the .ua domain zone, maintain minimum authorised capital of ₴30m (approximately €700,000), and confirm no direct or indirect ownership, control or affiliation with the aggressor country.

The constrained nature of the process had been flagged in advance by the Eastern European and CIS advisory 4H Agency, which noted that the tender conditions and application framework were likely to be reviewed.

While the relaunch of lottery concessions would typically attract foreign investor interest, the advisory cautioned that “the extremely tight submission window from 1-29 December — makes it highly unlikely that they will be able to prepare compliant bids in time. Realistically, the market will be defined by three domestic firms that can act quickly.”

Since February 2025, gambling policy in Ukraine has been coordinated by the Ministry of Digital Transformation. In March, the Cabinet of Ministers approved the establishment of PlayCity as a new central executive authority, formally replacing the former gambling regulator KRAL from 1 April.

Entering 2026, former gambling licence holders have called on PlayCity and the MDT to review previous market suspensions stemming from investigations conducted by the State Bureau of Investigation (SBI).

Operators have argued that the suspensions were unfair, claiming the investigations were discriminatory and based on findings that certain financial transactions were deemed to be complicit in Russian interference within Ukraine’s financial system.