The Association of Ukrainian Gambling Business Operators (AUOGB) appealed to state bodies with a call not to introduce strict fixed limits for legal iGaming.
RBC-Ukraine reported this, citing the AUOGB appeal published by Interfax-Ukraine.
In its letter to the Ministry of Digital Transformation, the Ministry of Finance, the Bureau of Economic Security, the State Tax Service, профильні committees of the Verkhovna Rada, and the PlayCity state agency, AUOGB says such restrictions will lead to an outflow of players to the shadow segment, a significant part of which has Russian origin.
"The proposed strict restrictions for legal gambling organizers will drive the industry into the shadows. The gambling market is a legal sector of the economy that annually provides more than UAH 17bn in budget revenues," the appeal says.
According to AUOGB, in 2024 and the first nine months of 2025 alone, legal operators paid almost UAH 31bn in taxes.
The Association is convinced that limits should be personal and risk-oriented, rather than strict and fixed.
Gambling business operators also proposed additionally increasing the limits on the time a player participates in gambling per week and per month.
They also pointed out that the Law “On Gambling” does not require setting any fixed limits or a “ceiling” for players. In the Association’s view, the proposed thresholds are unrealistic and encourage players to move to illegal casinos.
AUOGB calculated that if a limit of €1,000 per month is introduced, the budget could miss out on around UAH 5.6bn in taxes per year. In addition, it is projected that the result of introducing limits will be the shadowing of the industry — a shift of 30% to 50% of players to the illegal sector, which is controlled by Russians.
"We risk handing this sector over to shadow operators with our own hands. The new rules must work for the state and citizens, not for the growth of the shadow market," the letter says.
The association also points to international experience. According to its data, in EU countries with strict limits, the share of the shadow segment grew sharply — in particular, in Germany to 60–80%, and in Finland to 32–35%. At the same time, in countries with flexible limiting models, the shadow market remains minimal.
AUOGB President Oleksandr Kohut said the issue goes beyond economics.
"You see, Ukraine should not break a white industry with its ill-considered steps and повторювати the mistakes of European countries, where excessive regulatory restrictions led to a growing share of offshore gambling and the movement of citizens into the “grey” zone, where there are high risks of financial fraud and no protection of consumer rights," he said.
The Association calls on the regulator to finalize the draft order and abandon the introduction of strict fixed “ceilings,” and instead provide for personal player spending limits.
For her part, Deputy Minister of Digital Transformation Nataliia Denikieieva noted that the state must find a balance between protecting players and avoiding “overregulation.”
"On the one hand, we must protect the player — a citizen of Ukraine; on the other hand, we understand that any “overregulation” of the existing white legal market will encourage the player to move to the illegal segment and, as a consequence, reduce tax revenues," Denikieieva said.
Deputy Head of the PlayCity state agency Yuliia Zaichenko noted that limits should одновременно prevent gambling addiction and avoid encouraging players to move to the illegal market segment.
"We really want these limits not to lead to the gambling market going underground. But we also want them to serve as a safeguard against gambling addiction among citizens," she emphasized.
As a reminder, the introduction of limits is provided for by the draft order of the Ministry of Digital Transformation “On establishing limits on player spending on gambling and the time a player participates in gambling,” which has been published on the ministry’s website. The stated goal of the document is to combat ludomania.
At the same time, according to research by the National Health Service of Ukraine, gambling addiction in Ukraine does not have a mass character.
