Proposal from Ukraine's Gambling Industry Association
The Ukrainian Gambling Business Association has presented the Ministry of Digital Transformation with a plan for a targeted, commander-assisted blocking mechanism for service members struggling with gambling addiction. This proposal serves as an alternative to a draft resolution from the Ministry, which would impose a total ban affecting over 1 million military personnel. Gambling regulation has been a contentious issue in Ukraine since its legalization in 2020, balancing industry growth with public health concerns.
On March 20, 2026, the Ministry published a draft Cabinet resolution titled 'On Approval of the Procedure for Restricting the Participation of Military Personnel in Visiting Gambling Establishments and Participating in Gambling Games.' This draft mandates a complete block on gambling access for all service members via registry synchronization. In response, the Association addressed a letter to Prime Minister Yulia Svyrydenko on April 3, 2026, advocating for an individualized approach to the issue.
Key Association Recommendations
The Ukrainian Gambling Business Association has put forward two primary recommendations:
- For the Cabinet of Ministers to establish a special procedure for applying additional restrictions on military personnel's participation in gambling for the duration of martial law.
- To grant the market regulator the direct authority, based on an application from a unit commander, to enter a service member's details into the registry of persons with restricted gambling access.
The Association believes a viable approach would involve commanders submitting information to apply an individual restriction or ban on a service member's gambling participation. They emphasize that any restriction procedure must define a mechanism for targeted, individualized access limits for personnel whose gambling negatively impacts duty performance, military discipline, or financial standing.
Regarding the current market, 34 'Play.City' licenses have been issued to gambling organizers. Estimates from Kantar, Gradus, and Factum indicate the illegal market segment constitutes between 39% and 53%. The legal sector's annual volume is estimated at approximately UAH 60 billion. Article 16 of Ukraine's Law 'On State Regulation of Activities Related to the Organization and Conduct of Gambling Games' provides for a mechanism to restrict gambling participation at the initiative of third parties, which could be utilized within the new targeted blocking framework.
The Association's proposed initiatives could significantly impact Ukraine's gambling landscape, particularly concerning service members facing addiction. A tailored approach to restricting access may help mitigate risks for military personnel while safeguarding their rights. It is crucial that any regulatory changes align with the needs and realities service members confront under current conditions. This underscores the necessity for continued dialogue between state bodies and the gambling industry to achieve shared regulatory goals.
As the debate over gambling regulations for military personnel intensifies, the Ukrainian government is considering measures to restrict access during wartime. This proposed targeted approach contrasts sharply with the blanket ban suggested in a recent draft resolution. To gain a comprehensive understanding of the implications of these changes, you can explore how the new restrictions aim to balance military welfare with the interests of the gambling industry in our detailed report on military access to gambling during wartime.