Appeal from the Ukrainian Gambling Business Association
The Ukrainian Gambling Business Association has written to Prime Minister Svyrdenko, expressing concern over a draft government resolution that would completely ban military personnel from gambling. The association argues that such a measure could increase cybersecurity risks by exposing servicemembers' data, fail to address gambling addiction, and drive players toward illegal platforms linked to the Russian Federation. This proposal comes as Ukraine continues its efforts to regulate its gambling market, which was legalized in 2020 after a long ban.
A draft Cabinet of Ministers resolution, 'On Approval of the Procedure for Restricting the Participation of Military Personnel in Visiting Gambling Establishments and in Gambling,' was published for discussion on the Ministry of Digital Transformation's website on March 20, 2026. It proposes to completely block access to gambling for over 1 million servicemembers by verifying players against a military registry. To date, 34 'Play.City' licenses have been issued to gambling operators.
Identified Problems and Risks
The association warns that an outright ban does not eliminate demand. 'In the absence of legal access, this category of persons moves to the uncontrolled segment, primarily to illegal online resources. The majority of the illegal gambling segment has links to the Russian Federation as an aggressor state,' the association's letter stated.
Furthermore, a person's military status is sensitive information, creating additional database security risks. 'This is the key vulnerability of the proposed mechanism, as its implementation requires checking and comparing data that allows establishing a person's affiliation with military service,' the association emphasized.
The association has also developed and submitted alternative proposals to the Ministry of Digital Transformation. It believes effective regulation should be based not on a total ban, but on controlled, targeted mechanisms that minimize risks without pushing players into the illegal market.
- First, there is the security of databases containing the list of all the country's military personnel.
- Second, restrictions on a specific user category do not solve the problem of gambling addiction but merely displace demand into the illegal segment.
This situation highlights the need for a balanced approach to gambling regulation in Ukraine, especially concerning the military. Banning servicemembers' participation may not only fail to reduce the problem but could heighten risks related to cybersecurity and a shift to illegal resources. It is crucial for regulators to consider these factors when developing gambling policy and to seek effective solutions that ensure both safety and control in this sphere.
The implications of restricting gambling access for military personnel extend beyond individual choices, potentially affecting national security and state revenue. As highlighted in a recent analysis, the risks associated with such a ban could lead to an increase in unregulated gambling activities, undermining efforts to maintain a secure and profitable gambling market in Ukraine.