Ukraine Lottery Tender Draws Three Domestic Bidders

Ukraine has closed the application window for companies seeking to operate the country’s state-run lottery, with the tender attracting bids exclusively from domestic operators.

The closure was confirmed by PlayCity, which continues to act as Ukraine’s gambling and lottery regulator amid the ongoing conflict following Russia’s invasion in 2022. In December, the Ministry of Digital Transformation announced it would begin reviewing applications to relaunch the lottery market, with PlayCity formally overseeing the tender process. The deadline expired on 29 December.

PlayCity said three incumbent operators submitted applications: LLC MSL, Ukrainian National Lottery (UNL) and PrJSC Patriot. The outcome indicates that the relaunch is designed to maintain market continuity rather than introduce new or foreign entrants.

The inclusion of MSL and Patriot has raised eyebrows among some observers. Both companies were implicated in Russian-linked money-laundering investigations in 2015, which contributed to the suspension of Ukraine’s lottery market at the time and prompted a wider regulatory reset.

PlayCity director Gennady Novikov acknowledged that current legislation, combined with wartime conditions, significantly limits the scope for attracting new operators.

“As a result, licences will be issued not for ten years, but for the period of martial law plus one year, with a maximum duration of three years,” Novikov said.

He added that the shortened licence term would give the Ministry of Digital Transformation and Parliament time to review the regulatory framework, propose updated rules and potentially relicense the market under a revised approach, including the possibility of attracting international companies in the future.

The tender also represents a partial reset of lottery regulation. Operators have effectively operated without paying licence fees for more than a decade following the expiry of Ministry of Finance-issued licences in 2013 and 2014.

Under the current concession criteria, applicants must demonstrate at least three years of operational experience in the lottery or gaming sector, operate a website registered under the .ua domain, maintain minimum authorised capital of ?30m (approximately €700,000), and confirm there are no direct or indirect ownership or control links to the aggressor country.

Industry advisers had previously warned that the structure and timing of the tender would deter foreign participation. The narrow submission window, running from 1 to 29 December, was widely viewed as insufficient for international groups to prepare compliant bids, effectively limiting the contest to domestic firms able to 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 creation of PlayCity as a new central executive authority, formally replacing the former regulator KRAL from 1 April.

Entering 2026, former licence holders have called on PlayCity and the Ministry to revisit earlier market suspensions linked to investigations by the State Bureau of Investigation. Some operators continue to argue those actions were unfair, claiming the probes were discriminatory and based on disputed findings relating to alleged Russian financial influence.