Finland has submitted legislative proposal HE 16/2025 vp, establishing a strict B2B licensing regime that will require all gambling software suppliers to obtain licenses by 2028. The proposal also confirms the legal separation of state monopoly Veikkaus Oy into competitive and monopoly entities.
The Finnish government’s new operational framework will transform the country’s gambling market when it launches on January 1, 2027, introducing mandatory licensing for both operators and software suppliers.
Legislative proposal HE 16/2025 vp establishes a dual-license structure that creates clear dependencies throughout the supply chain. Licensed operators will be prohibited from using software from unlicensed suppliers, a requirement that takes full effect by January 1, 2028.
Dual-License Structure Separates Operator and Supplier Requirements
The legislation creates two distinct license categories for the competitive market:
Gambling Game License (rahapelitoimilupa) for B2C operators offering online betting and casino games will become available in early 2026. These licenses carry a five-year validity period and subject operators to a 22% tax on Gross Gaming Revenue.
Game Software License (peliohjelmistotoimilupa) for B2B suppliers manufacturing, providing, installing, or modifying gambling software will open for applications in early 2027. Licensed operators cannot use software from unlicensed suppliers once the requirement becomes mandatory on January 1, 2028. These licenses also carry a five-year validity period.
The mandatory B2B licensing requirement represents a significant departure from most European regulatory frameworks, which focus primarily on operator licensing while allowing suppliers to self-certify or operate under less stringent oversight.
Supply Chain Implications for Market Entry
The 2028 deadline for mandatory supplier licensing creates a strategic decision point for game aggregators, platform providers, and content suppliers. Companies must evaluate whether Finland’s market size justifies the licensing investment and operational compliance costs.
Large international operators may have sufficient leverage to pressure their suppliers into obtaining Finnish licenses. Mid-tier operators face a more challenging position – if their preferred content providers choose not to pursue Finnish licensing, these operators could find themselves locked out of the market or forced to rebuild their game portfolios with compliant suppliers.
This closed-loop accountability system means operators cannot simply license themselves and assume their existing supplier relationships will transfer to the Finnish market. Due diligence on supplier licensing intentions becomes a critical component of market entry planning.
Veikkaus Oy Splits Into Separate Legal Entities
To comply with EU competition laws, the proposal confirms the separation of Veikkaus Oy’s operations into distinct legal entities within the same corporate group:
The monopoly entity will retain exclusive rights for the national lottery, physical slot machines, and land-based casinos under a 10-year license.
The competitive entity will operate as a separate company in the licensed online casino and betting market, competing under the same five-year license terms and 22% tax rate as private international operators.
This structural separation addresses longstanding EU concerns about state monopolies operating in competitive markets. The arrangement creates an interesting test case – whether a former monopoly operator can compete effectively against established private operators when operating under identical regulatory and tax conditions.
New Supervisory Authority to Oversee Licensed Market
The Finnish market will be overseen by a dedicated supervisory authority within the upcoming Lupa- ja valvontavirasto (Permit and Supervision Agency). The authority’s operations will be funded directly through industry supervision fees, shifting regulatory costs from taxpayers to market participants.
The legislative proposal provides operators and suppliers with clear timelines for market entry. B2C operator applications open in early 2026, while B2B supplier applications follow in early 2027, with the mandatory licensing requirement taking effect at the start of 2028.
Finland’s approach could establish a regulatory template for other Nordic markets considering licensing reforms. The mandatory B2B licensing component, in particular, represents a more comprehensive regulatory framework than most European jurisdictions currently employ.
Our Take
This mandatory B2B licensing creates a closed-loop accountability system rarely seen in European markets. Unlike other jurisdictions that focus primarily on operator licensing, Finland is building compliance requirements throughout the entire supply chain.
The 2028 deadline for mandatory supplier licensing gives the market just over two years to prepare. Game aggregators, platform providers, and content suppliers must decide now whether Finland’s market size justifies the licensing investment and operational costs.
Source: Finnish Government
