Ukraine’s gambling regulator PlayCity has opened a tender for software that will block military personnel from using licensed gambling services, with the Ministry of Defence expecting the system in place by December 24, 2026 at the latest.
The procurement covers a module that checks a user against state registers at the point of account creation. If the check returns a match, the person is denied access to regulated gambling websites and licensed venues.
What the tender covers
The software sits on top of controls PlayCity already runs. Licensed operators are required to check players against the Register of Persons Restricted from Access to Gambling, which holds people who have been barred or who have self-excluded. Self-exclusion lets a person voluntarily block their own access for a set period.
The new module adds military status to that check and automates it, so operators do not have to ask the question themselves. Regulators across central and eastern Europe have tightened player-protection rules this year, with Poland’s competition authority opening proceedings against seven licensed bookmakers over dark patterns.
Trembita does the verification
The technical basis is Trembita, the state data exchange system Ukraine adopted from Estonia and now uses to move data between roughly 200 state registers. Trembita will connect the Register of Military Personnel, built by the Ministry of Defence, to the restricted-persons register held by the regulator.
Operators will not see whether a customer serves in the armed forces. The system returns a single answer on whether access should be restricted, and nothing about why. That design keeps personnel data inside government systems, which matters in a country where the location and identity of service members is itself a security question.
Where the directive came from
The Cabinet of Ministers endorsed the ban in June 2026 and instructed PlayCity to enforce it. Gennady Novikov, head of PlayCity, set out the reasoning when the decision was announced.
“Gambling addiction is a real danger. When it comes to military personnel, that risk can impact not only the well-being of individuals, but also security.”
The concern is combat readiness. Ukrainian authorities have linked gambling debt among service members to theft of military property and to soldiers becoming targets for pressure.
This is not the first restriction. In 2024, President Volodymyr Zelensky ordered a review after a petition on gambling addiction in the armed forces, and rules introduced that year barred service members from online casinos during martial law and tightened gambling advertising. Apple and Google removed dozens of unlicensed casino apps from their stores in the same period, and thousands of illegal gambling sites were taken down.
Operators question the effect
The industry pushed back in March 2026. Alexander Kogut, head of the Association of Ukrainian Gaming Operators, argued the measure would move play rather than stop it.
“Such a ban would not stop people in the military from gambling.”
His position is that demand shifts to unlicensed sites, where there is no register to check against, no age verification and no complaints process.
Illegal sites remain outside the system
The tender covers licensed operators only. Illegal gambling websites are not connected to Trembita and will not run the check, which leaves the group the policy targets reachable by anyone operating outside the licensing regime. The same gap has been documented in other markets, where black-market betting has grown alongside tighter rules on licensed operators.
Reporting cited alongside the initiative goes further, linking Russian-connected casino operators to attempts to collect information on Ukrainian soldiers. The Pin-Up casino investigation appears among the cases raised in that context, with concerns covering data harvesting, blackmail and the effect on military effectiveness. Those claims sit outside the scope of the tender and have not been resolved through the regulator.
What happens next
PlayCity now has to award the contract, have the module built and integrate it with two registers and every licensed operator before the December 24 deadline. The Register of Military Personnel is the harder dependency, since it has to stay current across mobilisation, discharge and casualty records for the check to mean anything.
The measure will be judged on whether it moves play off licensed sites and onto unlicensed ones. PlayCity has spent the past two years blocking illegal domains, and the number of sites it has to keep blocking after December will be the clearest reading of whether the register worked or simply redirected the problem.
Source: PlayCity









