Against this backdrop, the figure of ₴14.5 billion in revenues from legal operators in 2025 looks like a success — but a success “on thin ice.” Without high-quality regulation, strong institutions, and normal cooperation between the state and the white market, these revenues remain fragile and unstable.

A Young Market and “Uneven” Institutions

The Ukrainian gambling market is a typical young market with high expectations and uneven institutional performance.

State agencies delay decisions and create unpredictability: licensing procedures, by-laws, sanctions, and fines often look less like systematic policy and more like fragmented reactions. For investors, this signals risk: tomorrow the rules may change without a transition period or clear logic.

At the same time, the state is pushing limits and other restrictions that European practice has shown to have the opposite effect: overly rigid frameworks do not reduce addiction but instead encourage players to move to offshore operators. There, there are no limits, no responsible-gaming tools, and no mechanisms to help problem gamblers.

For years, the Verkhovna Rada has failed to advance tax-law harmonization. As a result, the legal market operates under triple pressure: licensing fees, a GGR tax, and a tax on any payout to the player — even when there is no net win. This creates a paradox: the more honestly an operator works and the harder it tries to bring a player out of the “grey zone,” the more expensive it becomes.

Add to this the practice of baseless searches, account freezes, and criminal proceedings against those who formally operate within the legal field. Under such conditions, legal businesses receive a clear message: you pay taxes and invest in compliance, but the guarantees of protection are minimal.

SOMS as a Tool, Not a “Magic Wand”

The State Online Monitoring System (SOMS) was conceived as a key element of digital oversight: a single “window” through which the state sees real turnover, bets, payouts, suspicious transactions, and risky player behavior. This is absolutely the right direction — without online monitoring, talking about modern gambling regulation is simply unserious.

The problem lies elsewhere: SOMS simply cannot see those who are entirely outside Ukraine’s legal framework. No matter how many alerts come in or how many sites are blocked, offshore operators simply switch to new mirrors, payment gateways, and “drop” schemes.

Thus, if the institutional logic does not change, SOMS risks becoming yet another tool for pressuring white-market operators. Legal operators become maximally transparent, fully “under the microscope,” while competing with those who remain invisible to the system and bear no compliance costs.

As a result, the risks for the budget and for players do not decrease, while the legal segment gradually loses motivation to invest in Ukraine.

What a “Mature” Regulatory Model Gives Ukraine

Leading European jurisdictions have long shown that when the state offers a transparent, competitive, and digital regulatory model, online gambling stops being a “grey zone” and becomes a stable source of budget revenue. Players gain protection, the market gains investment, and the state gains oversight tools.

For Ukraine, this is not just another reform. It is an element of financial security in a country that is fighting a war, rebuilding, and simultaneously striving to earn the trust of international partners and investors.

If we want to preserve and increase the ₴14.5 billion from the legal segment — rather than watch this money flow to offshore islands and crypto wallets — we need not new bans, but a mature regulatory architecture. One with strong institutions, digital monitoring, a fair tax model, and partnership with the white market.