Contributed By NJORD Law Firm
Operators in the Estonian Market
Currently, there are around 42 licensed gambling operators in the Estonian market (both online and land-based). This number is not impressive, but it needs to be understood in the context that Estonia is a small country with 1.3 million inhabitants. Out of the licensed operators, there are some with a stable local presence (including land-based facilities), such as the Olympic Entertainment Group and Novoloto (Fenix Casino), but also some regional operators such as:
Out of the total of 42 licensed gambling operators, 17 licences have been issued to foreign legal entities.
In 2025, a new land-based casino commenced operations in Estonia – Bombay Club (Kopikas Entertainment OÜ).
Sector Developments
Carrying on from previous years, the authors have noticed a consistent increase in interest in Estonian online licences. The Estonian digital landscape attracts international companies due to the convenience of the e-residency programme, which allows companies to be managed digitally from anywhere with an internet connection, and the wide range of digital services offered by the public authorities, including the regulator, as well as co-operation partners.
During the previous five years, there has been a steady increase in the online market, as well as a steady decrease in the offline market. Professional advisers expect the online market to continue growing in the coming years, in line with international trends, although a flattening out in Estonia was anticipated as neighbouring Finland is set to offer gambling licences in 2026. So far, no decrease can be seen. The land-based market is expected to remain the same, mainly due to the difficulties in achieving consent from the local municipalities, and higher costs than online gambling.
Heightened Scrutiny
Public scrutiny of gambling operators and related risks has risen, driven by investigative reporting and debates over tax policy and AML/CFT implications. Media tests of onboarding and payments have pressured stakeholders and informed the public. The Estonian Tax and Customs Board has tightened its review practice by issuing detailed feedback and applying narrower interpretations of law. Even minor changes like adding brands or updating terms and conditions (T&Cs) now trigger iterative queries and system adjustments.
The Consumer Protection Board’s 2025 guidelines further tightened advertising compliance by clarifying rules and providing examples, prompting heightened marketing supervision and more brands to seek pre-clearance.
The Financial Intelligence Unit has also intensified scrutiny of gambling since late 2023 by issuing AML questionnaires and signalling formal reviews (from 2024). Operators must align procedures with Estonian law and be ready to submit documentation in Estonian, as the Financial Intelligence Unit operates only in Estonian. A recent risk assessment flagged remote gambling as highly exposed, and the Financial Intelligence Unit warns that weak crypto controls and KYC/source of funds checks may trigger licensing risks.
Legislative Changes
The Gambling Act
The Gambling Act entered into force on 1 January 2009 and there have been only minor changes made to it.
The Gambling Tax Act
There are, however, recent and forthcoming changes in the Gambling Tax Act. These include an increase in the tax rate for remote gambling and toto (sports betting) from 5% to 6% in 2024, with a further rise to 7% in 2026. Lotteries and commercial lotteries saw their tax rate increase from 18% to 22% in 2024. Furthermore, the tax for gaming tables rose from EUR1,278.23 to EUR1,406, and for skill game slot machines, from EUR31.95 to EUR32.
The Gambling Reform Bill
In addition to the already adopted changes, the Riigikogu’s (the Estonian parliament) Finance Committee has advanced a draft to modernise gambling regulation and boost sport and culture funding via gambling tax. The draft proposes cutting the remote gambling and toto tax rate from 6% to 4% in steps of 0.5% per year to keep Estonia competitive and support growth-driven revenues. The drafters point to the Foresight Centre’s projections that remote gambling tax receipts could multiply by 2029 and boost culture and sport funding. The plan combines a competitive tax rate and design with stronger licensing and supervision capacity and reflects positive international assessments of Estonia’s regulatory framework. It also foresees a ten-fold increase in maximum fines to better match the societal impact of violations and cover enforcement costs, although prior enforcement activity and fines have been low. The draft is at plenary first reading as of October 2025 and expected to be voted upon before the end of 2025. It is the most notable gambling framework update in Estonia in over 15 years. Other key measures include:
Receipt of Gambling Tax
The receipt of gambling tax has shown a substantial year-on-year increase over recent years. The increase from 2021 to 2022 was over 40%. In 2023, the gambling tax receipts continued to grow by about 2–3%, marking a steady but smaller increase compared to the previous year. In 2024, gambling tax receipts experienced a notable increase of 17% compared to the previous year. This growth, however, can be largely attributed to the raise in the tax rates. Had the tax rates remained the same, the growth in tax receipts would have closely aligned with the steady increase observed in previous years.
In Estonia, the following sectors are regulated and permitted:
See 3.2 Definition of Gambling for types of gaming.
Social gaming and fantasy sports are not regulated by the law. Fantasy sports are primarily enjoyed within a smaller group of friends for fun. There are no large platforms, such as those in the USA or the UK, where they can be played professionally for money.
Organising of gambling is prohibited if the prerequisite for determining the outcome of a game is to achieve a certain number of participants or bets, and the return of the full bet to the player is not guaranteed if the prerequisite is not achieved.
In Estonia, the sectors that are regulated and permitted are the same for both land-based and online casinos. See 2.1 Online Gambling for further details.
In Estonia, the following acts apply to the gambling sector:
According to the Gambling Act, Section 2, Subsection 1, gambling is a game that meets all the following criteria:
There are four types of games in Estonia, as follows.
Land-based gambling is not specifically defined, but it serves as the foundational basis of the legislation.
Online gambling is considered a way of organising gambling. According to the Gambling Act, Section 5, Subsection 1, remote gambling (online gambling) is the organisation of gambling in a manner where the outcome of the game is determined by an electronic device and the player can participate in the game by electronic means of communication, including telephone, the internet, and media services. Gambling is not considered remote gambling where electronic means of communication are used only for receiving bets, providing information about the outcome of the game, or transferring a prize amount to the account of a player.
All offences are covered in Chapter 5 of the Gambling Act. The key offences and penalties are as follows (one fine unit is EUR8).
Violation of the Age Limit Established for Players of Gambling Games
A person under 21 years of age being present in a gaming location for games of chance or enabling a person under 21 years of age to play a game of chance or a game of skill organised as remote gambling, or enabling a person under 18 years of age to be present in a gaming location for a toto or enabling such person to play a toto, or enabling a person under 16 years of age to play the lottery is punishable by a fine of up to 200 fine units (see above) or detention. If committed by a legal person, the same act is punishable by a fine of up to EUR2,600.
Violation of the Requirement for Identification and Registration of Persons Entering a Gaming Location
Failure to identify or register persons entering a gaming location for games of chance by the organiser of the game of chance or violation of the requirements established for registration is punishable by a fine of up to 100 fine units. If committed by a legal person, the same act is punishable by a fine of up to EUR2,000.
Violation of the Rules of the Game and Deceit of a Player
Violation of the established rules of the game, deceit of a player, and failure to submit the rules of the game to a player at the player’s request are punishable by a fine of up to 200 fine units or detention. If committed by a legal person, the same act is punishable by a fine of up to EUR2,600.
Violation of the Restrictions on the Participation of Persons Under 21 Years of Age in Gambling
A person under 21 years of age is punished for playing a game of chance or a game of skill organised as remote gambling or for being present in a gaming location for games of chance, by a fine of up to ten fine units.
The organisation of prohibited gambling is punishable by a fine of up to 200 fine units (see 3.5 Key Offences) or detention. If committed by a legal person, the same act is punishable by a fine of up to EUR2,600.
The organisation of gambling by a gambling operator holding an activity licence without an operating permit or at a location not indicated in the decision on the issue of the operating permit, as well as organisation of gambling not indicated in the decision on the issue of the operating permit are punishable by a fine of up to 300 fine units. If committed by a legal person, the same act is punishable by a fine of up to EUR2,600.
State supervision over the organisation of gambling is exercised by the Estonian Tax and Customs Board, which decides on issuing, refusing, and revoking activity licences for the organisation of gambling and operating permits for gambling and performs reviews and supervisory procedures in case of violations.
The Estonian regulator, the Tax and Customs Board, is approachable and co-operative. Estonia’s approach to regulation is a combination of digital innovation and regulatory frameworks. Innovations are expected to be legalised before they happen, which is a prescriptive approach. Importantly, experimentation is also legalised. The country is one of the world’s most digitalised economies, so technology is greatly used in Estonia with respect to regulation and governance.
In Estonia, licensing is a two-step process.
The activity licence and operating permit must be applied for with regard to each type of gambling, separately. For types of gambling, see 3.2 Definition of Gambling.
Gambling must be the sole activity of the gambling operator. The organiser of gambling may engage in ancillary activities related to the organisation of gambling at the gaming site, including catering, currency exchange and the organisation of leisure and cultural events (only for land-based gambling).
Licences are issued by the Tax and Customs Board and are readily available after complying with the requirements of the law and submitting the necessary documents and information.
Activity licences are issued for an unspecified term and are not transferable.
An operating permit is issued for up to 20 years and it is not transferable. Operating permits for remote (online) gambling are issued for up to five years.
An operating permit for an instant lottery is issued for up to five years.
The key application requirements are as follows.
The electronic record-keeping and control system is an electronic communications network connecting the gaming machines of the gambling operator or additional games of chance, or gaming equipment used for the organisation of remote gambling or toto. The gambling operator shall ensure the possibility of connecting the electronic record-keeping and control system with the information system of the Tax and Customs Board. This system shall ensure the registration and recording of data in a manner that enables calculation of the turnover of the gambling operator and the percentage of the distributions made to players in the total amount of all bets for each gaming machine, each gaming table connected with the system, and remote gambling at any moment of time. This is important from a gambling tax perspective.
The decision to issue an activity licence, or refuse to, must be made within four months of the receipt of all the necessary documents and information but not later than six months after receipt of the application. From the authors’ practice, a well-prepared application may secure the licence within just one month.
As to step two, the operating permit, the decision shall be made within two months but not later than four months after receipt of the application for the operating permit. Again, a well-prepared application will result in a fast process.
The state fee for applying for an activity licence is set at EUR47,940 (games of chance), EUR31,960 (toto/sports betting), and EUR3,200 (games of skill).
The state fee for an operating licence is EUR3,200 (regardless of type).
The state fee for reviewing a lottery operating permit is EUR640.
There are no annual fees. Once the licence needs to be renewed, the same fees apply as for a new one.
Individuals associated with the gambling operators are not licensed in Estonia. The persons occupying the managing bodies and persons holding or wishing to acquire a qualified holding in a gambling operator must show they are fit and proper by submitting certain documents and information to the regulator for authorisation, either as part of the activity licence application or prior to being appointed as a member of the managing body or acquiring a qualified holding, as applicable.
Before acquiring a qualifying holding (any direct or indirect holding in the share capital of a company organising gambling which represents 10% or more) in a gambling operator, or increasing their shareholding exceeding 20%, 30% or 50%, a person shall submit the following information to the regulator:
A gambling operator should submit the following information regarding a person to be appointed to a managing body (eg, a director):
There are no fees associated, other than the general state fee paid upon the submission of the application for the activity licence. The regulator must be informed upon a change in the managing bodies of the gambling operator, as well as prior to a person acquiring or increasing their qualified holding in the gambling operator. Regulatory bodies can revoke the operator’s licences or impose fines if the notification obligation is not followed.
For a land-based casino, written consent must be obtained of the local municipality government for opening at a certain location. Such a location may not be situated together with preschools and childcare institutions, schools, and youth organisations. A gaming location for games of chance may only be situated in a separate building, a hotel, conference centre, or recreational establishment, or a business building or shopping centre and if there are no residential parts in the same building.
The consent for opening a gaming location for a game of skill is granted for up to 20 years, and the consent for opening a gaming location for a game of chance or toto is granted for five to 20 years.
A gambling operator is engaged in the organisation of gambling and needs a licence in order to engage in its activities. In practice, it means that Estonia does not regulate B2B licences, only B2C ones.
A gambling operator may transfer its activities aimed at organising gambling to another person only upon the written consent of the regulator. The Tax and Customs Board shall decide upon granting the consent or refusing to grant the consent within 30 working days after receipt of an application.
See 6.1 B2C Licences.
See 6.1 B2C Licences.
The company that is organising the gambling and offering it to the Estonian market is the one that needs licensing. In the case of white labels operating under the licence of the white-label provider, there is no additional licensing; however, the licensee needs to keep the regulator informed regarding the trade marks and websites used by the operator.
For gambling operators that have no activity licence or operating permit in Estonia, the Estonian Tax and Customs Board implements measures to restrict gaming. There is a list of domain names for blocked illegal remote gambling servers. There are currently over 1,800 sites listed, and the list is constantly updated.
HAMPI contains a list of persons that have self-restricted their playing of games. The purpose of maintaining the list is to provide persons with an opportunity to limit their gambling in order to mitigate the potential negative social and economic consequences of gambling to the persons themselves and to society. A person may choose which type of game they are going to restrict. It is not possible to file a request for setting restrictions for others; for example, a family member or a friend. It is possible to set restrictions on games of chance (land-based and online), toto, and classical lotteries. The restrictions do not apply to instant lottery (ie, scratch lottery tickets). The holder of the list of persons with restrictions on gambling is the Estonian Tax and Customs Board. The operators must check whether a person has listed themselves in the HAMPI upon every time before allowing access to their service.
Before allowing a player to play a game for the first time, the gambling operator shall conspicuously present the opportunity to set an upper limit for the amount that the player will be ready to lose as a result of gambling with the given operator during a week or month. An operator is prohibited from accepting bets that may increase the loss to a player beyond the limit set by the player. The limit must be enforced across all of the operator’s websites and platforms.
The gambling operator must ensure that a clear warning is presented to the player regarding the addictive nature of gambling and that a reference is made to the contact details of organisations that assist gambling addicts.
The player must be constantly shown clear information about how long they have been playing and must be able to see the details of their bets and winnings.
In addition to HAMPI (see 7.1 RG Requirements), the gaming operators may also propose precautionary measures. Some of the key management tools used by the gambling operators are as follows:
The relevant legislation in terms of AML is the Estonian Money Laundering and Terrorist Financing Prevention Act from 2017 with amendments (see 8.2 AML Requirements). The legislation has implemented the Fifth Anti-Money Laundering Directive.
The supervisory authority in this respect is the Financial Intelligence Unit, which is a governmental authority under the Ministry of Finance. There are no guidelines issued specifically for the gambling sector.
The Financial Intelligence Unit has the right to forward data that it has registered, as well as analyses and assessments, to the Tax and Customs Board for proceedings related to a gambling activity licence.
Changes to the Money Laundering and Terrorist Financing Prevention Act entered into force in late 2023, which significantly increased the potential penalties for obliged entities, including gambling operators, for breaches against the requirements of the Act. The Financial Intelligence Unit has let the operators know that they intend to place significant focus on gambling operators in the next few years and expect full co-operation.
The supervisory agency is the Estonian Consumer Protection and Technical Regulatory Authority (TTJA).
Advertising means information that is made public in any generally perceived form for a charge or without charge for the purpose of increasing the provision of services or the sale of goods, promoting an event, or directing the conduct of a person in the public interest (Advertising Act, Section 2, Subsection 1, clause 3).
Following the Advertising Act, Section 292:
The website of a gambling operator has to include an additional warning, notifying the players of the addictive nature of gambling and urging them to play responsibly.
The following restrictions stipulated in the Advertising Act are relevant.
Advertising of gambling, a gaming location, or an organiser of gambling (“advertising of gambling”) is prohibited if the organiser of gambling has no operating permit required under the Gambling Act.
Advertising of games of chance is prohibited except:
Advertising of toto is prohibited:
Advertising of games of skill is prohibited:
Advertising of lotteries is prohibited:
The placing, producing, or publicising of advertising that violates the general requirements for advertising is punishable by a fine of up to 300 fine units. If committed by a legal person, the same act is punishable by a fine of up to EUR400,000.
According to the Advertising Act, Section 34 – Violation of Prohibition on Advertising of Goods and Services, similarly to the foregoing, the placing, producing, or publicising of advertising that ignores the prohibition on advertising of goods and services is punishable by a fine of up to 300 fine units. If committed by a legal person, the same act is punishable by a fine of up to EUR400,000.
A qualifying holding in a gambling operator is any direct or indirect holding in the share capital of a company organising gambling that represents 10% or more of the share capital of the company, or all rights related thereto, or of the voting rights in the company, or that makes it possible to exercise a significant influence over the management of the company in which that holding subsists. Before acquiring a qualifying holding in a gambling operator, or increasing such holding so that its proportion in the share capital of the gambling operator, or all rights related thereto, or votes represented by shares will exceed 20%, 30% or 50%, a person shall submit to the Tax and Customs Board data about the size of the holding to be acquired and additional information and documents regarding the acquirer.
See 10.1 Disclosure Requirements.
Passive investors are treated the same way as active ones – ie, all investors are treated equally, so the information provided in this chapter can be applied to both types of investor.
The Tax and Customs Board may revoke an activity licence if the gambling operator and its platform do not meet the requirements set by the law. For example:
The invalidity of an activity licence renders all the operating permits, issued to the same gambling operator for organising gambling of the same type, invalid. The person whose activity licence has been revoked shall close down all gaming locations of the same type of gambling and stop making the same type of gambling available within three days after the day of revocation of the activity licence.
An operating permit can be revoked if, for example:
See 11.1 Powers, 3.5 Key Offencesand 3.6 Penalties for Unlawful Gambling.
The proceedings in the Estonian Tax and Customs Board are not open to the public. The Estonian Rax and Customs Board does not publish statistics.
The latest public statistics by the Estonian Consumer Protection Board (consumer protection and marketing) do not reflect gambling disputes at all, which means that there are very few of them, if any. The Estonian Consumer Protection Board also keeps a “blacklist” of companies that do not comply with their decisions: as of the beginning of October 2025, no licensed gambling operator has been entered on that blacklist.
Estonian gambling tax is paid by the gambling organiser. The period of taxation is one calendar month. The tax rates for gambling tax as of 10 October 2025 are:
Gambling tax is paid into the state budget, where it is distributed among ministries in accordance with the Gambling Tax Act. Declarations are submitted electronically. Although the gambling tax rate is planned to increase to 7%, as of the time of writing (November 2025), there is a draft law in the Riigikogu that would lower the gambling tax rate by 0.5% per year until the tax rate is 4%, and change the distribution of the revenues from gambling tax to be more flexible.
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