Gaming Law 2025

Last Updated November 25, 2025

Estonia

Law and Practice

Authors



NJORD Law Firm has presence in Estonia and clear Nordic focus and coverage. NJORD Law Firm is strong in technology law and all kinds of regulatory matters, including banking, fintech, IT, and gaming. For clients in the gaming industry, the firm starts with identifying needs, creates a tailored GAP analysis, and considers gambling taxation structures, corporate matters, privacy policies, terms and conditions, AML/KYC compliance, and other parts of licensing. For already up-and-running gaming businesses, the firm provides day-to-day legal assistance within AML, marketing, and consumer protection. In addition to gambling operators, NJORD Law Firm serves many clients in the banking and fintech sectors. This year, the Estonian branch of NJORD Law Firm celebrates its 20-year anniversary.

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:

  • Paf, Åland’s (a partly self-governed part of Finland) publicly held organisation;
  • NinjaCasino and CoolBet, with a strong focus on the Nordics; and
  • the big international players.

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:

  • updated definitions of remote and additional gambling;
  • mandatory audits of annual financial reports; and
  • stricter AML data requirements for licence applications.

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:

  • sports betting (defined as toto);
  • bingo;
  • casino;
  • lotteries; and
  • poker.

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:

  • the Gambling Act;
  • the Gambling Tax Act;
  • the Advertising Act;
  • the Media Services Act;
  • the International Sanctions Act; and
  • the Money Laundering and Terrorist Financing Prevention Act.

According to the Gambling Act, Section 2, Subsection 1, gambling is a game that meets all the following criteria:

  • it is a precondition for participating in a game that the player makes a bet;
  • the player may win a prize as a result of the game; and
  • the outcome of the game is partly or fully determined by an activity based on chance or depends on the occurrence of a previously unknown event.

There are four types of games in Estonia, as follows.

  • Games of chance (games organised on gaming tables and gaming machines) – these are games in which the outcome depends on chance and that are played by means of a mechanical or electronic device or by mediation of the organiser of the game.
  • Lotteries (bingo, etc) – these are games in which the outcome depends on chance, the prize pool constitutes up to 80% of the selling price of the circulation of the lottery tickets, and the outcome of the game is not determined more than three times per 24 hours or it is determined by opening the ticket field on the lottery ticket.
  • Totos – these are games in which the outcome depends on the occurrence, non-occurrence, or manner of the event predicted by the player, where the event on which the player is betting is beyond the control of the gambling operator. The winning of a prize depends on whether the bet turns out to be true or not and the amount of the prize depends on the amount of the bet and the winning coefficient determined before the making of the bet (betting) or percentage of the total amount of the bets as determined by the gambling operator, the number of people who bet correctly, and the amount of their bets (totalisator).
  • Games of skill – these are games in which the outcome depends predominantly on the physical skills or abilities or knowledge of the player, and that are played by means of a mechanical or electronic device.

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.

  • First, the intended operator will be scrutinised when applying for the activity licence.
  • Second is the application for an operating permit, whereby the actual organising of the gambling will be examined and assessed.

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.

  • Activity licence – the purpose of the activity licence is to ensure that the company and the people related to the company are experienced in this field and have the funding needed to organise gambling. Documents proving the reliability and competence of the persons involved must be submitted (including shareholders, management board members, and supervisory board members). All shareholders who own at least 10% in the gambling operator must disclose additional information and documents.
  • Operating permit – the purpose is to assess whether or not the games to be provided are in compliance, all the necessary systems are up and running, and the documents comply with the provisions set by the law. This includes AML/KYC procedures, consumer protection, and gaming rules, as well as the “technical solution” (this is the connection between the operator’s servers and the regulator through X-tee which allows for the regulator to retrieve statistics directly from the operator’s servers). A gambling operator must ensure that it has access to the list of persons that have self-restricted their playing of games, with the help of the Tax and Customs Board. Also, an electronic record-keeping and control system must be adapted to the gaming operator system.

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:

  • the acquirer’s name, place of residency, and date of birth/personal identification code;
  • documents certifying the financial status of the person during the last three years (including a full list of the individual’s immovable property, construction works and securities belonging to the person, and authenticated copies of the person’s tax returns for the last three years); and
  • a certificate from the police of the place of residence confirming the absence of penalties.

A gambling operator should submit the following information regarding a person to be appointed to a managing body (eg, a director):

  • their given name and surname, personal identification code or, in the absence thereof, their date of birth;
  • their place of residence, full list of places of employment and positions;
  • documents which prove the trustworthiness and conformity to the requirements of the Gambling Act, which the applicant considers important to submit (proof of the absence of punishments from the police of the place of residence);
  • documents certifying the financial status of the person during the last three years, including a full list of the immovable property, construction works and securities belonging to the person; and
  • authenticated copies of the person’s income tax returns for the last three years.

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:

  • timers;
  • reality checks;
  • timeouts;
  • self-assessment tests; and
  • supportive insurance (developed to prevent problem gaming by helping customers to get the professional counselling they need).

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 advertising of gambling shall not contain an incitement to participate in gambling or visit a gaming location or information that may suggest that gambling contributes towards social success; and
  • the advertising of gambling shall include the following textual warning (in Estonian), “Tähelepanu! Tegemist on hasartmängu reklaamiga. Hasartmäng pole sobiv viis rahaliste probleemide lahendamiseks. Tutvuge reeglitega ja käituge vastutustundlikult!” (“Attention! This is advertising of gambling. Gambling is not a suitable means for solving financial problems. Examine the rules and behave responsibly!”) ‒ the warning shall, given ordinary attention, be noticeable, understandable, and clearly distinguishable from other information.

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:

  • on the premises where a game of chance is organised;
  • on board a watercraft or aircraft used for international carriage of passengers;
  • in the building of a passenger terminal of an airport or port that provides regular international services;
  • in a hotel where gaming premises for games of chance are located;
  • on the website of an organiser of games of chance; and
  • advertising communicated by post, email, or phone, provided that the client has subscribed to it, it is communicated only to the client’s own postal or email address, or the telephone number used by the client, and the client is able to terminate the communication of advertising at any time by notifying the organiser of the games of chance of one’s wish.

Advertising of toto is prohibited:

  • in and on the buildings and territories in the use of preschool childcare institutions, basic schools, upper secondary schools, vocational educational institutions, hobby schools, permanent youth camps, and youth project camps, and in close proximity thereof;
  • on websites directed at children;
  • at a place and during the time of holding an event that is mostly directed at children, and on the tickets for such event;
  • on television and radio programmes;
  • on the front and back covers of newspapers or magazines, unless published together with the sponsor’s announcement; and
  • as outdoor advertising, unless published together with the sponsor’s announcement.

Advertising of games of skill is prohibited:

  • in and on the buildings and territories in the use of preschool childcare institutions, basic schools, upper secondary schools, vocational educational institutions, hobby schools, permanent youth camps, and youth project camps, and in close proximity thereof;
  • on websites directed at children;
  • before or during television and radio programmes that are mostly directed at children;
  • on the front and back covers of newspapers or magazines, unless published together with the sponsor’s announcement; and
  • as outdoor advertising, unless published together with the sponsor’s announcement.

Advertising of lotteries is prohibited:

  • in and on the buildings and territories in the use of preschool childcare institutions, basic schools, upper secondary schools, vocational educational institutions, hobby schools, permanent youth camps, and youth project camps, and in close proximity thereof;
  • on websites directed at children;
  • before or during television and radio programmes that are mostly directed at children; and
  • at a place and during the time of holding an event that is mostly directed at children, and on the tickets for such event.

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 holder of the activity licence has organised gambling without an operating permit for organising gambling;
  • the holder of the activity licence has committed an intentional violation of tax law; or
  • incorrect information has been knowingly submitted upon the application for the activity licence.

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:

  • the gambling operator has not engaged in organising gambling at the location indicated in the decision for over a whole running year without good reason; or
  • the gambling operator has repeatedly violated the regulation governing the advertising of gambling or the gaming location.

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:

  • EUR300 per gaming machine used for the organisation of games of chance and 10% of the amount received from the bets made on the gaming machines used by the gaming operator for the organisation of games of chance, less winnings;
  • EUR1,406 per gaming table and EUR32 per gaming machine of skill;
  • when organising a lottery, 22% of the amount received from the sale of lottery tickets;
  • when organising a commercial lottery, 22% of the prize fund of the commercial lottery, if the value of the prize fund exceeds EUR10,000;
  • in the case of remote gambling, toto, and games of chance and skill, 6% of the amount received from the bets made, less any winnings (rising to 7% from 2026);
  • when organising a gambling tournament as a tournament, 6% of the amount received from the participation fees of the gambling tournament, from which the part of the prize fund received has been deducted (rising to 7% from 2026);
  • when organising a gambling tournament as a round game, 6% of the amount received from the participation fees of the gambling tournament (rising to 7% from 2026); and
  • when organising a gambling tournament as a tournament and a round as a remote gambling tournament, 6% of the amount received from the participation fees of the gambling tournament (rising to 7% from 2026).

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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Trends and Developments


Authors



NJORD Law Firm has presence in Estonia and clear Nordic focus and coverage. NJORD Law Firm is strong in technology law and all kinds of regulatory matters, including banking, fintech, IT, and gaming. For clients in the gaming industry, the firm starts with identifying needs, creates a tailored GAP analysis, and considers gambling taxation structures, corporate matters, privacy policies, terms and conditions, AML/KYC compliance, and other parts of licensing. For already up-and-running gaming businesses, the firm provides day-to-day legal assistance within AML, marketing, and consumer protection. In addition to gambling operators, NJORD Law Firm serves many clients in the banking and fintech sectors. This year, the Estonian branch of NJORD Law Firm celebrates its 20-year anniversary.

The Continuing Popularity of the Estonian Gambling Licence Amid Increased Scrutiny and a Decreasing Gambling Tax Rate

General developments

Increased level of attention in the media

Over the past year, there has been a notable surge in public discourse concerning gambling operators and the associated risks of their activities. This discussion has not only focused on the implications for Estonia’s reputation as a business-friendly environment but has also highlighted broader societal concerns. The media has played a pivotal role in amplifying these discussions, bringing to light various facets of the gambling industry that were previously under-explored.

At the beginning of the year, a significant political development occurred when one of the elected parties in the Riigikogu, Estonia’s parliament, proposed reversing the planned increase in the gambling tax rate. Instead, they suggested a decrease, aiming to enhance Estonia’s attractiveness to gambling companies.

This proposal sparked a swift response from the Financial Intelligence Unit (FIU), which is tasked with overseeing Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) matters. The FIU promptly highlighted the potential risks associated with such a move, emphasising the need for careful consideration of the broader implications.

The media’s attention to this subject has been relentless, with journalists actively seeking opinions from the public and various authorities. Their investigative efforts have gone beyond mere reporting; they have attempted to open accounts, conduct test payments, and scrutinise the operational procedures and shareholdings of companies operating under an Estonian licence. This comprehensive approach has contributed to a more informed public discourse and has pressured stakeholders to address the underlying issues.

Increased level of reviews by Tax and Customs Board

The Tax and Customs Board, the regulator for gambling, has long been recognised for its diligence in reviewing submitted documentation from gambling operators. However, recent months have witnessed a significant intensification in the thoroughness of these reviews. Previously, the regulator would typically request amendments only in cases of major errors. This approach has evolved, with the regulator now adopting a more meticulous stance, scrutinising even minor details.

In practice, this heightened level of review has resulted in more detailed feedback than ever before. The interpretation of the law has become increasingly restrictive, prompting gambling operators to reassess their systems and procedures. Even those with previously approved systems have found themselves needing to make adjustments in response to new applications and related reviews by the regulator.

The process has become more iterative, with operators often undergoing several rounds of follow-up questions or amendments. This is true even for seemingly straightforward processes, such as adding a new brand or updating terms and conditions (T&Cs). The increased scrutiny reflects a broader trend towards ensuring compliance and maintaining the integrity of the gambling sector.

Decrease of gambling tax rate?

Historically, Estonia’s gambling tax rate was set at 5%. In 2024, a decision was made to increase the rate to 6% in 2025, with a further increase to 7% planned for 2026. This was intended to generate additional revenue for the state. However, the anticipated revenue boost did not materialise as expected, prompting a re-evaluation of the tax strategy.

The Finance Committee of the Riigikogu (the Estonian Parliament) has since introduced draft legislation aimed at gradually reducing the gambling tax rate from 6% to 4%, decreasing by 0.5% per year. This amendment proposes that the tax rate will not increase to 7% in 2026 but will instead decrease to 5.5%. The Committee’s rationale is to ensure Estonia remains competitive in the global tax landscape and maintains a favourable business environment.

The Committee has acknowledged that previous amendments demonstrated that merely increasing the tax rate does not guarantee the expected additional revenue. Moreover, it may diminish Estonia’s attractiveness compared to other countries. The draft legislation seeks to establish a taxation system where a fixed base amount remains in the state budget, with additional revenue generated from actual market growth.

The vote on the draft is expected to take place before the end of 2025.

Supporting sport and culture through gambling tax

In conjunction with the proposed decrease in the gambling tax rate, the draft law amendment also aims to redefine how the tax collected from gambling operators is distributed. A portion of the gambling tax is earmarked for the Estonian Cultural Endowment (Eesti Kultuurkapital), which allocates funds between culture and sport.

From a cultural perspective, the funds are primarily directed towards the construction and maintenance of cultural buildings. On the sporting front, the focus is on building and maintaining various sports facilities across Estonia. This approach underscores the government’s commitment to supporting cultural and sporting initiatives, leveraging the gambling tax as a means to enhance these sectors.

Review of gambling advertisements

The regulation of gambling advertisements is contingent upon the type of licence held by the gambling operator, making it susceptible to conflicts with existing laws and practices. While the law provides specific guidelines, it is challenging to anticipate and regulate every possible scenario. The Consumer Protection and Technical Regulatory Authority (TTJA) serves as the regulator in this domain.

The TTJA has published guidelines with specific examples regarding gambling advertisements and, in spring 2025, it released updated guidelines. In 2023, the TTJA conducted inspections of gambling advertisements from companies holding an Estonian licence. The list of monitored brands was compiled based on advertisements identified by officials and reported as violations by the public.

The sample included 19 gambling operators, with violations found in the advertisements of 15 operators. For four operators, no advertisements were identified during the observation period. Of the 152 advertisements reviewed, 150 were initially assessed by the TTJA as not meeting the requirements.

The main violations included missing or inadequate warning text (in 128 cases), advertisements containing calls to action or references to social success (in 133 cases), and the publication of prohibited gambling advertisements (in 26 cases). Although the TTJA has not conducted additional market reviews since 2023, this scrutiny has heightened awareness of gambling advertisement regulations and prompted operators to adopt a more proactive approach. When planning new advertisements that may not comply with laws and regulations, operators have reached out to the TTJA for guidance and approval.

Possible increase in the fines

Over the past five years, the Tax and Customs Board has conducted only one misdemeanour proceeding, resulting in a legal entity being fined EUR2,000 for organising prohibited gambling. In the same proceeding, a natural person was fined EUR320. Another misdemeanour proceeding is currently underway. The ability to detect and process misdemeanours has been hampered by limited personnel and the high cost of proceedings, given the maximum possible fine amount.

The draft law currently under discussion in the Riigikogu proposes raising fine amounts ten-fold. According to the explanatory notes, this increase will enable the authorities to address misdemeanours in accordance with their actual impact on society. Raising the fine rates is deemed necessary to ensure that the cost of committing a violation is not lower than its potential profit, thereby effectively curbing violations in the gambling sector. Additionally, updating the fine rates will help cover the costs incurred by the state in conducting misdemeanour proceedings in the future.

The continuous popularity of the Estonian gambling licence

Many working in this line of business had expected the popularity of the Estonian licence to flatten out, as the country’s neighbour, Finland, will introduce its gambling licences in 2026. So far, no slowing down in the applications or the issuance of new licences can be seen.

Trends regarding AML

AML reviews by the FIU

For several years, the FIU has been vocal about the potential risks of money laundering and terrorist financing associated with gambling services offered by foreign companies under an Estonian licence. This concern has led to increased scrutiny and regulatory measures aimed at mitigating these risks.

At the end of 2023, the FIU distributed AML questionnaires to all gambling operators with Estonian licences. In 2024, the FIU announced plans to commence official reviews of gambling operators and their internal AML procedures. Although no audits or reviews have been reported as of the date of writing, this does not imply that they will not occur or be indefinitely postponed.

The general recommendation for gambling operators is to ensure that their internal AML procedures align with their internal policies and comply with Estonian laws and regulations. This proactive approach is essential to maintaining compliance and mitigating potential risks.

Furthermore, unlike the Tax and Customs Board, the FIU operates exclusively in Estonian and accepts documents only in this language. Consequently, in the event of reviews, audits, or queries from the FIU, gambling operators must provide input, including their AML-related internal policies, in Estonian.

AML risks arising from accepting bets in crypto

In a recently published risk assessment, the Estonian Ministry of Finance identified the remote gambling sector as the greatest risk and vulnerability to money laundering in Estonia. As risk factors, they point out the number of foreign companies holding Estonian gambling operator licences that are based in Cyprus (ten companies) and Malta (six companies). Additionally, some ultimate beneficial owners hail from jurisdictions considered high-risk for money laundering, including Russia, Belarus, Georgia, and Uzbekistan.

Remote monitoring has revealed that at least five service providers permit clients to make deposits and withdrawals using virtual currencies through collaborations with virtual currency service providers. Casinos have traditionally been associated with a higher risk of money laundering, where the principles of “know your customer” and “verify the source of funds” are not always consistently applied. The integration of online casinos with modern technologies further exacerbates these existing risks.

The FIU has already alerted the sector to potential upcoming reviews and audits. Operators that facilitate client transactions using cryptocurrencies may be more likely to be selected for the FIU’s scrutiny. A few years ago, similar heightened risks were identified among virtual asset providers. At that time, the FIU adopted a stringent approach, resulting in the revocation of over 70% of previously issued cryptocurrency service licences following thorough reviews.

NJORD Law Firm

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+372 667 6440

tallinn@njordlaw.ee www.njordlaw.com/en
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Law and Practice

Authors



NJORD Law Firm has presence in Estonia and clear Nordic focus and coverage. NJORD Law Firm is strong in technology law and all kinds of regulatory matters, including banking, fintech, IT, and gaming. For clients in the gaming industry, the firm starts with identifying needs, creates a tailored GAP analysis, and considers gambling taxation structures, corporate matters, privacy policies, terms and conditions, AML/KYC compliance, and other parts of licensing. For already up-and-running gaming businesses, the firm provides day-to-day legal assistance within AML, marketing, and consumer protection. In addition to gambling operators, NJORD Law Firm serves many clients in the banking and fintech sectors. This year, the Estonian branch of NJORD Law Firm celebrates its 20-year anniversary.

Trends and Developments

Authors



NJORD Law Firm has presence in Estonia and clear Nordic focus and coverage. NJORD Law Firm is strong in technology law and all kinds of regulatory matters, including banking, fintech, IT, and gaming. For clients in the gaming industry, the firm starts with identifying needs, creates a tailored GAP analysis, and considers gambling taxation structures, corporate matters, privacy policies, terms and conditions, AML/KYC compliance, and other parts of licensing. For already up-and-running gaming businesses, the firm provides day-to-day legal assistance within AML, marketing, and consumer protection. In addition to gambling operators, NJORD Law Firm serves many clients in the banking and fintech sectors. This year, the Estonian branch of NJORD Law Firm celebrates its 20-year anniversary.

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