Finland Is Moving from a State Monopoly to a Strictly Regulated Licensing System

For many years, Finland has operated under a state monopoly, where a single operator controlled the local gambling market, with the aim of protecting players and limiting gambling-related harm. In practice, however, this model has become increasingly difficult to maintain, mainly because Finnish players, like players across Europe, have been able to access offshore operators without real restrictions.

This is exactly the same situation that led other countries such as Denmark, Sweden and Netherlands to move away from monopoly systems and adopt licensing frameworks, and Finland is now following that same path.

The reform is already approved at a legislative level, and the structure is becoming clearer. Licence applications are expected to open during 2026, with the market itself planned to go live in mid-2027, at which point private operators will be able to offer online betting and casino services under a regulated system. However, the important point is not just that the market is opening, but how it is opening.

Unlike earlier markets, where regulation developed gradually after launch, Finland is building its system based on what has already happened in other countries, and this is likely to result in a stricter framework from the start. Even at this stage, several key elements are already clear.

Operators will be required to implement full identity verification and player authentication, meaning that all users must be verified before they can gamble, and systems must be in place to monitor behaviour and detect harmful patterns.

In addition, there will be strong anti-money laundering and risk management obligations, requiring operators to actively monitor transactions, report suspicious activity, and demonstrate that their systems are effective in practice, not just formally in place.

At the same time, the rules around marketing are expected to be significantly tighter than what many operators are used to, including clear restrictions on targeting vulnerable users, limits on aggressive promotion, and in some cases even bans on certain types of affiliate or influencer marketing. There are also structural requirements around licensing itself, including ongoing supervision, the possibility of fines or licence revocation, and even additional licensing layers for software providers, meaning operators will not be able to rely on unregulated third-party solutions.

All of this points to the same conclusion: Finland is not simply opening its market, it is building a controlled system where operators are expected to take active responsibility for how their platform works, how players behave, and how risks are managed. This is why the timing question needs to be understood correctly. It is true that not all details are final yet, and full technical preparation may still be early, but the direction is already clear, and operators who understand that direction now will be in a much stronger position than those who only react once the market is fully open.

More importantly, the shift to a licensed system changes how activity is viewed from a legal perspective. Once a country defines a clear licensing framework, operating outside that framework becomes much harder to justify, and this is exactly where recent European case law, including the Wunner decision, becomes directly relevant.

The Wunner Decision: How EU Courts Are Redefining Liability for Offshore Operators

The change in Finland is not only about opening a new market, it also highlights a broader shift across Europe in how courts look at operators that work across borders without the proper licences. This is where the Wunner decision becomes important. The case deals with a situation that is very common in the iGaming industry, where an operator offers services in a country without holding a local licence, often relying on a licence from another jurisdiction or operating from offshore while still targeting players in regulated markets. In the specific case, a player used an online gambling service that was not licensed in their country and later argued that the activity was unlawful under local law, and because of that, the player should be able to recover their losses.

The key question for the court was simple but important: Is this just a regulatory issue between the operator and the authorities, or can the player rely on the lack of a licence to make a legal claim?

The answer was clear – the court accepted that national gambling laws are designed to protect players, and that the requirement to hold a local licence is part of that protection, which means that if an operator ignores that requirement and still offers services into that country, the player may rely on that breach and claim that the activity should not have taken place. In practical terms, this opens the door for players to bring claims against operators, not only based on contractual arguments, but based on the fact that the service itself was provided in breach of the law.

This is a major shift for offshore and cross-border operators.

For years, many operators treated licensing as mainly a regulatory issue, meaning that the main risk was fines, warnings, or being blocked by local authorities. The Wunner decision shows that this approach is no longer enough, because the risk now also includes direct claims from users, which can be harder to predict and harder to control.

The situation becomes even more complex because these claims do not stay in one place. Under the Rome II Regulation, the law that applies to these types of claims is usually the law of the country where the player is located, which means that an operator can be licensed in one country but still face claims in several others where it does not hold a licence.

This is especially relevant in markets such as Germany and Austria, where courts have already seen claims from players trying to recover losses from operators that were not locally licensed at the time.

When looking at this together with what is happening in Finland, the connection becomes clear. As more countries move to structured licensing systems, the line between licensed and unlicensed activity becomes sharper, and courts are more willing to treat activity outside that system as something that can create real legal consequences.

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