What Finland’s Gambling Reform Means for MGA Licence Holders
Finland has recently taken decisive steps in liberalising its long-standing gambling monopoly. Earlier this month, the Finnish Parliament approved the new Finnish Gambling Act, marking a pivotal moment in the country’s transition towards a licence-based competitive gambling framework. The reform will bring significant regulatory implications for operators, particularly those licensed by the Malta Gaming Authority (MGA) and currently targeting the Finnish market.
Under the new Act, Veikkaus will retain exclusive rights only for lotteries, scratch cards and certain land-based games, while online casino and fixed-odds betting will be open to licensed competition. Applications for gambling licences under the new Gambling Act may be submitted from next month, with approved licensees able to commence licensed gambling operations and marketing in Finland from 1st July 2027. At the same time, the supervisory mandate transitions to the newly established Finnish Supervisory Authority. This phased rollout allows operators to prepare for compliance and integration with Finnish regulatory expectations well before full market participation.
While the new Gambling Act does not currently prohibit Finnish residents from accessing gambling services outside the licensed system, winnings derived from unlicensed operators will be treated as taxable income, further tying in with the regulator’s push towards increasing channelling rates.
Who can apply and what’s required?
Gambling licences (B2C) under the new Gambling Act can be granted to a natural or legal person provided they meet eligibility requirements similar to those of other regulated markets. Operators based both within the EEA and outside the EEA (subject to the appointment of a representative domiciled in the EEA) will be able to submit applications.
A licensee must demonstrate robust internal controls, AML programmes, strong governance, and comprehensive plans for player protection, marketing and reporting obligations.
Finland’s new licensing framework also introduces a multi-layered cost structure for operators:
- Application fee: €29,000 per licence.
- Licence amendment/authorisation fee: €1,120.
- Annual supervisory/licence fees: Tiered based on Gross Gaming Revenue (GGR), ranging from approximately €4,000 up to €434,000.
- GGR tax: A 22 % tax on GGR for all licensed gambling services.
- Corporate income tax: Operators tax-resident in Finland will also be subject to Finnish corporate tax on profits, aligning with Finnish tax law.
Does EU Mutual Recognition Apply?
Finnish regulators have confirmed that, consistent with prevailing EU case law, a gambling licence granted in one EU member state does not automatically permit legal operation in another member state. This view reflects recent rulings of the Court of Justice of the European Union, affirming that restrictions on freedom to provide services in the gambling sector may be justified for public policy reasons.
Operators targeting Finland solely under an MGA licence will therefore need to secure local authorisation to continue legal market access and active targeting of the Finnish market once the new regime is fully operational. Operators that actively target Finnish customers without holding a valid Finnish licence may be subject to administrative enforcement measures, including marketing bans imposed by the National Police Board. The new Act allows for additional restrictive measures to be imposed on operators operating outside the regulated system once the framework enters into force. Such enforcement actions may have wider regulatory consequences, as they could negatively impact an operator’s ability to satisfy the fitness and propriety assessment applied by the Finnish Supervisory Authority when reviewing future licence applications.
Broader Market Implications
The latest regulatory change in Finland follows a wider Nordic and EU trend towards local licensing and territorial regulation, steadily reducing the number of markets that can be actively targeted solely based on an MGA B2C Licence. Similar trajectories are also being observed internationally; jurisdictions such as Chile are progressing towards their first online gambling licensing regime, currently expected by the end of 2027.
As locally regulated markets expand, the practical scope of lawful cross-border targeting under an MGA licence continues to narrow. That said, monopoly markets such as Norway, as well as jurisdictions like Iceland, remain commonly targeted by MGA licensees, reflecting the fragmented nature of global gambling regulation and the absence of uniform EU market access.
A natural question arising from Finland’s reform is how this will affect the relevance of the MGA B2C Licence. In practical terms, the more probable outcome is a gradual shift in licensing strategies, with some operators transitioning from standalone MGA B2C licences to Recognition Notice certificates, retaining their Maltese presence for regulatory credibility, fiscal efficiency, access to payment and banking infrastructure, as well as the availability of a knowledgeable workforce and ecosystem. In fact, according to the last MGA Annual Report, the MGA issued 62 Recognition Notice certificates, an increase of 36 over the previous year.
The Evolving Role of the MGA Licence and How ARQ Can Help
The Finnish reform also introduces a significant B2B licensing requirement, scheduled to enter into force on 1 July 2028. From that date, holders of Finnish B2C gambling licences will only be permitted to use gambling software supplied by entities holding a Finnish B2B software licence, signalling a potential impact in the medium to long term on suppliers operating under an MGA B2B licence.
In practice, this signals that even well-established regulatory approvals, such as the MGA B2B licence, will face increasing localisation pressures. However, against a backdrop where the credibility of offshore regulators is frequently scrutinised and regulatory stability remains uneven, the MGA licence continues to hold a strong position.
The MGA remains widely recognised as a global benchmark for regulatory compliance, governance, and player protection. Its value is particularly evident as banks, EMIs, PSPs, platform providers and software suppliers continue to tighten their compliance requirements.
As regulatory fragmentation accelerates, ARQ helps gaming businesses remain compliant and strategically positioned without losing sight of commercial reality.
Damian Callus
Damian Callus is a Lead Regulatory Advisor within ARQ’s Gaming Advisory Unit, supporting gaming clients with licensing and ongoing regulatory and operational compliance. He has over six years of experience at the Malta Gaming Authority, where he worked within both the Authorisations and Compliance Department, overseeing the technical compliance function, including the review and assessment of thematic reviews and compliance audits on MGA-licensed remote gaming operators.
