AI regulation - a key framework for the future of gambling

Ukraine is gradually developing its own legal framework for artificial intelligence, and this process is increasingly having implications for the gambling industry as well. This is not simply an abstract technological reform; it is about establishing the rules under which algorithms will operate tomorrow, algorithms that analyze player behavior, personalize offers, and determine who should be targeted with advertising and who should be subject to restrictions.

I have previously written about sovereign artificial intelligence models and their potential impact on the gambling industry. This is undoubtedly a trend that will shape the regulatory future of gambling, which is why it is encouraging to see the national regulator actively working on these issues already.

The draft law on artificial intelligence is being developed by the WINWIN AI Center of Excellence, established under Ukraine’s Ministry of Digital Transformation. The legislation is being designed as an analogue of the European AI Act and is intended to harmonize Ukrainian legislation with EU standards.

At the same time, the future law is expected to go beyond simply replicating the European approach. The working group is already considering the possibility of legally defining the concept of an “AI agent” and establishing liability for its actions, issues that currently lack clear regulation even in many countries with more advanced AI infrastructure. The full text of the legislation is still being developed by a broad working group of experts, which is consulting with market participants. This provides grounds to expect a well-balanced and high-quality outcome.

This is particularly important for the gambling industry, as it is likely to be among the first sectors to face the practical consequences of these changes. Artificial intelligence has long ceased to be a futuristic concept for gambling operators. Algorithms are already being used for:

• analyzing player behavior and identifying harmful patterns;

• preventing fraud and verifying users;

• personalizing bonus offers and communications;

• detecting risky gambling behavior and early signs of gambling addiction.

This is why an issue that may initially appear to be purely technological is, in fact, directly connected to player safety and the stability of the regulated market. When algorithms make decisions that affect real people including individuals who may be particularly vulnerable to developing gambling-related harm, society has a legitimate interest in knowing who is responsible for those decisions.

The development of Ukraine’s AI legislation presents a unique opportunity to establish clear boundaries for the use of algorithms and AI agents in the gambling industry before these technologies become deeply embedded in established practices, rather than attempting to regulate opaque and already entrenched mechanisms after the fact.

The key issues that the legislation should address can be grouped into three areas.

First, liability: who should ultimately be responsible for decisions made by an algorithm or an autonomous AI agent—the developer, the gambling operator, or another party?

Second, user data protection: how will data concerning player behavior, which forms the basis of many analytical algorithms, be stored, processed, and transferred?

Third, maintaining human oversight: in which circumstances should an AI-generated decision be subject to mandatory human review or approval rather than being made entirely autonomously?

A clear legal framework aligned with European approaches would allow artificial intelligence to become a tool for responsible gambling, transparency, and player protection rather than an opaque mechanism for influencing user behavior. For operators, this means preparing for the new requirements in advance: reviewing their algorithms, documenting decision-making logic, and ensuring that human intervention remains possible wherever it is critically important.

As the legislation is still being developed, the gambling industry has an opportunity to participate in the discussion and help shape what these rules will ultimately look like. Given how deeply AI is already integrated into the day-to-day operations of gambling companies—from fraud detection to personalized offers—ignoring this process would be a mistake.