New lottery rules as an opportunity for a transparent market

The recent PlayCity competition for official lottery operator status, the results of which were announced on January 28, marked the first tangible step toward bringing Ukraine’s lottery market out of the “gray” zone. Only three companies — M.S.L., UNL, and Patriot — advanced to the final stage under the updated rules. At first glance, this may appear to preserve the existing hierarchy of market players. However, behind this formality lies a strategic transition from a regulatory vacuum to a clearly structured legal framework.

For many years, the absence of licensing conditions and a legally defined operational format effectively detached lotteries from the state. Large volumes were circulating, millions of players were participating — yet without proper agreements, without systemic monitoring, and without real profit accounting. This was not merely a gap in reform; it was a de facto status quo: a shadow market lacking transparent payments, fair competition, and legally established accountability.

The new model will function differently. First, all official operators will be required to submit electronic reporting that, in real time, reflects sales volumes, prize payouts, and overall cash flows. Second, every lottery ticket and every terminal will receive a unique QR code, effectively turning a street kiosk or retail outlet into an officially verified point of sale. This technical marker directly disrupts shadow schemes. What was once chaotic and optional is expected to become measurable and predictable.

As for international companies, the current stage is objectively limited to a domestic core. This reflects both the capabilities of the existing legislation and the way the market can operate today within the framework of the профиль law. It is far from perfect, but unfortunately, this outcome corresponds to the current lottery legislation.

Overall, lotteries are becoming a key bridge between traditional offline business and modern iGaming. The legalized segment is acquiring digital tools — point-of-sale identification, financial monitoring, real turnover measurement, and payout tracking — tools that iGaming operators have effectively been using for years. This is the only realistic mechanism through which the legal market can gradually reclaim a significant share of the “gray” sector, ensuring predictable state revenues while providing genuine player protection. It is not a perfect system, but it represents a serious reform scenario — moving from chaos toward predictability.