Draft Regulation Sets Product-Level Requirements for Licensed Online Gambling

Finland’s Ministry of the Interior has published for public consultation a draft regulation setting out detailed requirements for gambling offered by holders of Finnish gambling licences.

The regulation is proposed to enter into force on 1 July 2027 and will be relevant for both gambling operators and game suppliers preparing for the new Finnish licensing regime.

A machine-translated version of the draft regulation is available here:

The draft introduces maximum permitted stakes across several electronic casino game categories. Electronic slot machine games would be subject to a maximum stake of EUR 20 per game round, while electronic bingo would also be capped at EUR 20 per round.

Higher limits are proposed for certain electronic table games, including card, dice, lottery wheel and number lottery games. Online poker would be subject to a maximum initial bet of EUR 1,000 per game.

According to the explanatory memorandum, where a combination game includes characteristics of several game categories, the applicable maximum stake would be determined by reference to the maximum permitted stake for the game types included in that combination game.

A separate, lower set of stake limits would apply to players under the age of 25. For this group, the maximum stake for electronic slot machine games and electronic bingo would be EUR 10 per round, while several table game categories would be capped at reduced levels.

The draft also regulates tournament entry fees. Table game tournaments, excluding player-versus-player poker, would be subject to a maximum entry fee of EUR 1,000. For player-versus-player poker tournaments, the proposed maximum entry fee is EUR 5,000, while electronic slot machine tournaments would be capped at EUR 500.

The regulation expressly permits certain forms of jackpot winnings, including surprise-type jackpots and winning-combination jackpots. Jackpot prizes may be fixed, odds-based or progressive.

For electronic slot machine games, the draft contains several product design and player protection requirements. Players must select their own stake and start each game round themselves. Operators may not offer or technically enable simultaneous play of two or more electronic slot machine games. This means that the rules would effectively prohibit autoplay for electronic slot machine games. Each game round must last at least 2.5 seconds, and players must not be allowed to shorten the draw time before the result is displayed.

The draft also restricts certain game presentation features. Slot games must not use visual, audio or other effects to suggest that a win is likely in future rounds, or to present losses in a way that gives the impression that a win is imminent. The visual display of the game must correspond to the actual draw result.

In electronic games of chance, players must be informed that choices made during the game do not affect the outcome of the draw.

Finally, the draft requires electronic gambling games to include playing-time reminders. Players must receive an on-screen notification every 15 minutes showing the time spent playing. After the notification, players must choose whether to continue playing or log out, except in electronic casino games where players play against each other. Players may also choose to receive reminders more frequently after the first notification.

Nordic Legal’s initial analysis

In Nordic Legal’s initial opinion, the limits and restrictions proposed in the Finnish draft regulation appear workable and pragmatic for both licensed operators and game suppliers.

Compared with Denmark and Sweden, the Finnish proposal is more prescriptive at product level, particularly for online slots. Danish and Swedish regulation has generally focused more on licensing, certification, responsible gambling controls, player monitoring, self-exclusion and intervention duties, rather than detailed product-by-product restrictions on game mechanics.

The closest comparison is the UK, where online slot regulation already includes structural controls such as stake limits, minimum game-cycle duration, restrictions on autoplay and restrictions on features that may increase play intensity or misrepresent losses. The Finnish draft follows a similar policy direction, especially in relation to player-initiated game rounds, minimum game duration, restrictions on simultaneous slot play and limits on game presentation features.

However, the Finnish model appears relatively balanced. The proposed slot stake limits are higher than the British limits, while still being combined with clear technical safeguards and lower limits for players under 25. This suggests a regime that is protective, but not unduly restrictive.

Overall, Finland appears to be adopting a hybrid model: more detailed than the Danish and Swedish frameworks, but less restrictive than the UK on monetary slot limits. For international operators and suppliers, this should make the Finnish requirements manageable within existing regulated-market product frameworks.

Please note that the regulation is still in draft form and may change before adoption.

The deadline for submitting comments is 5 August, and the public consultation is open to anyone wishing to comment.

For further information, reach out to us at: [email protected]

We will continue to monitor developments closely and keep you informed as further guidance is issued.