Ukraine Issues Order 99 Setting Unified Compliance and Inspection Standards for Lottery Operators

Ukraine’s gambling office PlayCity has published official compliance criteria for lotteries operating on domestic soil. Order 99 establishes a unified audit form for scheduled and unscheduled state checks on both online and land-based operations, as reported by Lottery Daily. The checklist assesses financial stability, technical integrity, stakeholder identification, and operational restrictions including bans on occupied territories and casino-style visuals.

Inspections document business metadata, officials involved, check type, duration, and any violations. Operators can note procedural irregularities by officials and rate audit integrity on a one-to-ten scale. Non-compliance falls into high, medium, or minor categories under Ukraine’s gambling framework.

Financial, Ownership, and Technical Mandates

Operators must maintain charter capital of at least UAH 30m (£501,000) from verified sources, with total equity above this baseline. At least 50% of all wager revenues must go to the prize pool. Insurance is required to cover unpaid prizes in bankruptcy.

Executives, chief accountants, major shareholders, and ultimate beneficial owners cannot be residents or entities of an aggressor state, nor subject to sanctions or terrorist registries. Trademarks or brands linked to such states are prohibited. Lottery equipment cannot simulate slot machines, roulette, dice, or card games; all hardware must pass technical tests, carry tamper-evident seals, and link to the central electronic betting system for real-time bet, refund, and payout records.

Territorial Rules and Martial Law Suspensions

Point-of-sale locations are barred from government buildings, healthcare facilities, schools, libraries, museums, religious venues, and residential housing. All materials must carry clear 18+ messaging. Land-based operators must maintain at least 5,000 physical distribution points and 5,000 active terminals nationwide, while online operations are limited to one operator-owned .ua domain website and one mobile app, with full public disclosures and ticket verification tools.

Under current martial law, the 5,000-point and terminal requirements are suspended in combat zones, occupied territories, and affected areas. Inspections occur only in non-conflict territories. All other rules remain enforceable. The standardized form clarifies expectations and documentation for both regulator and operator, reducing procedural disputes in a constrained operating environment. Operators should map current setups against the non-suspended criteria to limit exposure to high-severity findings once full territorial rules resume.

Reporting: Lottery Daily

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