Legal gambling advertising is making a comeback. What will it look like?

For almost a year, Ukraine has been subject to strict restrictions on gambling advertising. And finally, from 1 April 2025, gambling advertising will return to the legal Ukrainian media space, but with certain restrictions. The Law of Ukraine No. 4116-IX provides for stricter penalties for violation of licensing requirements.

In particular, according to the Law, it is allowed to advertise gambling in accordance with the following rules:

• on television and radio - only at night (23:00 - 6:00);

• in specialised media with a 21+ rating;

• directly in gambling establishments;

• on the websites and applications of licensed gambling organisers;

• in online media registered in accordance with the Law on Media;

• in video services, search engines and social networks - if there is a targeting of advertising to an audience with an age limit of 21+, etc.

  
  

Everything seems to be quite good and adequate, but the issue of combating illegal advertising remains open, as the black market has not complied with any prohibitions and restrictions and will not do so in the future, so the legal advertising market will need help from both the national regulator and law enforcement.

The national regulator (as of 1 April 2025, PlayCity replaced CRGL and is currently the only legitimate gambling market supervisor in Ukraine) has the authority to block illegal websites, impose fines (up to UAH 2.01 million) and monitor compliance with advertising restrictions. However, the effectiveness of these measures depends on:

• Resources: the regulator needs sufficient funding and staff to monitor all advertising channels;

  
  

• Coordination with law enforcement: police and cyber police are supposed to investigate illegal operations, but often focus on physical establishments rather than digital advertising;

  
  

• technical capabilities: blocking websites is a temporary solution, as illegal operators quickly create "mirrors" (alternative domains).

  
  

Law enforcement, for its part, can apply criminal liability for illegal gambling organisation (Article 203-2 of the Criminal Code of Ukraine), but fighting advertising is difficult due to its dispersion and anonymity of performers.

What can be done?

An effective fight against illegal gambling advertising in Ukraine requires a comprehensive approach that includes:

1. Strengthening the powers of the regulator. To do this, PlayCity should be given greater opportunities to monitor social media and platforms, for example, through cooperation with Meta, Google, and Telegram. Increase the regulator's budget to hire cybersecurity and analytics specialists and introduce an automated online monitoring system that will detect illegal advertising in real time.

2.Wider involvement of law enforcement agencies. Specialised cyber police units could be created to combat illegal online advertising. Involve the financial monitoring service to track payments for advertising, including cryptocurrency transactions, which are often used by the black market.

3. Expand cooperation with the private sector. As part of this process, the regulator should conclude agreements with advertising platforms on mandatory licence checks before placing gambling advertisements. At the same time, it makes sense to create a system to encourage legal gambling business organisers to report illegal competition by providing them with incentives, such as tax reductions for cooperation.

At the same time, the rule of "balance of interests" should be observed, as excessive regulation could harm the legal market, which is already under pressure from advertising bans, while illegal operators would be left unchecked.