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Online Gaming in Estonia

Authored by - NJORD Law Firm (Last Updated Jun 2024)

Overview

Open

Estonia Online Gaming Overview

Regulated
Gambling in Estonia is regulated by the Gambling Act and the main regulatory authority is the Estonian Tax and Customs Board. The Gambling Act allows for the following types of gambling: games of chance, toto i.e. sports betting, lottery, games of skill and commercial lottery.

Market size
The online gambling market in Estonia is growing fast. Considering Estonia’s rather small market (population 1.3 M) we have around 30 (both online and land-based) active gambling operators currently.

Competitive landscape
The full list of gambling operators by subtypes of gambling can be found here: https://www.emta.ee/en/business-client/registration-business/gambling-operators/list-legal-gambling-operators

Localisation
Advertising of gambling is regulated by the Advertising Act and supervised by the Estonian Consumer Protection and Technical Regulatory Authority. Advertising is allowed under certain conditions and only if the gambling operator holds a valid operating permit.

For payment methods, many operators integrate their services with third-party PSPs, such as Skrill or Trustly.

Marketing of betting sites is prevalent as banner ads on online media websites, as well as traditional advertisements on billboards.

Top Key Attractions and Challenges

Attractions

  • Low tax rate
  • Approachable regulatory authority
  • Expanding market
  • Fast licensing process
  • E-residency programme
  • Estonia is capable of being operated as a “.com” jurisdiction.
  • Estonia is an EU member state.

Challenges

  • Restricted advertising
  • High share capital requirements
  • Bank account opening might be difficult for non-resident operators or companies without any board members residing in Estonia. All local banks are very cautious about non-residents and needs to understand how the business is connected to Estonia. However, operators may use any payment service provider outside of Estonia as well (must be within the European Economic Area). The payment service provider can be either a credit institution (bank) or a payment institution.

Licensing & Regulation

Well-regulated / Unregulated (Open)

Estonia Online Gaming Licensing & Regulation

In Estonia, licensing is a two-step process: first, the intended operator will be scrutinised when applying for the activity licence and then follows the application for an operating permit, whereby the actual organising of the gambling will be examined and assessed. The activity licence and operating permit must be applied for with regard to each type of gambling separately. Both...

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Enforcement

Irregular / Mixed impact

Estonia Online Gaming Enforcement

Regulating bodies
The main regulatory body is the Tax and Customs Board, which conducts general supervision over gambling operators.

Supervision by Regulator
Additionally, gambling operators must adhere to the supervision and regulation of the Estonian Financial Intelligence Unit (AML questions) and the Estonian Consumer Protection Board (consumer protection and marketing).

There is no regular audit or compliance assessment...

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Marketing

Restricted

Estonia Online Gaming Marketing

General rules for the advertising of gambling apply.

Only an operator with an operating permit is allowed to advertise gambling; Advertising of gambling shall not contain an incitement to participate in gambling or visit a gaming location or information which may suggest that gambling contributes towards social success.

Advertising of gambling shall include the textual warning: “Tähelepanu! Tegemist on hasartmängu...

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Fees

High

Estonia Online Gaming Fees

Estonia Online Gaming Fees

Application fees
As the licensing in Estonia is a two-step process, there is a separate state fee for applying for activity license and for operating permit. The state fee for applying for an activity licence depends on the type of gambling. The state fee for applying for operating permit is EUR 3200, except in the...

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Taxes

Low

Estonia Online Gaming Taxes

Licence taxes
Generally speaking, most gambling products are subject to tax at 5% GGR, except lotteries (please see that section).

However, these games are not subject to gambling tax:

Games of skill, the only possible prize of which is getting the opportunity to take part in the same game again Sports competitions Lotteries with the value of the prize pool...

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Future Outlook

Positive

Estonia Online Gaming Future Outlook

The general future outlook seems positive. The market is growing and there are no attempts to put an end to that growth.

There are no regulatory changes in the pipeline. Starting from 2024, the gambling tax rates were raised and for certain types of games, the tax will raise again in 2026.

At the end of 2023, Estonian Financial Intelligence...

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Legal Expert

NJORD Law Firm

Office locations Estonia (Tallinn)

NJORD is a full-service law firm with a local framework and a Nordic profile. We provide legal advice and solve problems for clients nationally and internationally.

As a law firm, our principal tasks are to ensure that our clients obtain justice and to provide the help and advice they require. This must be done properly. With professionalism, knowledge and experience and with respect for the client, the process and all parties involved.

NJORD is based on three core values – Knowledge, Diversity and Respect.

Our Nordic profile affects our culture and mindset. Basically, we have a Nordic way of working – a flat organizational structure and a diverse culture where respect of differences and diversity is valued. We insist on taking responsibility and using our professionalism where it can make a difference for our clients and for society.

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