The Gambling Act (Hasartmänguseadus, HasMS) defines a game of chance based on three criteria: the player places a wager and stands to win a prize, while the outcome depends — either partially or entirely — on chance or the occurrence of an event that is unknown in advance.

As of January 1, 2026, a wager is defined not only as a monetary sum or other property-related obligation but also as a crypto-asset (§ 2(2) HasMS).

The Act distinguishes between four types of gambling games:

• Games of chance — the outcome depends on chance and is determined by a mechanical or electronic device or by the organizer (e.g., slots, roulette, card games, poker tournaments).
• Lotteries — the outcome depends solely on chance; these include classic, instant, and number lotteries.
• Totalizator games (Toto) — wagers placed on the outcome of an event beyond the organizer’s control, primarily sports betting.
• Games of skill — the outcome depends predominantly on the player’s physical dexterity or knowledge.

Remote gambling — the organization of a game where the outcome is determined by an electronic device and the player participates via electronic communication means. Games of skill where the only prize is the right to play again do not fall under the scope of the Act.

The sector is regulated by two specific laws and several general ones; there is no unified EU law on gambling, and the Estonian regime is entirely national.

A key reform took effect on 1 January 2026. It brought crypto-assets within the definition of a stake, restricted the channels for accepting payments, required licences to be approved by the Financial Intelligence Unit, introduced mandatory audits, and launched a phased reduction of the remote gambling tax from 6% to 4% by 2029.

Estonia has permitted online gambling since 2010. Licences issued in other EEA countries do not grant the right to operate in Estonia.

The main regulator is the Tax and Customs Board (Maksu- ja Tolliamet, EMTA). It issues licences and permits, supervises operators, collects the gambling tax, and maintains the register of licensed operators and the list of blocked illegal websites.

Yes. The system has two tiers: first, an activity licence (tegevusluba), which vets the company itself, its owners and its capital; then an operating permit (korraldusluba) for a specific type of game and venue, or for remote gambling.

a. Validity period

b. Types of licences. Separate activity licences are issued for games of chance, totalisator and games of skill. No activity licence is required for lotteries; a permit is sufficient, but it may only be obtained by a public limited company with share capital of at least EUR 1 million, all of whose shares are held by the state (AS Eesti Loto). Commercial lotteries are conducted on a notification basis.c. B2C and B2B. Only operators dealing directly with players (B2C) are licensed. There is no separate B2B licence in Estonia.

d. Software suppliers. No licence is required. Remote gambling software and gaming machines are assessed by an independent expert accredited under ISO/IEC 17025 and recognised by EMTA; the operator attaches the expert’s report to its permit application.

Any game of chance not provided for by law, or organised without an Estonian licence and permit, is prohibited. All major verticals (online casino, slots, poker, sports betting and games of skill) are permitted, subject to licensing.

Key prohibitions and restrictions:

• A monopoly of the state-owned company AS Eesti Loto; private operators may only conduct commercial (promotional) lotteries.
• Gambling on credit. An operator may not grant credit to a player or act as an intermediary in obtaining it (§ 34(1) HasMS).
• Games of chance and remote games of chance and skill: from 21; totalisator and lotteries: from 18. The minimum age for lotteries was raised from 16 to 18 on 1 January 2026.
• Anonymous payments. Since 2026, stakes in remote gambling may only be accepted through a credit institution, payment institution, e-money institution or crypto-asset service provider authorised in the EEA (§ 5(3) HasMS).
• Game parameters. The average return to player in games of chance must exceed 80% of stakes.
• Players in the HAMPI register. Admitting persons who have imposed a restriction on themselves is prohibited.

Loot boxes and in-game currencies are not covered by the Gambling Act; the Ministry of Finance has stated that it has no current plans to regulate them.

The applicant obtains, in sequence, an activity licence and then an operating permit from EMTA; the applications cannot be submitted in parallel. A realistic timeframe to launch is 6–12 months.

Requirements for the applicant:

• a public limited company (AS) or private limited company (OÜ) registered in Estonia or another EU Member State; a non-resident must first register with EMTA as a non-resident taxpayer;
• the organisation of gambling must be its sole activity;
• fully paid-up share capital of EUR 1,000,000 for games of chance, EUR 130,000 for totalisator and EUR 25,000 for games of skill;
• an impeccable reputation of shareholders with a qualifying holding, beneficial owners and members of management bodies: no criminal record, no involvement in managing an illegal operator, and no fault in a company’s bankruptcy;
• transparent origin of capital and good tax compliance over the past three years;
• a contact person for the Financial Intelligence Unit who is permanently resident in Estonia.

Stages and timeframes:

For remote gambling, the following are also required:

• an independent expert’s report on the software’s compliance;
• connection of the operator’s electronic accounting and control system to EMTA’s information system;
• a verified connection to the HAMPI restrictions register;
• information about the server. The server may be located abroad, provided the local authorities are able to cooperate with EMTA and the FIU; for states party to the Convention on Cybercrime, which includes the entire EU and EEA, this condition is deemed to be met.

Local presence. An office and staff in Estonia are not required. Tax registration and a resident contact person for the FIU are mandatory. A single application for a remote gambling permit may cover several websites.

Cost. State fees for an online casino total EUR 51,140. The main burden lies in the EUR 1 million share capital, certification, technical integration and legal support.

No, Estonia has no personal licences. The suitability of individuals is assessed as part of the company’s activity licence.

• Who is assessed. Shareholders with a qualifying holding, beneficial owners, and members of the management board and supervisory board.
• What is assessed. No criminal record; no past management positions at an operator that worked without a licence or had its licence revoked for violations; no court-established fault in a bankruptcy. EMTA also evaluates the experience and reputation of the managers.
• AML contact person. Appointed under the Money Laundering and Terrorist Financing Prevention Act; must be permanently resident in Estonia and acceptable to the FIU.
• The operator must notify EMTA immediately of any change in these persons.

Advertising is permitted only for operators holding an Estonian permit and is strictly limited by § 29² of the Advertising Act; for games of chance, a general ban applies with narrow exceptions. Supervision is carried out by TTJA.

Games of chance, including online casinos. Advertising is permitted only:

• at the gambling venue;
• on board ships and aircraft on international routes and in international terminals;
• in a hotel where a casino is located;
• on the operator’s own website;
• in direct messages to customers who have given their consent.

Outside these places, only the operator’s trademark may be displayed, with no call to gamble and no information about the game or the odds.

Totalisator and games of skill. Advertising is generally permitted but is prohibited in children’s and educational institutions and in media aimed at children. Totalisator advertising is prohibited on radio and television, and on the front and back pages of publications and in outdoor advertising it is permitted only together with a sponsorship announcement.

General requirements:

• calls to participate in gambling and creating the impression that gambling contributes to social success are prohibited;
• every advertisement must carry the statutory warning in Estonian;
• only an operator holding an Estonian permit may sponsor media services and programmes.

The fine for a legal entity for a violation is up to EUR 400,000. According to TTJA, 104 of the 230 advertising materials it inspected in 2025 contained violations.

Yes. Affiliate marketing is not prohibited and is not separately licensed: affiliates are not gambling operators and do not fall under EMTA’s supervision.

In practice, their activities are limited by the advertising rules:

• only operators holding an Estonian permit may be promoted; advertising unlicensed websites is prohibited;
• an affiliate’s materials on casino products fall under the general ban on advertising games of chance, so in practice only totalisator and games of skill can be promoted legally;
• under the Advertising Act, liability is borne both by the advertiser and by whoever produced and distributed the advertisement;
• posts by bloggers and influencers must be labelled as advertising; the government has discussed tightening the rules for social media.

Organising gambling without a licence or permit results in a fine and, for remote operators, the blocking of the website and payments; players bear no liability.

• The Gambling Act establishes misdemeanours punishable by a fine; for legal entities, according to reports on the 2026 amendments, up to EUR 32,000 for general violations and up to EUR 26,000 for breaching age restrictions (to be verified). Engaging in activity without the required permit may also give rise to criminal liability under the Penal Code (offence to be verified).
• EMTA enters illegal websites on a public list; internet service providers must block access to the domain, hosting providers must remove the content, and payment intermediaries must not process payments to such operators (§ 56 HasMS).
• Consequences for a future licence. A person who managed an illegal operator may not be a shareholder, beneficial owner or manager of a licensee.
• Advertising an operator without an Estonian permit is prohibited; the fine for a legal entity is up to EUR 400,000.
• Participating in an unlicensed game is not punishable. Winnings from operators holding a permit in Estonia or the EEA are exempt from income tax; winnings from other operators are taxable.

A licensee must maintain its capital, pay gambling tax monthly, transmit gaming data to EMTA electronically and undergo an annual audit.

• Capital and reserve. Equity must not fall below the statutory minimum; the reserve capital must be at least one third of the share capital and is built up through annual allocations of at least one seventh of net profit.
• The gambling tax return must be filed and the tax paid by the 15th day of the month following the reporting period.
• Electronic records. The operator’s accounting and control system is connected to EMTA’s information system via the state data exchange layer X-tee (X-Road) and transmits data on stakes, winnings and players.
• Since 2026, the auditor must confirm compliance with the capital and reserve requirements, the financial position, and the accuracy of the data underlying the tax returns (§ 10¹ HasMS). EMTA or the FIU may request the auditor’s report, which must be provided within seven days.
• Data retention. Player and game data must be kept on the server for at least five years and be accessible to the supervisory authorities.
• Any change in the information submitted for the licence or permit, such as a change of owners, managers, platform or game rules, must be reported to EMTA immediately.
• No recurring licence fees. The state fee is paid on application; the law provides for no annual licence fee.

Operators licensed before the reform have until 1 January 2027 to bring their activities into line with the new requirements.

Gambling operators are obliged entities under the Money Laundering and Terrorist Financing Prevention Act; supervision is carried out by the Financial Intelligence Unit (FIU).

• Risk assessment and procedures. A documented business-wide risk assessment, internal control rules and staff training.
• Customer due diligence. Due diligence measures apply when paying out winnings, accepting a stake, or both, where the amount is EUR 2,000 or more, whether in a single transaction or in linked transactions. In remote gambling, identity is verified when the player account is opened.
• Enhanced due diligence. For politically exposed persons, customers from high-risk countries and unusual transactions; verification of the source of funds.
• Monitoring and reporting. Ongoing monitoring of transactions and reporting of suspicious transactions to the FIU.
• Contact person. A person responsible for communication with the FIU must be appointed and be permanently resident in Estonia.
• Record keeping. Customer due diligence and transaction data must be kept for five years.
• Closed-loop principle. Payouts are returned to the same account or instrument from which the stake was made; payments may only pass through institutions authorised in the EEA.

The 2026 reform tightened controls at the point of entry: the FIU now takes part in reviewing licence applications, and the scope of information on beneficial owners and AML procedures has been expanded along the lines of § 70 of the Money Laundering and Terrorist Financing Prevention Act. The reform was prompted by the FIU’s findings of weak AML controls at some operators and a growing number of non-resident players from high-risk countries.

From 10 July 2027, the national rules will be replaced by the directly applicable Regulation (EU) 2024/1624 (AMLR).

The core measures are the age threshold, mandatory limits and the national self-exclusion register HAMPI.

• 21 for games of chance and remote games of chance and skill; 18 for totalisator and lotteries. The operator verifies the player’s age and identity before play begins.
• The register of persons with gambling restrictions is maintained by EMTA. Players impose the restriction themselves, by type of game, for a period of 6 to 36 months (to be verified). The operator must check every player against the register and must not admit those listed.
• In remote gambling, the player must set a weekly or monthly loss limit. An increase in the limit takes effect after 48 hours; a decrease takes effect immediately (§ 55 HasMS).
• Ban on credit. The operator may not grant or arrange credit for gambling.
• Players must have access to the game rules, information on risks and on the option of self-exclusion; advertising must carry the mandatory warning.
• Fairness of play. The average return to player must exceed 80%; the random number generator and software must be verified by an independent expert.

The Ministry of Finance is preparing an expansion of HAMPI: allowing family members and, possibly, a court to initiate a restriction, as well as reviewing online game mechanics and incentives.

The entire ownership structure must be disclosed; the key threshold is a qualifying holding, i.e. 10% or more.

• On application. Information on shareholders with a qualifying holding, beneficial owners and members of management bodies, as well as a list of companies in which the applicant or a management board member holds more than 25%.
• EMTA assesses the reputation of each such person, including indirect owners, and the origin of the funds contributed to the capital; since 2026, the application must also be approved by the FIU.
• Any change of shareholders, beneficial owners or managers must be reported to EMTA immediately. The law does not set out a separate prior-approval procedure for transactions, but the appearance of a person who does not meet the requirements is a ground for revoking the licence (to be verified against § 20 HasMS).
• Beneficial ownership register. Information on beneficial owners is entered in the commercial register under the general rules (25% threshold).
• Transfer of licence. The licence and permit are non-transferable; the business can only be sold through a sale of shares in the company.

EMTA may inspect operators, issue precepts, impose fines, suspend and revoke licences and permits, and block illegal websites.

• Access to data. On-site inspections, requests for documents, direct access to gaming data through the electronic reporting system, and access to the server.
• Precepts and coercive measures. A precept to remedy a violation, backed by a non-compliance levy; deficiencies in an application must be remedied within 30 days.
• Grounds include: false information, failure to continue meeting the capital or reputation requirements, repeated or material breaches of the law, non-payment of tax, and failure to commence operations.
• Precepts to internet service providers and payment intermediaries in respect of illegal operators.
• Related authorities. The FIU takes action for AML breaches; TTJA acts on advertising violations and may propose revocation of a permit.

Typical grounds for enforcement action:

• weaknesses in AML controls (the FIU fined operators in 2024);
• breaches of advertising rules (45% of the materials inspected by TTJA in 2025);
• operating on the Estonian market without a permit, the main reason for blocking;
• admitting persons listed in the HAMPI register or below the required age;
• late notification of changes to EMTA and failures in data transmission.

Remote gambling and totalisator are taxed at 5.5% of the difference between stakes and winnings (GGR); the law provides for a reduction of 0.5 percentage points per year, down to 4% from 1 January 2029.

Schedule for remote gambling and totalisator: 6% in 2025, 5.5% in 2026, 5% in 2027, 4.5% in 2028, and 4% from 2029. According to some sources, further reductions depend on revenue targets being met (to be verified). The previously planned increase to 7% has been cancelled.

Due to a drafting error in the Act of 3 December 2025, remote games of chance were left without a tax rate in January–February 2026. An amendment of 10 February 2026 restored the 5.5% rate from 1 March 2026, without retroactive effect.

Other taxes:

• Corporate income tax. 0% on retained profits and 22% on distribution.
• Gambling services are exempt from VAT; input VAT (standard rate 24%) is not deductible.
• Winnings from operators holding a permit in Estonia or the EEA are not subject to income tax.

Yes. Since 1 January 2026, the law expressly includes crypto-assets in the definition of a stake, but only within the regulated framework.

• Payment channel. A stake in remote gambling must be received through a credit institution, payment institution, e-money institution or crypto-asset service provider authorised in the EEA (§ 5(3) HasMS). Deposits directly from private wallets are excluded.
• The crypto-asset service provider must be authorised under Regulation (EU) 2023/1114; the transitional period for former Estonian licences ended on 1 July 2026.
• Enhanced controls, full traceability of funds, transaction monitoring and the closed-loop principle apply.
• Tax and reporting. Stakes in crypto-assets are recorded in the electronic reporting system and form part of the tax base under the general rules.
• Transitional period. Operators licensed before the reform must bring their payment arrangements into compliance by 1 January 2027.

Yes. The adopted amendments are taking effect in stages through 2029, and a second package of amendments on player protection is being prepared.

Supervision is shifting towards AML compliance and advertising, while the market is shifting towards international operators.

• AML supervision. The FIU and EMTA are checking compliance with the new rules on payments, audits and disclosure of beneficial owners; inspections of operators licensed before the reform are expected after 1 January 2027.
• Stricter vetting of applicants. The legislator openly anticipated that the new requirements would reduce the number of applications, particularly from smaller companies.
• Advertising. Following its 2025 review, TTJA will continue to monitor advertising on social media and by influencers; the question of further restrictions periodically returns to parliament.
• Player protection. Expansion of HAMPI and possible restrictions on game mechanics and bonuses.
• Finland. The opening of the Finnish market on 1 July 2027 changes the position of Estonian operators targeting Finnish players: they will need a Finnish licence.
• Preparing for the AMLR. Transition to uniform EU rules and AMLA technical standards.

Yes. The main risks are the political durability of the policy of attracting online operators and the tightening of AML requirements.

• Political risk. The tax-cutting policy has drawn criticism from experts and the opposition, which intensified after the drafting error that left online casinos untaxed for two months. The next parliamentary elections will be held in March 2027, and the reduction schedule may be revisited.
• AML risk. The FIU classifies remote gambling and operators with foreign owners as higher-risk areas. Stricter vetting and supervision increase the cost and duration of licensing.
• Small domestic market. With a population of 1.3 million, growth can come mainly from foreign players, and serving them requires licences in their countries of residence. Following the CJEU judgment in Case C-440/23 (16 April 2026), operating in another EU Member State without a local licence carries the risk of claims for the recovery of player losses.
• Finland. From 1 July 2027, the Finnish market becomes licensed, and an Estonian licence will no longer be a route to serving Finnish players.
• Advertising. Advertising of online casinos is effectively banned, which makes it difficult to launch a new brand on the local market.
• High entry threshold. The EUR 1 million capital requirement for games of chance rules out small start-ups.
• Banking and payments. Estonian banks are cautious about working with the sector, and the requirement to route payments through EEA institutions narrows the choice of providers.

Estonia combines an EU licence, one of the lowest online gambling tax rates in Europe and fully digital dealings with the state.

• Taxes. 5.5% of GGR in 2026, with a statutory reduction to 4% by 2029; 0% tax on a company’s retained profits.
• Indefinite licence with no annual fees. The activity licence has no expiry date; the state fee is paid once, on application.
• Predictable timelines. The law sets maximum review periods: 4–6 months for the licence and 2–4 months for the permit.
• Crypto-assets. One of the few EU jurisdictions where the law expressly permits stakes in crypto-assets through authorised providers.
• No local office requirement. The company may be registered in another EU Member State and the server may be located abroad; management can be handled remotely through e-Residency.
• Digital environment. Applications, reporting and data exchange with EMTA are handled electronically.
• Reputation. An EU licence backed by real supervision makes it easier to work with banks, payment providers and game suppliers than an offshore licence.
• Ecosystem. International gambling groups operate in Estonia, and there is a well-developed market of IT professionals.

Limitations a start-up should be aware of in advance: EUR 1 million in capital for casino products, no B2B licence, and an Estonian licence does not confer the right to operate in other EU countries.