Casino Advertising Fines: How Ukraine Moves to Enforcement and What It Means for Bloggers
The Ukrainian market for gambling advertising is entering a phase that effectively did not exist before, the phase of real enforcement of sanctions. The appearance of the first enforcement proceedings in the Unified Register of Debtors for unpaid fines for illegal advertising of online casinos has become a marker that the state is no longer limiting itself to formal decisions by the regulator. For the first time in a long while, sanctions are ceasing to be declarative and are beginning to have practical consequences. The key point in this story is not the names of individual bloggers, but a break in the logic of accountability. Previously, fines for illegal gambling advertising remained for years in a zone of appeals, procedural refusals, and court pauses. Now, some decisions have moved into the stage of compulsory execution. This means that the state is demonstrating readiness not only to record violations, but to carry cases through to the end.
According to Opendatabot, the register has recorded the first active proceedings to recover multi-million-hryvnia fines. At the same time, the overall picture shows that none of the fines has been paid voluntarily. The law gives violators up to three months for voluntary payment, and part of this period has not yet expired. But the very fact that cases have been transferred to compulsory enforcement indicates that the regulator does not intend to wait for years. In parallel, a judicial front is taking shape. Some bloggers and one media outlet have decided to challenge the regulator’s decisions. In total, cases concerning eight fines are currently before the courts. This is an expected scenario. The market is testing the boundaries of the new approach, and the courts are effectively being asked to answer a key question: are sanctions for illegal gambling advertising legally resilient. The regulator in this area is PlayCity. Its position has been publicly stated and is quite firm. The agency emphasizes that it is consistently building a practice of holding violators accountable and intends to defend its position in court. This matters, because without stable judicial practice any sanctions risk once again turning into a formality.
Separate attention should be paid to the mechanics of punishment. A fine cannot be imposed automatically on a social media page. The state must legally establish a link between an account and a specific individual or legal entity. This is a complex and slow process, but it is precisely what makes sanctions less vulnerable to being overturned. Blocking of pages is possible only through Meta platforms after verification of violations. In other words, the regulator does not have a direct tool for instant blocking and is forced to work through international platforms. In fact, we are witnessing a transition from chaotic reactions to a systemic control model, where each stage has a legal foundation. This is why some earlier attempts to open enforcement proceedings ended in refusals due to procedural issues or the start of court challenges. These mistakes have now been taken into account, and the first cases are reaching the stage of recovery.
This process does not exist in a vacuum. In parallel, the state is launching the State Online Monitoring System for the gambling business, which is intended to provide a full picture of financial flows in the gambling sector. At the first stage, the system will record:
- bets
- payouts of winnings
- refunds
- top-ups of player balances
Later, control will be expanded to include game results, operation of gambling machines, compliance with responsible gambling principles, and accounting for transactions with gambling substitutes of the hryvnia. The Ministry of Digital Transformation of Ukraine emphasizes that the system will work with depersonalized data and will allow a transition to a data-driven approach in market regulation.
Taken together, these steps create a new reality for influencers, media, and the advertising market as a whole. Gambling advertising is ceasing to be a grey zone, where the maximum risk is limited to reputational losses. It is now a zone of financial and legal liability with real consequences. However, the final outcome depends on the courts. It is they who will determine whether compulsory recovery of fines becomes a stable practice or whether the market once again finds ways to hide behind procedural loopholes. But the very appearance of the first enforcement proceedings shows that the state has taken a step it long hesitated to take. And now the question is not whether there will be new fines, but whether there will be enough political and legal resilience to bring this story to a systemic result.
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