ESTONIA Law and Practice Contributed by: Karolina Ullman, Triin Kaurson, Linell Raud and Felix Raidmäe, NJORD Law Firm
1. Introduction 1.1 Current Outlook and Recent Changes Operators in the Estonian Market Currently, there are around 42 licensed gambling operators in the Estonian market (both online and land-based). This number is not impressive, but it needs to be understood in the context that Estonia is a small country with 1.3 million inhabitants. Out of the licensed operators, there are some with a stable local presence (including land-based facilities), such as the Olympic Entertainment Group and Novoloto (Fenix Casino), but also some regional operators such as: • Paf, Åland’s (a partly self-governed part of Finland) publicly held organisation; • NinjaCasino and CoolBet, with a strong focus on the Nordics; and • the big international players. Out of the total of 42 licensed gambling operators, 17 licences have been issued to foreign legal entities. In 2025, a new land-based casino commenced opera- tions in Estonia – Bombay Club (Kopikas Entertain- ment OÜ). Sector Developments Carrying on from previous years, the authors have noticed a consistent increase in interest in Estonian online licences. The Estonian digital landscape attracts international companies due to the convenience of the e-residency programme, which allows companies to be managed digitally from anywhere with an internet connection, and the wide range of digital services offered by the public authorities, including the regu- lator, as well as co-operation partners. During the previous five years, there has been a steady increase in the online market, as well as a steady decrease in the offline market. Professional advisers expect the online market to continue growing in the coming years, in line with international trends, although a flattening out in Estonia was anticipated as neighbouring Finland is set to offer gambling licences in 2026. So far, no decrease can be seen. The land- based market is expected to remain the same, mainly due to the difficulties in achieving consent from the
local municipalities, and higher costs than online gam- bling. Heightened Scrutiny Public scrutiny of gambling operators and related risks has risen, driven by investigative reporting and debates over tax policy and AML/CFT implications. Media tests of onboarding and payments have pres- sured stakeholders and informed the public. The Esto- nian Tax and Customs Board has tightened its review practice by issuing detailed feedback and applying narrower interpretations of law. Even minor chang- es like adding brands or updating terms and condi- tions (T&Cs) now trigger iterative queries and system adjustments. The Consumer Protection Board’s 2025 guidelines further tightened advertising compliance by clarifying rules and providing examples, prompting heightened marketing supervision and more brands to seek pre- clearance. The Financial Intelligence Unit has also intensified scrutiny of gambling since late 2023 by issuing AML questionnaires and signalling formal reviews (from 2024). Operators must align procedures with Estonian law and be ready to submit documentation in Esto- nian, as the Financial Intelligence Unit operates only in Estonian. A recent risk assessment flagged remote gambling as highly exposed, and the Financial Intelli- gence Unit warns that weak crypto controls and KYC/ source of funds checks may trigger licensing risks. Legislative Changes The Gambling Act The Gambling Act entered into force on 1 January 2009 and there have been only minor changes made to it. The Gambling Tax Act There are, however, recent and forthcoming changes in the Gambling Tax Act. These include an increase in the tax rate for remote gambling and toto (sports betting) from 5% to 6% in 2024, with a further rise to 7% in 2026. Lotteries and commercial lotteries saw their tax rate increase from 18% to 22% in 2024. Furthermore, the tax for gaming tables rose from
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