ESTONIA Trends and Developments Contributed by: Karolina Ullman, Triin Kaurson, Linell Raud and Felix Raidmäe, NJORD Law Firm
tiveness compared to other countries. The draft leg- islation seeks to establish a taxation system where a fixed base amount remains in the state budget, with additional revenue generated from actual market growth. The vote on the draft is expected to take place before the end of 2025. Supporting sport and culture through gambling tax In conjunction with the proposed decrease in the gam- bling tax rate, the draft law amendment also aims to redefine how the tax collected from gambling opera- tors is distributed. A portion of the gambling tax is earmarked for the Estonian Cultural Endowment ( Eesti Kultuurkapital ), which allocates funds between culture and sport. From a cultural perspective, the funds are primarily directed towards the construction and maintenance of cultural buildings. On the sporting front, the focus is on building and maintaining various sports facili- ties across Estonia. This approach underscores the government’s commitment to supporting cultural and sporting initiatives, leveraging the gambling tax as a The regulation of gambling advertisements is contin- gent upon the type of licence held by the gambling operator, making it susceptible to conflicts with exist- ing laws and practices. While the law provides specific guidelines, it is challenging to anticipate and regulate every possible scenario. The Consumer Protection and Technical Regulatory Authority (TTJA) serves as the regulator in this domain. means to enhance these sectors. Review of gambling advertisements The TTJA has published guidelines with specific examples regarding gambling advertisements and, in spring 2025, it released updated guidelines. In 2023, the TTJA conducted inspections of gambling advertisements from companies holding an Estonian licence. The list of monitored brands was compiled based on advertisements identified by officials and reported as violations by the public. The sample included 19 gambling operators, with vio- lations found in the advertisements of 15 operators.
For four operators, no advertisements were identified during the observation period. Of the 152 advertise- ments reviewed, 150 were initially assessed by the TTJA as not meeting the requirements. The main violations included missing or inadequate warning text (in 128 cases), advertisements contain- ing calls to action or references to social success (in 133 cases), and the publication of prohibited gambling advertisements (in 26 cases). Although the TTJA has not conducted additional market reviews since 2023, this scrutiny has heightened awareness of gambling advertisement regulations and prompted operators to adopt a more proactive approach. When planning new advertisements that may not comply with laws and regulations, operators have reached out to the TTJA Over the past five years, the Tax and Customs Board has conducted only one misdemeanour proceed- ing, resulting in a legal entity being fined EUR2,000 for organising prohibited gambling. In the same pro- ceeding, a natural person was fined EUR320. Anoth- er misdemeanour proceeding is currently underway. The ability to detect and process misdemeanours has been hampered by limited personnel and the high cost of proceedings, given the maximum possible fine amount. The draft law currently under discussion in the Riigikogu proposes raising fine amounts ten-fold. According to the explanatory notes, this increase will enable the authorities to address misdemeanours in accordance with their actual impact on society. Rais- ing the fine rates is deemed necessary to ensure that the cost of committing a violation is not lower than its potential profit, thereby effectively curbing violations in the gambling sector. Additionally, updating the fine rates will help cover the costs incurred by the state in conducting misdemeanour proceedings in the future. The continuous popularity of the Estonian gambling licence Many working in this line of business had expected the popularity of the Estonian licence to flatten out, as the country’s neighbour, Finland, will introduce its gambling licences in 2026. So far, no slowing down for guidance and approval. Possible increase in the fines
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