Licensed by the Estonian FIU · FIU000117Registry code 12233761Operating since 2014Punane 6, Tallinn 13619

info@micaconsult.com+372 5089565

EN · ET · RU · DE · PL · FI · UA · FR · NL · SV · PT · DA · NO · CS · LV · LT · IT · ES · TR · MX · 繁中 · 简中 · AR · BG · RO

English

EnglishEestiРусскийDeutschPolskiSuomiУкраїнськаFrançaisNederlandsSvenskaPortuguêsDanskNorskČeštinaLatviešuLietuviųItalianoEspañolTürkçeEspañol (México)繁體中文简体中文العربيةБългарскиRomână

LexorCorp Global Order

Guide

Commercial lottery in Estonia

A commercial lottery is a prize draw that a seller of goods or services runs to promote its sales or its brand.

LexorCorp Global OÜ · published 11 November 2026

This page in other languages

Eesti

In short

A commercial lottery is a prize draw that a seller of goods or services runs to promote its sales or its brand. In Estonia the Gambling Act's chapter on gambling operators does not apply to it 12 , but when the prize fund is above 10,000 euros the organiser must file a notice of economic activities with the Estonian Tax and Customs Board 7 4 before the activity starts 19 and pays gambling tax on the prize fund 13 29 . The prize fund may not exceed 100,000 euros 15 .

Order the application documents: Order

A commercial lottery is a prize draw that a seller of goods or services runs to promote its sales or its brand. In Estonia the Gambling Act's chapter on gambling operators does not apply to it12, but when the prize fund is above 10,000 euros the organiser must file a notice of economic activities with the Estonian Tax and Customs Board74 before the activity starts19 and pays gambling tax on the prize fund1329. The prize fund may not exceed 100,000 euros15.

Information as of 11 November 2026. Every numbered statement of this page was checked in the official text named below and re-checked by a second reviewer on 2026-11-11. The page is general information, not legal advice; the authority decides on every application.

What the activity is

The Gambling Act (hasartmänguseadus, HasMS) defines a commercial lottery as a classic or instant lottery organised by a provider of goods or services to promote the sale of goods or services, or to advertise the goods, services or their provider1. In a classic lottery the organiser determines the result after the offer to take part has closed; in an instant lottery the result is fixed among the tickets before purchase and is revealed when the player opens the play area2.

The right to take part is acquired together with the purchase of the goods or service, and the organiser may not demand any additional payment or other property obligation from participants3.

What is not covered:

  • a commercial lottery with a prize fund of up to 10,000 euros — the requirements of the Gambling Act do not apply to it at all4;
  • a lottery other than a commercial lottery — it needs a lottery operating permit and is not described here5;
  • games of chance, betting and other gambling (covered on a separate page).

The prize fund is the sum of the money values of all possible prizes; where a prize is a thing or a property right, its usual value is used6.

The legal act and the authority

  • Gambling Act (hasartmänguseadus), in particular § 6 and §§ 47–4817.
  • General Part of the Economic Activities Code Act (majandustegevuse seadustiku üldosa seadus, MSÜS) — the general rules on the notice of economic activities8.
  • Gambling Tax Act (hasartmängumaksu seadus, HasMMS) — the tax on the prize fund13.
  • Authority: the Estonian Tax and Customs Board (Maksu- ja Tolliamet, MTA) receives the notice7 and exercises state supervision over the organisation of gambling9. It may check whether the result of a commercial lottery was determined at random and in line with the game rules10.
  • Register: the notice is entered in the Register of Economic Activities (majandustegevuse register, MTR)8. Besides the general data, the register shows the game rules, the participation period, the place, manner and date of determining and publishing the result, and the value of the prize fund11.

Who must file a notice

Any provider of goods or services that organises a commercial lottery whose prize fund exceeds 10,000 euros must file a notice of economic activities with the MTA74. No activity licence or operating permit is needed: the Act states that its chapter on gambling operators (licences) does not apply to commercial lotteries12, and the operating-permit rule excludes the commercial lottery expressly5.

Exemptions the acts name:

  • prize fund of up to 10,000 euros — outside the Gambling Act4;
  • undertakings providing the services listed in § 6(1) points 4 and 5 of the Credit Institutions Act have no notice obligation under HasMS § 48(4)14.

Requirements for the organiser

Chapter 2 of the Act (gambling operators) does not apply to a commercial lottery12; whether other requirements apply is specified for the client's situation. What the act does require:

  • Prize-fund ceiling: at most 100,000 euros15.
  • No separate fee: participation comes only with the purchase; no extra charge3.
  • Game rules approved by a decision of the management board, containing: the organiser's business name and registry code; a description of the game, including conditions and procedure of participation; the probability of winning (or, if it cannot be stated as a number, the rules for determining the winner and the prize); the place, procedure and final date for handing out prizes; and the procedure and time limit for resolving players' complaints16.
  • In addition, the rules of a commercial lottery state: the time, place and procedure for determining and publishing the results of a classic lottery; for an instant lottery, the print run of tickets and the start and end dates; and data on the prizes, including the money value of each prize17.
  • Random result: the MTA may verify randomness and compliance with the rules10.
  • The general organiser duties of HasMS § 33 and the age limit of § 34(3) (no lotteries for under-18s) do not apply to a commercial lottery12.

Breach of the prize-fund limit or charging a separate fee for participation is a misdemeanour; for a legal person the fine is up to 20,000 euros18.

What the notice contains

The notice is filed before the activity starts19. It contains:

General data (MSÜS § 15(1))20

  • name and registry code of the company; contact details;
  • the statutory name of the field of activity and its classification code;
  • the start date (if different from the filing date) and the end date if the activity is for a fixed period;
  • name and contact details of the signatory and the basis of their right of representation.

Commercial-lottery data (HasMS § 48(2))21

  • start and end dates of participation;
  • place, manner and date of determining and publishing the result;
  • place, manner and period for handing out prizes;
  • the value of the prize fund.

The game rules are entered in the register11. A change in the general data must be notified without delay and no later than within five working days22.

State fee, tax and timing

  • State fee: none when the notice is filed through the single point of contact — the Estonian state portal (eesti.ee) or a notary23. Filed any other way, the State Fees Act sets a fee of 10 euros24.
  • Registration time: the registrar enters the data no later than the working day after the notice is filed25. This is the law's time limit, not a promise.
  • Gambling tax: the object of tax is the prize fund of a commercial lottery when its value exceeds 10,000 euros13. The rate is 22 per cent26. The tax period is the lottery period, from the first day of participation to the last day of handing out prizes in the game rules27; the declaration is filed and the tax paid to the MTA by the 15th day of the following calendar month28. The tax is paid by the organiser29. Other tax consequences (for example for winners) are specified for the client's case.

What LexorCorp Global OÜ does and how to order

LexorCorp Global OÜ (registry code 12233761) has no separate service row for commercial lotteries. The work is ordered under the row Activity licence application documentation, from €3,500, one-time; no VAT is added. State fees, where they apply, are paid by the client.

Under that row we:

  • set out the requirements of the act for the activity from its official text — here the Gambling Act provisions above;
  • prepare the documents and make the submission through the Register of Economic Activities, and follow up the authority's questions in writing.

We do not give legal advice, audit or tax advice, and we cannot promise any result, date or decision of the MTA.

Order: order form

Sources

  1. Gambling Act § 6 — text in force from 01.01.2026 (RT I, 30.12.2025, 9)
  2. Gambling Act § 4(2) — text in force from 01.01.2026 (RT I, 30.12.2025, 9)
  3. Gambling Act § 47(1) — text in force from 01.01.2026 (RT I, 30.12.2025, 9)
  4. Gambling Act § 2(5) p 4 — text in force from 01.01.2026 (RT I, 30.12.2025, 9)
  5. Gambling Act § 22(1) p 5 — text in force from 01.01.2026 (RT I, 30.12.2025, 9)
  6. Gambling Act § 2(4) — text in force from 01.01.2026 (RT I, 30.12.2025, 9)
  7. Gambling Act § 48(1) — text in force from 01.01.2026 (RT I, 30.12.2025, 9)
  8. MSÜS § 8(1), § 58(1) p 1 — text in force from 01.09.2025 (RT I, 02.01.2025, 26), valid until 31.12.2026
  9. Gambling Act § 66 — text in force from 01.01.2026 (RT I, 30.12.2025, 9)
  10. Gambling Act § 47(4) — text in force from 01.01.2026 (RT I, 30.12.2025, 9)
  11. Gambling Act § 48(3) — text in force from 01.01.2026 (RT I, 30.12.2025, 9)
  12. Gambling Act § 47(2); chapter 2 heading 'Hasartmängukorraldaja'; § 34(3) — text in force from 01.01.2026 (RT I, 30.12.2025, 9)
  13. Gambling Tax Act § 1(1) p 3 — text in force from 01.03.2026 (RT I, 18.02.2026, 2), valid until 31.12.2026
  14. Gambling Act § 48(4) — text in force from 01.01.2026 (RT I, 30.12.2025, 9)
  15. Gambling Act § 47(5) — text in force from 01.01.2026 (RT I, 30.12.2025, 9)
  16. Gambling Act § 35(1) — text in force from 01.01.2026 (RT I, 30.12.2025, 9)
  17. Gambling Act § 47(3), § 43 p 2–4 — text in force from 01.01.2026 (RT I, 30.12.2025, 9)
  18. Gambling Act § 97 — text in force from 01.01.2026 (RT I, 30.12.2025, 9)
  19. MSÜS § 14(1) — text in force from 01.09.2025 (RT I, 02.01.2025, 26), valid until 31.12.2026
  20. MSÜS § 15(1) — text in force from 01.09.2025 (RT I, 02.01.2025, 26), valid until 31.12.2026
  21. Gambling Act § 48(2) — text in force from 01.01.2026 (RT I, 30.12.2025, 9)
  22. MSÜS § 30(5) — text in force from 01.09.2025 (RT I, 02.01.2025, 26), valid until 31.12.2026
  23. MSÜS § 9(1) and (6) — text in force from 01.09.2025 (RT I, 02.01.2025, 26), valid until 31.12.2026
  24. State Fees Act § 345 — text in force from 01.11.2026 (RT I, 21.10.2026, 10), valid until 31.12.2026
  25. MSÜS § 59(2) — text in force from 01.09.2025 (RT I, 02.01.2025, 26), valid until 31.12.2026
  26. Gambling Tax Act § 6 p 5 — text in force from 01.03.2026 (RT I, 18.02.2026, 2), valid until 31.12.2026
  27. Gambling Tax Act § 3(2) — text in force from 01.03.2026 (RT I, 18.02.2026, 2), valid until 31.12.2026
  28. Gambling Tax Act § 4(1) — text in force from 01.03.2026 (RT I, 18.02.2026, 2), valid until 31.12.2026
  29. Gambling Tax Act § 2 — text in force from 01.03.2026 (RT I, 18.02.2026, 2), valid until 31.12.2026

Official sources

The laws this article names, each linked to its official text, as read on 9 October 2026. For the Estonian acts we read the English translation in Riigi Teataja; the legally binding text is the Estonian one.

Sources in the text are named without links; the official texts are linked under Official sources. To see which of our services your company needs, open the Business Navigator.

Order the application documents

We prepare the application documents and manage the process; the authority decides. Not legal advice.

Order All licensed activities