Organising gambling in Estonia: activity licence and operating permit

A company that wants to run casino games, betting or games of skill in Estonia, on site or online, needs two decisions of the Estonian Tax and Customs Board: first an activity licence for the type of gambling, then an operating permit for each gaming location or for remote gambling¹²¹⁴. Below: the requirements, the application contents, state fees, statutory time limits and what LexorCorp Global OÜ prepares.

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

Under the Gambling Act (hasartmänguseadus, HasMS), a game is gambling when the player places a stake, can win a prize, and the result depends wholly or partly on chance or on an event not known in advance¹. The act names four types: games of chance, lotteries, toto and games of skill (the result depends predominantly on the player's dexterity, skill or knowledge)².

Remote gambling is gambling in which the game is played and the result determined outside a gaming location through an electronic device, including on the internet, or in which stakes are accepted and prizes paid through an electronic device³. The act does not apply, among others, to a game of skill whose only prize is another play of the same game, to sports competitions, and to small lotteries within the prize-fund limits it sets⁴. Trading in derivatives within the meaning of the Securities Market Act is not gambling⁵.

The legal act and the authority

The governing act is the Gambling Act in the wording in force from 1 January 2026⁶. Gambling operators, except organisers of commercial lotteries, are also obliged entities under the Money Laundering and Terrorist Financing Prevention Act (RahaPTS)⁷. Gambling tax is governed by the Gambling Tax Act (hasartmängumaksu seadus) and is not described here⁸.

The competent authority is the Estonian Tax and Customs Board (Maksu- ja Tolliamet, ETCB), which grants, refuses and revokes activity licences⁹. Before granting an activity licence the ETCB must obtain the approval of the Financial Intelligence Unit (Rahapesu Andmebüroo, FIU)¹⁰. According to the ETCB, operating permits are registered in the Register of Economic Activities (majandustegevuse register, MTR), and the ETCB publishes a "List of legal gambling operators"¹¹.

Who must apply

A games-of-chance, toto or games-of-skill operator must be a reliable legal person holding both an activity licence and an operating permit¹². The activity licence gives the right to apply for operating permits; it is issued separately for games of chance, toto and games of skill, is valid without a time limit and cannot be transferred¹³. Operating permits are issued separately for each gaming location and type of game, for toto, for each type or subtype of gambling organised as remote gambling, and for a lottery¹⁴. Except where the act provides otherwise, only an activity licence holder receives an operating permit¹⁵.

Main exceptions:

• A lottery needs only an operating permit, and only a public limited company with share capital of at least EUR 1,000,000 wholly owned by the Estonian state may organise lotteries¹⁶.
• A commercial (promotional) lottery needs no licence or permit; a notice of economic activities is submitted instead¹⁷.
• According to the ETCB, a licence from another European Economic Area (EEA) state does not give the right to offer gambling in Estonia¹⁸.

Requirements for the applicant

• Legal form and capital. A public or private limited company with share capital of at least EUR 1,000,000 for games of chance, EUR 130,000 for toto and EUR 25,000 for games of skill¹⁹. An additional reserve of at least one third of the share capital is required unless equity is at least half of assets²⁰.
• Sole activity. Gambling must be the only business; the operator may add only catering, leisure and cultural events, and support services to its own group²¹.
• Owners and management. No qualifying holder, beneficial owner or management body member may have a criminal record, have sat on the management body of a company that ran gambling without a licence or lost its licence on certain grounds, or have caused a company's insolvency by serious mismanagement²². A qualifying holding is a direct or indirect holding of at least 10 per cent or significant influence over management²³. The ETCB weighs, among other things, the organisational and technical level of the activity, the origin of the share capital, the management's experience and reputation, and tax behaviour of the last three years²⁴.
• AML/CFT. A risk assessment, procedural rules and internal control rules under the RahaPTS²⁵, and an FIU contact person who works permanently in Estonia and whose appointment the FIU approves; the FIU does not approve the application if these requirements are not met²⁶.
• Remote gambling. Stakes must be received through a credit, payment or e-money institution or crypto-asset service provider licensed in an EEA state²⁷. The operator must keep under-age players out, identify every player and keep records of stakes and payouts for at least five years²⁸; games of chance and remote games of skill are not open to persons under 21, and toto and lotteries not to persons under 18²⁹. Before first play, a weekly or monthly loss limit must be offered³⁰. Permits for a games-of-chance location, for toto and for remote gambling require the electronic recordkeeping and control system to be connected to the ETCB's information system³¹. A server outside Estonia needs proof that its state's gambling supervisor and anti-money-laundering authority can cooperate with the ETCB and FIU, unless that state has joined the Convention on Cybercrime or its authorities have a cooperation agreement with the ETCB and FIU³².

Documents filed with the application

Activity licence. The application states the type of gambling and the name, position and signature of the person who completed it and contains the data of RahaPTS § 70(3) points 3–11 and (3¹)³³:

• Ownership: for an applicant not in the Estonian commercial register, its owners and beneficial owners³⁴.
• People: education, employment history and reputation documents of management members and the procurator; for foreign nationals, identity documents for every citizenship and a criminal record certificate of the country of origin no older than three months, legalised or apostilled, with a sworn statement where it falls short³⁵.
• AML/CFT and sanctions: procedural and internal control rules, the FIU contact person and the person responsible for international financial sanctions³⁶.
• Accounts: the list of payment accounts in the applicant's name³⁷.

The ETCB may also ask for the articles of association and data on companies in which the applicant or its board members hold more than 25 per cent³⁸.

Operating permit. The application names the applicant, the type or subtype of gambling, the location or (for remote gambling) the address of the server holding the software, the contact person, the requested validity and the date the state fee was paid³⁹. For remote gambling it attaches data on the software, an independent expert assessment of the software's compliance with HasMS § 54, the internet addresses used for play and the payment accounts between operator and players⁴⁰. A land-based location also needs the local government's written consent⁴¹.

State fee and processing time

State fees under the State Fees Act (riigilõivuseadus)⁴²:

The ETCB decides on an activity licence within four months of receiving all necessary documents and information, and no later than six months after the application⁴³; the FIU decides on its approval within 60 days of receiving all required documents¹⁰. On an operating permit the ETCB decides within two months of receiving all necessary documents, and no later than four months after the application⁴⁴; an expert examination can extend this by up to two months⁴⁵. The ETCB may request further information from the applicant⁴⁶. These are the law's time limits, not a promise. A remote-gambling operating permit is issued for up to five years⁴⁷.

What LexorCorp Global OÜ does and how to order

LexorCorp Global OÜ prepares the application for the gambling activity licence (tegevusluba) and the preparation for the operating permit (korraldusluba) under the Gambling Act, prepares the application file with the AML and responsible gambling documents, and manages the Tax and Customs Board's questions. As an add-on it prepares responsible gambling and player protection procedures: the player protection policy, age and identity verification, self-exclusion (including the national register), deposit and loss limits, and problem-gambling indicators and intervention.

The client provides the information, capital and people meeting the legal requirements, signs and answers the authority's questions. Not included: state fees, and certification and technical implementation of the gaming system. LexorCorp Global OÜ gives no legal or tax advice and does not audit. The Tax and Customs Board grants or refuses the licence and permits; no date or decision is promised. LexorCorp's own FIU licence (FIU000117) covers its trust and company services and does not authorise the client.

Order on the licensed companies page: order form.

Sources

1. HasMS § 2(1) — text in force from 01.01.2026
2. HasMS § 3 — text in force from 01.01.2026
3. HasMS § 5(1) — text in force from 01.01.2026
4. HasMS § 2(5) — text in force from 01.01.2026
5. HasMS § 2(6¹) — text in force from 01.01.2026
6. Riigi Teataja header, HasMS — text in force from 01.01.2026
7. RahaPTS § 2(1) p 3 — text in force from 21.07.2026
8. Hasartmängumaksu seadus, title — text in force from 01.03.2026
9. HasMS § 16(3) — text in force from 01.01.2026
10. HasMS § 18(3¹), § 19(2) p 3 — text in force from 01.01.2026
11. ETCB, List of legal gambling operators — text in force from page last updated 30.10.2026
12. HasMS § 9(1) — text in force from 01.01.2026
13. HasMS § 16(1)-(2) — text in force from 01.01.2026
14. HasMS § 22(1) — text in force from 01.01.2026
15. HasMS § 22(2) — text in force from 01.01.2026
16. HasMS § 9(1), § 9(5) — text in force from 01.01.2026
17. ETCB, Applying for permits — text in force from page last updated 26.02.2026
18. ETCB, Applying for permits — text in force from page last updated 26.02.2026
19. HasMS § 9(4), (6), (7) — text in force from 01.01.2026
20. HasMS § 10(2), (6) — text in force from 01.01.2026
21. HasMS § 9(2) — text in force from 01.01.2026
22. HasMS § 9(3) — text in force from 01.01.2026
23. HasMS § 11(1) — text in force from 01.01.2026
24. HasMS § 18(1), (3) — text in force from 01.01.2026
25. RahaPTS §§ 13(1), 14(1); HasMS § 17(1) via RahaPTS § 70(3) p 5 — text in force from 21.07.2026
26. RahaPTS § 17(5); HasMS § 18(3²) — text in force from 21.07.2026
27. HasMS § 5(3) — text in force from 01.01.2026
28. HasMS § 53(1), (3) — text in force from 01.01.2026
29. HasMS § 34(2)-(3) — text in force from 01.01.2026
30. HasMS § 55(1) — text in force from 01.01.2026
31. HasMS § 22(2¹) — text in force from 01.01.2026
32. HasMS § 26(2) p 5, § 52(3)-(4) — text in force from 01.01.2026
33. HasMS § 17(1) — text in force from 01.01.2026
34. RahaPTS § 70(3) p 3 — text in force from 21.07.2026
35. RahaPTS § 70(3) p 8–10, (3¹) — text in force from 21.07.2026
36. RahaPTS § 70(3) p 5–7 — text in force from 21.07.2026
37. RahaPTS § 70(3) p 11 — text in force from 21.07.2026
38. HasMS § 17(3) — text in force from 01.01.2026
39. HasMS § 23(1), § 26(1) p 1 — text in force from 01.01.2026
40. HasMS § 26(2) — text in force from 01.01.2026
41. HasMS § 23(2) p 1, § 27(1) — text in force from 01.01.2026
42. RLS §§ 260, 261(1)-(2) — text in force from 01.11.2026
43. HasMS § 18(4) — text in force from 01.01.2026
44. HasMS § 22(4) — text in force from 01.01.2026
45. HasMS § 23(3) — text in force from 01.01.2026
46. HasMS § 18(2), § 28(1) — text in force from 01.01.2026
47. HasMS § 26(1) — text in force from 01.01.2026

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.

• Gambling Act — Riigi Teataja, English translation
• Money Laundering and Terrorist Financing Prevention Act — Riigi Teataja, English translation
• State Fees Act — Riigi Teataja, English translation

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.