Two Out of Several Dozen: How Ukraine Launches Gambling Market Monitoring Without Enforcement Mechanism

The DSOM is the first system that provides the state with data on gambling business transactions in real time. However, only two companies have connected to it so far, while the rest of the licensees have six months to do so — with no clearly defined penalties for delays.

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Native Apps and "Slots Uey" became the first companies to connect to the State System for Online Monitoring of Gambling Business (DSOM). Liga.net was informed about this by a government source. Against the backdrop of several dozen licensed market operators, this is still a symbolic start.

What the state sees after connection

Before the launch of DSOM, the regulator received market data retroactively in the form of reports for previous periods. This made it impossible to respond promptly to violations. Now each bet, payout, or refund is transmitted to the system as a separate transaction with a unique identifier — 24/7, without delays.

The first phase of DSOM is the financial core: the state sees bet acceptance, winnings payouts, and refunds to players. This is sufficient for controlling cash flows, but the system currently does not cover the internal mechanics of games.

"Right now we are in the final stages of seeking financing, because unfortunately the state budget did not allocate funds for this critically important system"

Head of PlayCity (State Agency for Gambling)

The second phase — analytics, control of gaming machine operations, compliance with responsible gambling principles, and accounting of gaming money substitutes — is expected in autumn 2026. Its estimated cost: 45 million hryvnia, but this figure may change due to exchange rates and market conditions.

Six months — and what next

All licensed operators have been given six months to connect to DSOM. The enforcement mechanism for ignoring this deadline has not been publicly detailed: PlayCity speaks of "gradual coverage of the entire licensed market" without clarifying what consequences non-compliance will entail.

  • First phase — transactional monitoring (bets, payouts, refunds). Already in test operation.
  • Second phase — advanced analytics and control of the gaming process. Tender in the near future, financing outside the state budget.
  • Market connection deadline — 6 months from the start of industrial operation.

The practical value of DSOM directly depends on the completeness of its coverage: a system connected to two operators out of several dozen gives the state not a picture of the market, but a fragment of it. The real test will occur not now, but in six months — when it becomes clear how many companies connected voluntarily and how many had to be nudged.

If the regulator does not publish a list of those who missed the deadline and does not apply specific measures, the question about DSOM's real function will remain open: is it a control tool or voluntary reporting in a new format.

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