Ukraine iGaming marketing: PlayCity-compliant growth under Law 768-IX

Marketing for licensed casino and sportsbook operators in Ukraine: SEO, affiliates, media buying and CRM within Law 768-IX and PlayCity ad rules.

An iGaming marketing agency in Ukraine plans and runs player acquisition, SEO, content, media buying, affiliate and CRM programmes for operators that hold a Ukrainian licence, and keeps every placement inside the advertising rules. A licensed operator can legally advertise only in specific channels: on its own website and app, on TV and radio between 23:00 and 06:00, in registered online media for adults over 21, and on platforms and search engines that can target over-21 users (Law of Ukraine "On Advertising", Article 22-1). Advertising for a business without a Ukrainian licence is prohibited outright.

Ukraine legalised gambling under Law No. 768-IX of 14 July 2020, which permits online casino, online poker and bookmaking under separate licences. The framework was rewritten by Law No. 4116-IX of 4 December 2024, which came into force on 1 April 2025 (with some exceptions). It added stricter advertising rules, mandatory player limits and a new regulator. The old Commission for the Regulation of Gambling and Lotteries (KRAIL) no longer runs the market. Since 2025 the regulator has been the State Agency of Ukraine PlayCity, a central executive body that implements state policy on gambling and lotteries (Cabinet of Ministers Resolution No. 505 of 2 May 2025).

Basher works in Ukraine only with operators that hold a Ukrainian licence. We do not work with offshore brands targeting Ukrainian players, including those holding only a Curaçao or Anjouan licence, which PlayCity lists as a warning sign of an illegal casino.

Market snapshot 2026

  • Regulator: State Agency of Ukraine PlayCity (successor to KRAIL), playcity.gov.ua
  • Governing law: Law No. 768-IX as amended, most recently by Law No. 4574-IX of 21 August 2025; advertising rules in Article 22-1 of the Law "On Advertising"
  • Online licence types: online casino, online poker, and bookmaking (which covers both betting shops and the internet) (Article 44)
  • Licence term and fee: 5 years each. Online casino costs 6,500 minimum wages, online poker 5,000 and bookmaking 30,000 (Articles 53, 54 and 56)
  • Who can apply: a Ukrainian company (PlayCity licensing portal)
  • One licence, one brand: each licence allows a single brand, or a group brand for members of a group of organisers (Article 44(2))
  • Website: a domain in the .UA zone, notified to the regulator, with mandatory disclosures in Ukrainian (Article 24)
  • Minimum player age: 21 (Article 18)
  • Online identification: electronic signature, MobileID, BankID or other permitted methods (Article 17(4))
  • Player limits (online): spending capped at 15% of self-declared average monthly income per day, 25% per week and 40% per month. Play time is capped at 6 hours per day, 21 per week and 100 per month, with no more than 2 hours of continuous play before a 15-minute break (Ministry of Digital Transformation Order No. 207 of 26 December 2025)
  • Fine for advertising violations: 600 minimum wages per violation, imposed by the regulator (Article 59)

Why this market is hard to enter

The first constraint is the channel map. Ukraine does not ban gambling advertising outright. Instead it bans everything except a list of allowed channels (Article 22-1(1)). Outdoor, transport and print outside specialist titles are not on that list. TV and radio are limited to 23:00-06:00. Platforms and search engines are only allowed where they can technically target users over 21. The regulator's own guidance names social networks, street and transport placements, broadcast before 23:00 and ads without the operator's licence number as signs of illegal advertising (PlayCity, illegal gambling advertising). In practice, operators should treat social media as a high-risk channel that needs legal sign-off for each placement.

The second constraint is creative. Since the 4116-IX amendments, gambling ads cannot feature people under 21, military personnel, volunteers, doctors or anyone dressed to look like them. They also cannot feature "popular persons" (media figures, creators, public figures and monetised social accounts), except athletes, and cannot use film, TV or cartoon characters (Article 22-1(2)). Ads cannot suggest winning is easy or that gambling can replace work or income (Article 22-1(3)). Every ad must carry a fixed text or audio warning covering at least 15% of the ad, black on white, plus the licence number, date and issuing body (Article 22-1(5) and (9)).

The third constraint is promotions. The advertising law prohibits offering free bonuses in place of a stake, compensating players for the cost of access, and making calls or sending messages about gambling to an undefined group of people (Article 22-1(1)). The gambling law separately bans any bonus, gift or incentive triggered by a player losing (Article 15). Acquisition models built on deposit bonuses and outbound SMS do not transfer.

How Basher executes here

For Ukraine we typically prioritise four services:

  • SEO and content. The operator's own website and app are explicitly permitted advertising channels. That makes organic search and on-site content the most durable channel. We build Ukrainian-language content for casino, betting and poker terms, including mandatory disclosures and responsible-gambling material. The law requires site information in the state language (Article 24(5)).
  • Media buying. Search and video platforms with 21+ targeting, registered adult online media, and late-night TV and radio slots. Every creative goes through a checklist covering the warning, licence data, banned personas and banned themes.
  • Affiliate marketing. A narrower model than in most European markets (see the FAQ below). We help operators set up partner programmes where the operator commissions every placement and each one sits in a permitted channel.
  • Managed CRM. Lifecycle journeys built around mandatory spending and time limits and the ban on loss-triggered incentives. Communication goes only to registered players, never as mass unsolicited messages.

Channel mix that works in Ukraine

The legal channel map, not cost, sets the mix.

ChannelStatus for a licensed operatorSource
Own website, app and own pages on sharing platformsPermittedArt. 22-1(1)
Search engines, video and sharing platformsPermitted only with technical 21+ targetingArt. 22-1(1)
Registered online media for 21+PermittedArt. 22-1(1)
Linear TV and radio23:00-06:00 onlyArt. 22-1(1)
Influencers and media personalitiesProhibited (athletes excepted)Art. 22-1(2)
Sport sponsorshipPermitted, excluding children's and youth sport, with no outdoor or transport placementsArt. 22-1(4)
Product placement, branded merchandiseProhibitedArt. 22-1(1), (4)
Temporarily occupied territoriesAdvertising prohibitedArt. 22-1(1)

App store listings of the operator's betting or casino app are not treated as advertising (Article 22-1(1)). That makes app store optimisation a legitimate lever.

Regulatory + compliance considerations

PlayCity issues licences, keeps the public registers of licensed organisers and the register of people restricted from gambling, and uses the State Online Monitoring System as its main supervisory tool (Articles 5, 8 and 12). It also enforces advertising law in the gambling sector and decides on blocking access to unlicensed websites and apps (Article 8). It accepts public complaints about gambling ads on websites, social networks, TV and radio (PlayCity complaint form).

Wartime rules apply directly to marketing. Gambling ads cannot use themes related to resisting Russia's armed aggression, or patriotic calls and symbols (Article 22-1(2)). While martial law is in force, military personnel's participation in gambling is restricted under a procedure set by the Cabinet of Ministers (Law 768-IX, Section XI, item 9). CRM and KYC flows have to reflect that.

Responsible gambling is built into onboarding. Players must set spending and time limits before they play, and operators must enforce them (Article 15). Players can change spending limits no more than once a month (Order No. 207). Operators must not let a player use more than one personal account (Article 15).

Other regulated European markets

Basher has an office in Rotterdam (Netherlands) and runs the same licensed-only playbook in the markets next to Ukraine: Poland, Romania, the Baltics, Czech Republic, Germany. The cross-border view, with every regulator side by side, is on our regulated Europe page, and the full service line-up for operators is on the iGaming marketing agency services page.

FAQs

What does an iGaming agency in Ukraine do for a licensed operator?

It plans and runs acquisition and retention inside the legal channel map: Ukrainian-language SEO on the operator's .UA site, paid search and video with 21+ targeting, adult online media, late-night broadcast, compliant partner programmes and limit-aware CRM. It also reviews every creative for the required warning, licence details and banned personas before it goes live (Article 22-1).

Who regulates gambling in Ukraine in 2026?

The State Agency of Ukraine PlayCity, a central executive body that implements state policy on gambling and lotteries (Resolution No. 505). It took over from KRAIL after Law No. 4116-IX replaced the commission with a central executive body (Law 4116-IX).

How does casino affiliate marketing work in Ukraine?

It is more restricted than in most European markets. Only a licensed operator can commission gambling advertising (Article 22-1(6)), and one business cannot act as the advertiser of another business's gambling brand (Article 22-1(10)). Promotion by bloggers and media personalities is banned (Article 22-1(2)). Any partner placement therefore needs to be commissioned by the licensee, sit in a permitted channel such as a registered 21+ online medium, and carry the warning and licence details. Operators should get Ukrainian legal advice on contract structure. Basher's affiliate marketing work here starts with that review.

Can gambling brands advertise on social media or with influencers in Ukraine?

Platforms are allowed only where they can target users over 21. Influencers and other "popular persons" are banned, with athletes as the only exception (Article 22-1). PlayCity lists social network ads among the signs of illegal advertising (PlayCity), so treat this channel with caution.

Does Basher work with unlicensed or offshore operators targeting Ukraine?

No. Advertising gambling without a Ukrainian licence is prohibited (Article 22-1(7)), and PlayCity can block unlicensed sites and apps (Article 8). We only work with licensed operators.

How much does an iGaming marketing agency cost in Ukraine?

Agency fees follow three models: a monthly retainer (typical for SEO, content and CRM), performance pricing tied to results (CPA, revenue share or a percentage of ad spend) or a hybrid of both. Basher typically works with operators spending USD 25K a month or more in paid media, and supports smaller brands during a launch when there is a clear scaling plan. Directional 2026 ranges by service are in our iGaming marketing agency cost guide.

Get in touch

Basher is an iGaming marketing agency founded in 2020 in Lima, Peru, with offices in Lima, Rotterdam and the Gold Coast. AffPapa named it Agency of the Year in 2025. We work only with licensed operators and produce native content in English, Spanish, Portuguese, Russian and Ukrainian. Our services cover player acquisition, media buying, managed CRM, affiliate marketing, SEO, content, PR, sponsorships and analytics.

Sources

All sources checked 1 October 2026.

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