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A mountain worth climbing: Slotegrator’s guide to gambling markets in the Balkans

Ayvar Gabidullin
August 4, 2023
13 min
5607

A region in which land-based gambling hasn’t truly been challenged during the past decade, the Balkans are currently experiencing a boom in iGaming. Most countries in the region have adapted to this shift by creating or updating their regulatory frameworks, in some cases compounding the growth, in others stifling it. Keep reading to learn about the possibilities offered by this up-and-coming part of Europe.

The Balkan peninsula in Southeast Europe is full of growing economies and gambling markets in which the online sector is only now reaching a critical market share. While regulations aren’t always operator-friendly, the Balkans are the exciting new frontier of iGaming in Europe.

Greece, Serbia, and Romania are sizable markets that operators interested in expanding their business footprint should pay close attention to. In contrast, smaller but vibrant ones like Bulgaria or Bosnia and Herzegovina can be an excellent springboard for newer businesses.

In this primer, we’ll cover all the key regulations of the region’s jurisdictions and the costs associated with obtaining a license and running an online casino or sportsbook in each of them.

Slovenia

Gambling in Slovenia is regulated by the 1995 Gaming Act. Under this law, online products can only be offered by operators that already hold a license to offer brick-and-mortar casino, betting, or lottery gaming services.

Both lotteries and betting are subject to state monopolies: Loterija Slovenije runs the national lottery, while Športna Loterija has exclusive rights to racing and sports betting. In the territory of the Republic of Slovenia, a maximum of two organizers may permanently organize classic games of chance, and the government may grant a maximum of 15 concessions for the organization of special games of chance in casinos and 45 concessions for the organization of special games of chance in gambling halls. Out of the ten permits already awarded, seven are held by the HIT group, a majority of which is owned by public entities. To acquire one of these licenses, operators need a minimum capital of €416,000 and the bank guarantee is 50% of that amount.

The Slovenian government made two attempts to liberalise the industry, in 2013 and 2016. The 2013 Gaming Act revision failed to get approval in parliament, while the 2016 draft never progressed through the legislative process and has since lost traction. Aimed primarily at ensuring compliance with European Union law, the amendments proposed in the 2016 draft would have allowed operators to acquire an online casino license without the need for a land-based casino license and a registered office located in Slovenia, opening the door to foreign operators. The lottery and betting monopolies would have remained intact.

Gross gaming revenues in Slovenia nosedived in 2020 due to Covid-related casino closures; however, the number had been steadily growing in previous years. In 2019, the industry’s GGR peaked at €322.2 million; about half (€158.8 million) of this amount was raked in by casinos, the rest by gaming halls, betting operations, and the national lottery. Revenue in the Online Gambling market is projected to reach €168.50m in 2023. The Online Sports Betting market has a projected market volume of €62.42m this year. Revenue is expected to show an annual growth rate (CAGR 2023-2027) of 8.28%, resulting in a projected market volume of €231.60m by 2027.

Croatia

Croatia revised its gambling regulations shortly after joining the European Union in 2013. The Act on Games of Chance entered into force on 1 January 2015, placing strict limitations on the industry.

Lotteries, administered by Harvatska Lutrija, are under state monopoly. Licenses to provide other online gambling services are attached to traditional land-based permits. This is true for both casino and betting games, both of which are capped at 20 operators.

The cost of an online license is close to €400,000 per year, which is quite high considering the limited size of the local market (Croatia has a population of around 4 million). This levy has unsurprisingly attracted the criticism of local operators. Gaming licenses are valid for 15 years.

Gambling taxes are equal to 5% of the turnover for lottery and betting operations, rising to 15% for casino games and 25% for slots.

Bosnia and Herzegovina

Bosnia and Herzegovina is a very diverse country in terms of ethnic diversity: more than 3.8 million Bosnians, Serbians and Croatians live on its territory. The Covid pandemic has significantly affected the gambling industry in Bosnia and Herzegovina — the country has digitalized and the gambling sector has moved online.

As is the case for other federations, Bosnia and Herzegovina lacks gambling laws that apply throughout its territory. Only anti-money laundering and data protection laws are enforced at a federal level.

Each of the three entities that make up the country regulates gambling within its jurisdiction. In the Brčko District, online gambling is banned following the 2004 Law on Games of Chance and Entertainment Games. On the other hand, local licensing is available in both Republika Srpska and the Federation of Bosnia and Herzegovina, thanks to laws published respectively in 2019 and 2015.

In both entities, lotteries are subject to state monopoly. Republika Srpska allows both casino and online betting services to be offered by authorised online operators; the Federation of Bosnia and Herzegovina only allows online betting (excluding virtual sports, which are explicitly banned), and licenses must be tied to a land-based operation. The price of the online license is KM 100,000 ($55,709).

Serbia

Fuelled by a sizable population of nearly 7 million, the GGR of Serbian gambling operators amounted to €785 million in 2019 – an increase of 71% over the previous year.

The State Lottery of Serbia holds exclusive rights to “classic games of chance”. These include lottery-type games, like lotto, instant lotteries, bingo, and keno, as well as “sports forecasting”. This is a very specific type of sports betting game, codified in the days of the Socialist Federal Republic of Yugoslavia. It consists of guessing the results of a predetermined list of matches, in a way similar to Italian Totocalcio or Spanish La Quinela.

Per the 2020 Law on Games of Chance, aimed at harmonising the country’s regulations with EU legislation, it is possible to acquire local licensing to provide online casino and betting services (excluding the above-mentioned sports forecasting) within Serbia.Companies applying for a gambling license have minimum share capital of €250,000, a bank deposit or guarantee of €300,000, and a daily risk cash deposit of €10,000. The land-based casino license fee is €500,000 per year, while the online casino license costs €2,500 per month.The license is valid for 10 years, and the number of online casino licenses is not limited — unlike licenses for land-based casinos, which are capped at 10 and are only awarded after a public consultation.

Online sportsbooks’ GGR is taxed at 15%, while online casinos only have to part with 10%. In addition to this, all operators are subject to a minimum monthly fee of €10,000.One general rule applies to both online and offline projects: the company must be registered in Serbia or any country of the European Economic Area (EEA).

Kosovo

Kosovo didn't regulate its gaming industry until 2019, when, prompted by two murders within a week in gambling establishments, the government imposed a 10-year blanket ban.

The only exception is currently the state lottery, run by Lotaria e Kosoves.However, players are not prosecuted for playing online on offshore gambling platforms. And most of the online gambling sites, which accept players from Kosovo are not blocked.

Albania

All forms of gambling, both offline and online, were banned in Albania by unanimous vote at the end of 2018. The ban was introduced to tackle both problem gambling in the general population and match-fixing in professional sports.

An exception is made for casinos within 5-star hotels located in tourist areas or outside towns.

Playing in foreign online casinos is not prosecuted. Online gambling, despite the ban, is still popular in Albania, and because if the lack of local options everyone turned to these unlicensed foreign gambling platforms. Therefore, with the gambling ban the government started blocking foreign gambling websites as well. However, players are not still not prosecuted or fined, and the block can easily be circumvented by a VPN, IPmask or using the TOR browser.

North Macedonia

Online gambling is legal since 2014. However, only online lottery was legal, and online gambling was not fully legal until 2020.

The local government holds a majority share in National Videolottery of the Republic of Macedonia, which in 2014 received the first and only license issued in the country. Casinos Austria, which holds a minority share (49%) of the aforementioned company, invested €6 million and provided the technical know-how for the joint venture.Since 2020 online gambling is no longer a monopoly and private companies can engage in online gambling activities, except online lottery, which remains a monopoly. Online gambling has been fully legalized in Macedonia (with an amendment to the Law on Games of Chance and Entertainment Games) to mitigate the negative effects of the global pandemic on the gambling operators. All operators, which have a Macedonian gambling licence can now operate an online platform as well.

Greece

Greece, the second-most populous country in the region, sports one of the Balkans’ wealthiest markets thanks to a GGR in excess of €2 billion.

The Greek gambling industry isn’t regulated by a comprehensive law but rather by a collection of acts, each covering specific types of operation.

A 2011 law regulates online gambling; in 2019, an amendment to this introduced a formal licensing process for both casino and sportsbook operators.

Licenses issued by the Hellenic Gaming Commission are valid for seven years and not limited in number. Annual fees amount to €3 million for online betting operators and €2 million for online casinos; the application fee for a license itself sets operators back €10,000. The tax rate, set at 35% of operators’ GGR, is a downside of the market. Required bank guarantee: €100,000 and minimum capital: €200,000.

OPAP, the gambling market leader in Greece, was founded in 1958 as the country’s lottery operator and currently holds exclusive rights to various online and offline games. OPAP’s monopoly on lotteries will run until 2030, that on scratch cards until 2026, and the one on horse racing until 2036.

Cyprus

Gambling in the Island of Love is currently regulated by the 2019 Betting Law, an update to the country’s comprehensive legislative framework introduced in 2012. Under the 2019 Betting Law, land-based casinos (legalised in 2015) can continue to operate, while online operators can only offer betting services. Bets are permitted on sports, esports, and non-sports events; a notable exception is horse racing, for which the Nicosia Race Club holds a monopoly.

Licenses for online bookmakers are issued by the National Betting Authority and are valid for one or two years. The cost is €30,000 or €45,000, depending on the length of the permit. Operators also need to provide a bank guarantee of €550,000 and are subject to a total tax burden equal to 13% of their GGR (10% tax + 3% administrative fee).

The gambling industry in Cyprus shows a steady upward trajectory the 2022 gross gaming revenue (GGR), near €960 million, increased by 22 per cent year-on-year. The financial results showed the GGR reached €959,557,906 last year, compared to 2021, which stood at €783,494,421. Also for the year 2022 there was a 17 per cent increase in Class A and B betting earnings compared to the year 2021.

Bulgaria

Bulgaria's gambling market is estimated to surpass the €2 billion mark, with a slim but quickly growing share represented by online products. Licensed operators can provide all forms of online gaming except instant lotteries and raffles. Only classic lottery games (not including keno and bingo) are subject to state monopoly.

The industry is currently regulated by the 2012 Gambling Act and supervised by the National Revenue Agency. This body replaced the dissolved State Commission on Gambling in August 2020 and immediately started working on updated secondary regulations. These are currently being implemented and will impact both online and land-based gambling operators.

The number of licenses available is uncapped. The cost depends on the type of permit, ranging from a minimum of €55,000 to well over €70,000. Licenses are valid for five or ten years, depending on the operator's initial investment in the country. Online casinos are required to place an initial investment of around €300,000, while for sportsbooks it's €500,000. All operators should also make available €500,000 as security.

Operators are taxed at a standard rate of 15%. The license maintenance fee is 20% of the GGR.

Romania

By far the most populated country in the region, Romania is home to 19 million people. In 2019, the online gambling industry of Romania raked in €70.2 million. If this seems like a low amount, consider that it represents a 416% increase from 2015, in the face of a meagre 5.5% increase in iGaming’s overall market share during the same period (from 9.5% to 15%).

Gambling in Romania is regulated by the 2009 Gambling Act and the 2016 Gambling Regulation; secondary texts on anti-money laundering measures, technical requirements, advertising, and player protection are currently being discussed.

As far as online services go, the National Gambling Office offers operators separate licenses for casinos, sportsbooks, raffles, and bingo-type games. The lottery is a state monopoly operated by Loteria Romana.

The number of licenses available is uncapped; the cost to start the process is €2,500. Yearly, operators have to pay €13,500 in administrative fees and an amount ranging from €6,000 and €120,000, depending on their turnover. Operators are also required to present a €100,000 guarantee. Taxes amount to 16% of the GGR or €100,000 per year, whichever is higher, plus a monthly levy of 2% of the turnover.

Moldova

Online gambling is a state monopoly. Loteria Nationala a Moldovei JSC controls the operations of all online casinos in the country. Gambling operators are monitored by the Ministry of Finance and the Licensing Chamber. The regulatory body of the gambling business in Moldova is the joint-stock company Loteria Nationala a Moldovei. This statutory fund is subordinated to the Ministry of Finance. The legality of the activity of establishments offering gambling entertainment is monitored by the Tax Service and the Ministry of Internal Affairs.Any advertising of gambling establishments and services is prohibited in Moldova, and the total amount of income tax for legal entities registered in the Republic of Moldova is 12%.

How can Slotegrator help?

With complex and conflicting regulations to navigate, choosing the right market and obtaining the necessary licenses for your iGaming business is easier said than done. Make sure you’re off to a good start by relying on our jurisdictional advisory services: thanks to over nine years of experience in the industry, we can safely guide you through the early stages of your project and take care of the legal aspects of getting it going.

For more information, get in touch with our sales team.

Ayvar Gabidullin
Ayvar Gabidullin
Business Development Manager
Ayvar has over five years of experience managing B2B and B2C sales departments in the online gambling industry. He started his career working in customer support for online casinos and grew to become the head of a department offering tailored services to VIP players. He joined Slotegrator with a strong focus on our company’s products and deep knowledge of what players need. His passion for the industry leads him to keep expanding his knowledge every day.

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