Belarus has positioned itself as a legal gambling haven, bringing in Eastern European operators over the past decade and adding iGaming into the mix in 2019. However, persistent crises, a weak currency, and a strict regulatory regime make it a hard market to enter.
While Belarus is a small country, with a population of fewer than 10 million people, its gambling market has never been focused on the local players.
The initial regulation of land-based gambling in Belarus coincided with the ban on gambling in neighboring Russia. Just as casinos there were confined to remote, hard-to-reach gambling zones, Belarus offered millions of Russian gamblers an opportunity to enjoy games of chance with a shorter trip and a smaller budget. The legislation was finalized in 2008 — just as the law banning gambling halls and casinos was about to enter into force in Russia.
The idea took off and the industry experienced an initial boom, but the subsequent tax increases, troubled economy, and increasingly harsh regulations curbed the development of gambling in the country.
Let’s dive in and see if the gambling market of Belarus is worth a look as a potential investment destination in 2022.
While the industry was never explicitly banned, land-based casinos and betting shops have only been regulated in the country since 2008.
On April 1, 2019, Belarus regulated online gambling. However, iGaming is seen more as an extension of the land-based industry, rather than a business in its own right: applicants for online gambling licenses must already have a land-based license and two years of experience working in the country.
That means that for a potential online operator, the only option is a partnership with an existing enterprise — a more realistic prospect than opening a totally different business and running it for two years.
It goes without saying that the company seeking a license has to be incorporated locally and have its servers on Belarusian soil.
The good news is that nearly every form of gambling is permitted in the country: poker, slots, sports betting, and live versions of the traditional games broadcasted over the internet.
Both foreigners and Belarusian citizens can be the founders of the company seeking to obtain a license. The only limitation is that shareholders can’t have any previous convictions of financial crimes or a history of administrative offenses.
Prices for every formal process are set in “base amounts,” which is a notional amount that the country uses to calculate pensions, fines, duties, taxes, and other payments. In 2022, the base amount equals 32 Belarussian rubles, or €10,95.
To establish an open joint-stock company (the local equivalent of a corporation) requires a minimum capital of €4,380 (400 base amounts), while for a closed joint-stock company, the amount is €1,095 (100 base amounts). A limited liability company is the simplest and cheapest option; the minimum capital is not specified and can be as low as 1 Belarusian ruble.
Formally, the application process for an online gambling license consists of making changes to the existing license.Doing so requires the company to pay a special duty of 250 base amounts (€2,737.5 as of 2022).
According to regulations, the company has to have two accounts open in a Belarusian bank: a checking account, which must be used for all payments to the players, and a special bank accountwhich should contain a reserve amount to be used to pay out winnings in case the checking account is out of funds. For online casinos, the required reserve is 90,000 base amounts (€985,500), while for sportsbooks and parimutuel betting enterprises, the mandatory sum is lower — 20,000 base amounts, or €219,000.
The regulator will confirm that the amount is actually held on the bank account on the first day of every quarter.
To legally work in Belarus, an online gambling enterprise has to operate from a local domain, .by, or its Cyrillic alternative, .бел.
The longest and most problematic phase of the licensing process is the testing. Authorities will need confirmation that the platform and all its software work exactly as specified in the documentation and adheres to the licensing authority’s standards, both when the project is first launched and throughout its lifetime.
A key regulator in this process is The Gambling Business Monitoring Center.This government institution performs the testing (specific timeframe and scope of the testing is determined by the individual agreement) and also facilitates the operation of the “Special Computer Cash System.”
Operators are obligated to integrate the system and cooperate closely with The Gambling Business Monitoring Center. All financial transactions and player data must be registered with the system.
After the testing is finished and the document package is assembled, the review process will take approximately 45 workdays, with an additional 20 days if the regulator requires additional information on the implementation of the platform.
Taxes and Advertising Policy
Gambling businesses in Belarus are subject to a 4% gambling tax on net income (deposits minus the winnings), as well as income tax of 4% on winnings and returned deposits. There are other taxes that are not tied to iGaming specifically but are nonetheless an obligation for a Belarusian company. However, gambling enterprises are exempt from VAT.
Unlike many other gambling markets, Belarus permits gambling advertising, provided operators stay within limits and do not advertise their services to children (the law specifically mentions that it’s forbidden to advertise on toys) and not create a false sense that winnings are guaranteed to every participant.
The land-based market is subject to more taxes. The rates were revised on December 31, 2021, in Commentary to the Law of Belarus Republic № 141-З.
Companies pay 7,854 BYN (€2,687) per gaming table, 264 BYN (€90) for every slot machine, 2,475 BYN (€846) for every totalizer counter, and 1,650 BYN (€564) for every bookmaking shop counter. This marks a 12–15% increase compared to the previous year, which continues a trend of ever-increasing taxes.
The market in recent years
The coronavirus pandemic and the protests of 2020 were extremely detrimental to the industry. The land-based segment relies on tourism, and as the stream of people coming to the country dwindled, so did the income of the casinos and gambling halls.
Online casinos were mostly hurt by frequent internet cutoffs.
On the other side of the coin, 2020 saw Belarus reaffirm its positive stance on cryptocurrencies: the first legal crypto exchange opened its doors. Crypto operations were brought into the legal framework by Presidential Decree № 8 in 2017, but practical implementation took time.
Belarusian citizens can freely trade crypto assets and don’t have to declare them as income or pay taxes on them until 2023.
Unfortunately for casinos, gambling using cryptocurrency is still very much illegal. Digital currency’s anonymity and perceived lack of transparency make it incompatible with current gambling regulations. Of course, since the demand for crypto gambling certainly exists, it’s likely that regulators will find a way to include digital assets in the license without jeopardizing player safety.
Belarus remains one of the most active gambling jurisdictions in the region. In 2021, the number of land-based casinos in the country dropped to 20, but this number is still considerable; Belarus is still home to more casinos than most European countries with a similar population.
In a way, the multiple challenges that the land-based sector has faced accelerated the adoption of online alternatives. Initially, Belarusian players were reluctant to change and stuck to their old habits. However, slowly but surely, the online segment is gaining purchase as local players get more used to the idea of making deposits and wagering on the internet.
The government is clearly taking iGaming more seriously as a potential source of tax revenue.
With the new Decree “on Improvement of Legal Regulation of Gambling Business,” the government now has legal grounds for immediately blocking any gambling websites that operate in Belarus illegally or target its citizens without a license. Besides the obvious benefits as a tool of player protection, this will also help legal iGaming operators by dealing with the black market competition.
The latest legal development is the new Personal Data Protection Law, which came into force on November 15th, 2021. This legal measure aims to clarify the definition of personal data, create additional obligations for companies to handle the data securely and responsibly, and create a comprehensive policy of data protection.
Neglecting these new measures can result in a fine of between 50 and 100 basic values.
Belarus remains a puzzle for investors. On one hand, the country is one of the most open to the industry, unlike most other countries in Eastern Europe; on the other hand, there is a worrying trend of ever-increasing taxes, as well as strict regulations and unstable economic conditions.
And since Ukraine legalized gambling in 2020, and Estonia matured into a long-standing regulated market, Belarus is no longer the only available choice.
If you are considering an investment in the Belarusian gambling industry, it might be worth it to consult professionals who know the ins and outs of the market, understand the legislation, and know enough about the region to make an educated guess about what's going to happen in the next one to five years.
One such option: Slotegrator’s own legal experts that can help you evaluate all pros and cons during a free consultation, which you can book by clicking a button below.