CIS and Baltic states market focus: Belarus

In the penultimate part of this five-part series, EGR Compliance examines emerging gambling markets for operators in the CIS region and Baltic states, in partnership with law firm Dentons

As many sports betting fans will tell you, Belarusian football has gone from something you’d never consider betting on to effectively the only game in town, thanks to the international shutdown of sport due to the coronavirus pandemic.

But as Europe and the rest of the world starts to awaken from its Covid-19 hibernation, should operators remain in the Belarusian market? And how will having the eyes of the world on its sports sector change the way this fledgling offshoot of Russia approaches its own regulatory journey?

In the penultimate of this five-part series, EGR Compliance, in association with international law firm Dentons solicitors, analyses Belarusian regulation and looks at how, with a few minor tweaks, this tiny country could become the CIS equivalent of Malta.

Belarus in numbers

Population: 9.4 million

GDP per capita: $6,289.94

Internet penetration: 79.3%

President: Alexander Lukashenko

Principal regulatory body: Ministry of Taxes and Duties of Belarus

What types of licences are available to operators?

There are five types of licence:

1) sports betting;

2) slot machine halls;

3) casino;

4) totalisator;

5) online gambling (operator is able to conduct online all land-based activities under this licence).

Lotteries are not considered as a type of gambling.

In order to obtain an online gambling licence, applicants should have a land-based licence (please note that this licence should be “active” i.e. relevant operator should conduct gambling business under such licence) for a minimum of two years.

Gambling tax

All types of gambling: 4% of gross gambling revenue (GGR) (payable each month)


Gambling tax is calculated on the basis of taxable items per month (payable per month):

each slot machine: €100

each sports betting shop: €700

each totalisator: €1,000

How long do licences run for? What are the costs of applying?


All types of licence do not have an expiry date.

License fee

Licence fee is the same for each licence type and equals to approximately €5,500 (payable once upon application for a respective licence).


For an online gambling licence, applicants should deposit within a “special account” in the amount of either (i) €220,000 (for sports betting and totalisator licensees) or (ii) €1m (for other types of online gambling activities).

What restrictions are placed on operator marketing to players?

Belarusian laws also establish certain requirements relating to gambling advertising, under which it is prohibited to, inter alia:

  • advertise gambling on TV and radio from 7 am to 10pm;
  • place advertising in mass media targeted at people under 18-years-old or focused on ecology, education, healthcare;

place advertising in buildings (premises, structures) of

  • educational institutions, healthcare organisations, culture, physical education, sports (with the exception of the premises of betting shops and totalisators located on their territory);
  • create the impression that winnings are guaranteed for each participant of these events;

involve minors (under 18) in the advertising materials.

Where are the big opportunities for operators looking to expand into the market?

As Belarus legislation is considered one of the most developed within the CIS, Belarus may be a good starting point for operators that are looking to enter the CIS.

What do operators need to be aware of if expanding into the market?

There are two main points that are important to know before entering the market:

  • there is a very specific payment model in Belarus called the automated information system of the unified settlement and information space for individuals and legal entities (“ERIP” settlement and information space) and system “Raschet” (calculation, payment or settlement), which is akin to Russian TSUPIS but covers the whole payment system of Belarus;
  • it is necessary to find a Belarusian partner in order to obtain a licence in Belarus as current gambling legislation provides for the two-years’ experience requirement.

Local expert view – What do you think of the market?

This market could be very successful and popular if it would be a bit less closed in terms of localisation requirements.

If the market would be more open, then Belarus could become somewhat like Malta but in the CIS in terms of the popularity of the market and influence in the region.


Ilya Machavariani, associate, Dentons

Ilya Machavariani is a gambling and gaming lawyer for Europe, Russia and the CIS heading the Russian and CIS gambling practice group at Dentons. He has extensive experience advising on gambling issues and advises clients on operating in the Russian Federation and the CIS, on the full range of regulations relating to the activities of gambling operators, as well as drafting the necessary contracts and internal documents. He also handles licensing processes for gambling operators that are entering new markets throughout the world.

Ivan Kurochkin, associate, Dentons

Ivan Kurochkin being an associate at CIS gambling practice group at Dentons has broad experience on gambling issues, especially in regulatory matters. His work involves advising clients doing business in the Russian Federation on various activities of gambling operators (including bookmakers), focusing on issues related to compliance with gaming licence requirements, applicable AML requirements, and issues relating to advertising of gambling operators.

Advertising | Belarus | Dentons Solicitors | Ilya Machavariani | Market Focus | Online gambling | Regulation | Sports betting