The 4H View: Everything you need to know about Poland

EGR has partnered with 4H Agency to bring its readers a series of long-form articles on the requirements and key facts and figures for a host of emerging markets throughout the world.

Tapping into 4H’s talent pool of experts, the articles will outline the regulatory framework and entry requirements for interested parties, as well as an insider’s view on how the market could shape up in the coming years.

Here, the series continues with Poland, with commentary from 4H partner and head of consulting department, Ivan Kurochkin.

Market overview

Poland is located at a geographic crossroads that links the forested lands of northwestern Europe and the sea lanes of the Atlantic Ocean to the fertile plains of the Eurasian frontier. The country’s population amounted to 36,687,353 people in 2023, with GDP of $809.2bn.

The Polish gambling industry became regulated in the late 1990s, when the first rules for land-based casino activities were outlined. The current gambling regulation was adopted in 2009, further amended in 2017 and 2024. Now, the Polish market is considered as one of the most popular and profitable European markets of all. It is well regulated but limited in terms of online and land-based casinos.

According to the statistics of the regulator, the Ministry of Finance, the turnover from the gambling industry amounted to $19.2bn, consisting of $9.8bn for online casinos, $3.2bn for online sports betting, $2.1bn for land-based casinos, $1.9bn for slot machines, $360m for land-based sports betting and $2bn for all lotteries in 2023.

For comparison, in 2022 market turnover was $15.4bn, and in 2021 it stood at $10.8bn. That showed a growth of around 80% in gambling turnover. Overall GGR in 2023 amounted to approximately $2.4bn, representing a 50% increase compared to the $1.6bn recorded in 2021. These numbers prove the Polish gambling industry is reliable and growing.

Regulations

Poland regulates and licenses the following gambling verticals:

• Online sports betting;
• Online casinos (monopoly);
• Land-based casinos;
• Slot machine halls (monopoly);
• Land-based sports betting;
• Lottery (half-monopoly).

Several Polish gambling verticals are limited via either the state-owned Totalizator Sportowy’s monopoly (online casino, slot machines hall and traditional lotteries) or a tender-based licensing process (only land-based casinos). Online and land-based sports betting, as well as raffle and promotional lotteries are available for all interested operators.

It is also permissible to operate poker tournaments, whereas a land-based casino licence is required both for poker games inside the casino, and for poker tournaments outside the casino (with an additional notice to the regulator).

Polish gambling legislation does not provide for B2B licences but requires certain providers to report their activities to the regulator. Specifically, manufacturers and distributors of slot machines must be registered with the regulator and listed by the relevant operator using their services.

Licence requirements

Applicants and operators conducting gambling activities in Poland must comply with several regulatory obligations.

The key requirements applicable to all operators include:

• Only joint-stock companies or limited liability companies registered in the Republic of Poland are permitted to organise gambling activities. However, operators established in another EU state or a member state of the European Free Trade Association (EFTA) may apply for a Polish gambling licence, provided they establish a representative office or operate through a branch in Poland.
• The operator, its shareholders and management board must have an “impeccable reputation”. They must not have any prior criminal convictions, be involved in a business subject to criminal liability, or have had a gambling licence revoked within six years preceding the new licence application.
• Operators must maintain records of their activities and submit reports to the regulator. This includes tracking chip and cash transactions for land-based casinos, the operation of slot machines, tax base records, winnings of at least $600, registered tips and other relevant data.
• Land-based operators must install an audiovisual monitoring system in their establishments and equip their premises with independent backup power sources and anti-interference installations to ensure continuous and uninterrupted gambling operations.
• Operators must ensure that employees directly involved in gambling activities (such as dealers, supervisors and cashiers) receive training on gambling regulations before assuming their duties.
• Operators are required to establish and maintain internal gambling and/or betting regulations as part of their licensing obligations.
• Any changes in company shares, management bodies or key personnel must be reported to the regulator.
• Licence applicants must submit all required documents to the regulator, including company registration documents, financial and legal background information, personal data of management and shareholders, the expected date of operations commencement, a description of the games or bets offered, the address of the gambling location or website, responsible gambling and anti-money laundering (AML) policies, workforce details and other relevant information.

There are also specific regulations applicable to different types of gambling licences:

• For online gambling:
  • equipment used for processing and archiving online gambling data must be installed and stored within the territory of a member state of the EU or a member state of the EFTA that is a party to the agreement on the European Economic Area.
  • online gambling operators may only use websites with a Polish domain.
• For land-based casinos:
  • in towns with up to 250,000 inhabitants, only one casino is permitted.
  • for every additional 250,000 inhabitants, one additional casino may be authorised.
  • the total number of casinos in a town must not exceed one casino per 650,000 inhabitants.
  • casinos may also operate on seagoing passenger ships and passenger ferries under the Polish flag, provided that gambling activities take place during the voyage, starting no earlier than 30 minutes after departure from the port and ending no later than 30 minutes before arrival at the destination port.
• For slot machines:
  • a land-based casino must have between five and 70 slot machines.
  • slot machines must be equipped with a permanent recording and memory systems that track the tax base for gambling taxation without influencing the game’s outcome.
  • the combination of slot machines within a land-based casino must allow for monetary winnings to accumulate while ensuring the integrity of the games and compliance with state budget obligations.
  • operator of slot machines (whether a land-based casino operator or the state monopoly operator of slot machine halls) must notify the regulator of any intention to relocate a slot machine, suspend or withdraw a slot machine from operation, or report its destruction or theft.
• For lotteries:
  • raffle, bingo and promotional lotteries may be operated on a national scale or on one-off basis.

Licence costs and terms

All Polish gambling licences are granted for the term of six years, with a possibility of renewal for another six years.

Local legislation states that there is no annual licence fee, but a one-time fee for licence issuance and for its renewal where applicable. There are the following fees for receiving and maintaining a gambling licence:

• $24,280 for an online sports betting licence, and $60,700 for each website under the online sports betting licence.

There is a requirement to maintain a minimum share capital of a company applying for a licence and to guarantee a financial security for the winnings/prizes. For an online sports betting licence, the share capital shall not be less than $520,000 and financial security $125,000.

• $388,400 for a land-based casino licence, and an additional $600 for registration of a slot machine.

The minimum share capital of a company applying for a land-based casino license is $1m. Operators should also provide financial security in the amount of $312,000.

• $24,280 for a land-based sports betting licence, and $600 for each betting shop under a land-based sports betting licence.

The minimum share capital of a company applying for a land-based sports betting licence is $520,000. Operators should also provide financial security of $10,400.

Additional fees for changing the licence varies from $2,420 to $4,800, depending on the type of licence.

Taxation

Casino and slot games are exempt from tax on winnings.

Apart from gambling taxation, Polish legislation also mandates all companies registered on its territory to pay general corporate taxes. These are:

• VAT – 23%.
• Corporate tax – 19%.

Responsible gambling and AML regulations

Responsible gambling rules

Poland enforces strict regulations to ensure operators take responsibility for protecting players and minors from the risks associated with gambling. To mitigate the negative consequences of gambling, operators must implement the following measures:

• Provide players with information on gambling risks and details of organisations that offer support for problem gambling.
• Verify players’ ages using personal identification documents and maintain a registration system for all players.
• Clearly display notices stating that gambling is prohibited for individuals under 18 years of age.
• Implement tools that allow players to monitor and control their gambling activity, including setting financial limits.
• Online gambling operators must also safeguard gambling-related data from unauthorised interference and ensure its authenticity can be verified.

AML rules

Poland enforces anti-money laundering (AML) regulations through the Act on Countering Money Laundering and Financing of Terrorism (AML Law), enacted on 16 June 2023, No. 1124.

Under the AML Law, gambling operators are required to:

• Conduct customer due diligence (CDD) when establishing a business relationship, as well as when a player places a bet or receives winnings of €2,000 or more. CDD must also be performed if there is suspicion of money laundering, terrorist financing or doubts regarding the accuracy of previously conducted CDD.
• Report any suspected money laundering or terrorist financing activities to the General Inspector of Financial Information (the AML regulator).
• Develop and obtain approval from the gambling regulator for their AML policies and procedures, both during the licence application process and throughout the licence period.
• Appoint a managerial-level employee responsible for ensuring compliance with AML regulations.

Marketing

Advertising of gambling in Poland is generally prohibited with several exceptions. The main exception is that advertisement is allowed inside the licensed facility (land-based casino or a sports betting shop), or around the place where the facility is located, as well as advertisement or promotion of gambling on the licensed online gambling website.

Also, it is permissible to advertise licensed sports betting activity in the following cases:

• Advertisement on TV, radio and cinema can be conducted only between 10pm and 6am (except during the broadcast of sports events).
• Advertisement can be conducted on mass events and sporting events of which the sports betting operator is a sponsor or is a sponsor of a team or players actively participating in the sporting event, or is a sponsor of a sports association that has a connection with the organised event,
• Advertisement is conducted to inform about a sponsorship event.

General rules applicable for each type of permissible advertising are:

• Advertisement shall contain a message about the licence, consequences of participation in illegal gambling and gambling risks.
• Advertisement shall not be aimed at or include minors.
• Advertisement shall not include statements that participation in gambling has a relaxing, calming effect or is a way to resolve personal conflicts or financial problems. Ads must not also show that gambling is linked with physical fitness, intellectual prowess or the chance to win easily, that absence of gambling is a negative, or in any other way encourage higher stakes or evoke association with any success.

Market specifics for entry

Poland regulates its gambling market very strictly. Apart from operators, local legislation also concerns third parties, like payment service providers and affiliates.

For example, payment service providers are specifically prohibited from providing services to operators whose websites are entered into the blacklist of the regulator. Additionally, advertising banking services on gambling platforms is strictly prohibited.

Telecommunication providers are also required to prevent access to blacklisted websites and cooperate closely with the regulator to ensure compliance with these regulations.

Despite the tender process, which limits the availability of land-based casinos, this type of licence remains the most popular in the market. At the time of writing, these are the numbers of issued licences:

• Online sports betting – 18.
• Land-based casinos – 51.
• Land-based sports betting – seven.

The 4H view

Poland’s gambling market, while highly regulated, remains one of the most restricted in Europe. The country has strict entry requirements, and sustaining operations in this market is challenging due to the state monopoly on several gambling verticals. For instance, online casino games, a popular sector, is unavailable to white-label operators, creating a fertile environment for illegal activities and reducing state revenue. The tax rates on gambling in Poland are among the highest globally, with a casino GGR tax of 50%, alongside severe fines for illegal gambling, imposed on players, service providers and operators alike.

This combination of state control over various verticals, including online casinos, along with high taxes and restrictive regulations on sports betting, limits the benefits for legitimate market participants.

Ivan Kurochkin is one of the founders of 4H Agency as well as partner and head of the Eastern Europe desk at 4H. After 10+ years’ experience in consulting every type of client from testing laboratories to global operators and B2B providers on a variety of matters related to the gambling operations, he has proven himself to be a business-oriented multi-jurisdictional adviser for entering new markets across the globe. Kurochkin‘s background helps him to choose the best and most efficient scenarios for expansion into new markets or for bringing existing operations of 4H’s clients to a significantly new level. He is also an expert in the field of responsible gambling and frequent author for industry media.