Message 001
Communication from the Commission - TRIS/(2026) 1858
Directive (EU) 2015/1535
Notification: 2026/0357/FI
Notification of a draft text from a Member State
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MSG: 20261858.EN
1. MSG 001 IND 2026 0357 FI EN 10-07-2026 FI NOTIF
2. Finland
3A. Työ- ja elinkeinoministeriö
Työllisyys ja toimivat markkinat -osasto
PL 32
FI-00023 VALTIONEUVOSTO
maaraykset.tekniset.tem@gov.fi
puh. +358 29 504 7022
3B. Arpajaishallinto / Rahapelitoiminnan valvonnan ryhmä
Konepajankatu 2, 11710 Riihimäki
PL 50, 11101 Riihimäki
Sähköposti: arpajaishallinto@poliisi.fi
Puhelin: 0295 480 181 (Poliisihallituksen vaihde)
4. 2026/0357/FI - H10 - Games of chance
5. Technical Transmission of Game and Gaming Account Transaction Data under the Gambling Act
6. Gambling
7.
8. The proposal would lay down provisions, pursuant to the Gambling Act (10/2026), on the technical transmission of game and gaming account transaction data. Under the Gambling Act, a licence holder is required to submit to the supervisory authority the game transaction and gaming account transaction data relating to the gambling activities it conducts. The proposed regulation specifies the method for transmitting the information, namely a data vault through which licence holders make the information available to the supervisory authority.
The proposed regulation sets out the requirements for, and provides a description of, the required data transmission solution. The regulation describes the directory structure required for the service, the procedures for implementing the service, the information to be submitted through the service, and the general requirements relating to the implementation of the service. The objective of the regulation is to ensure that the information is submitted in a systematic and uniform manner.
The proposed Regulation would enter into force on 1 July 2027.
9. The purpose of the proposed regulation is to ensure the uniform and systematic transmission to the supervisory authority of the game and gaming account transaction data generated by gaming systems. The game and gaming account transaction data to be submitted play a significant role in the supervision of gambling activities. In order for the submitted information to be used efficiently and cost-effectively for supervisory purposes, a clearly defined method for transmitting the information is required. Without an unambiguously defined transmission method, the information would be submitted in different formats and by different data transmission methods, making its use and processing more difficult.
The proposed regulation would provide the supervisory authority with the means to monitor the functioning of gaming systems in a proactive and responsive manner. Regular supervision would prevent abuse and technical risks that could jeopardise the legality and reliability of gambling activities. The obligation to use the data transmission method required by the supervisory authority would promote uniform practices and ensure consistent requirements for licence holders.
9a. The technical regulation on the transmission of game and gaming account transaction data under the Gambling Act lays down the requirements for the technical transmission, by means of a so-called data vault, of information on game transactions and players' gaming account transactions required by the supervisory authority for the performance of its statutory duties. The regulation is related to the licence holder's obligation under section 45(2) of the Gambling Act to submit information in the format specified by the supervisory authority. The regulation further specifies the related technical requirements.
The objective of the regulation is to ensure that game transactions and gaming account transactions are made available to the supervisory authority by all licence holders in a uniform manner, irrespective of differences in licence holders' products, system configurations and operating models. The regulation also aims to ensure that the information is made available to the supervisory authority with a sufficient level of operational reliability and information security. Without the regulation, there would be a risk that the supervisory authority would be unable to carry out the technical supervision of gambling activities, including the monitoring of the integrity of transaction data. This could give rise to significant risks to the achievement of the objectives of the Gambling Act, for example with regard to safeguarding the legal protection of persons participating in gambling.
The technical regulation on the electronic certificate for game and gaming account transactions under the Gambling Act lays down the use of the electronic signature service maintained by the supervisory authority. The purpose of the electronic signature service is to ensure the integrity of gaming data.
Gambling activities require the reliable operation of games based on randomness, as well as the reliable processing of financial transactions, including the payment of winnings. If the data generated by gaming systems were not stored and electronically signed, the supervisory authority would, in practice, be unable to detect or verify possible abuses. Such a situation would again constitute a significant systemic risk, in relation to which the proposed regulations represent a proportionate measure.
In the expert opinions issued on the draft regulations, stakeholders have generally considered the objectives of the proposals to be clear and coherent from the perspective of the overall framework and to provide a comprehensive technical framework. The architecture and technical specifications have also been refined in several respects on the basis of the feedback received, in order to ensure that the regulations better achieve their objectives. In addition, similar technical solutions are already in use in other EU Member States.
9b. The measures laid down in the regulation harmonise the technical reporting solutions used by licence holders. The technical implementation, maintenance and related solutions for the data vault are the responsibility of the licence holder. The service may be implemented either as an in-house solution or by procuring it from an external service provider. There are several service providers on the market capable of implementing the technical solution required by the regulation, and the choice of data vault solution does not restrict competition or the functioning of the internal market beyond the restrictions already laid down in the Gambling Act (e.g. section 7 on a game software licence and section 46 on the location of gaming systems). One alternative would have been a service maintained by the supervisory authority, in which case all operators would have been required to use the same system for submitting information.
General legislation cannot be regarded as sufficient in this context, since the Gambling Act expressly requires that information be submitted in the format specified by the supervisory authority. Accordingly, the legislature has also considered that the conduct of gambling activities involves technical aspects that require more detailed provisions. If these matters were not specified in detail and in a harmonised manner by means of a technical regulation, the practical alternative would be to issue separate guidance to each licence holder. In that case, the technical solutions could become fragmented and the applicable requirements could vary to such an extent that they could ultimately distort competition.
By contrast, the electronic signature service provided for in the regulation on the electronic certificate is maintained and administered by the supervisory authority. The purpose of the service is to ensure the integrity of the information submitted in connection with the conduct of gambling activities, for which reason oversight by the supervisory authority is justified. The chosen solution is also influenced by the fact that the supervisory authority already uses a corresponding certificate in the current gambling system, the provider of which was selected through a public procurement procedure.
An alternative approach would have been for the supervisory authority to specify the technical requirements for the certificate to be used by gambling operators, while allowing licence holders to choose from several different certificates, provided that the certificate selected complied with the requirements laid down by the supervisory authority. However, for the reasons set out above, and in view of the implementation timetable, this alternative has not, at this stage, been considered appropriate. The matter will be reassessed at a later stage if necessary.
9c. The restrictions imposed by the measures are proportionate to the objective pursued in the public interest. In particular, the proposals seek to ensure the reliability of the conduct of gambling activities and the integrity of data, which may be regarded as essential for safeguarding the legal protection of players and for preventing abuse and criminal offences. In addition, the regulations would further specify the provisions of the Gambling Act with regard to technical details in order to ensure a uniform and, from the perspective of licence holders, clear practical implementation.
Compared with any potential disadvantages arising from the regulations, failure to achieve the public interest objectives would result in greater harm, both economically and socially. The reliable conduct of gambling activities and effective supervision are cornerstones of the new gambling system. At the same time, efforts have been made, where possible, to reduce the burden on gambling operators on the basis of the comments received from gambling companies and other stakeholders during the consultation process, and particular attention has been paid during the drafting of the regulations to ensuring their practical workability.
10. Basic text references: The basic texts have been provided in connection with an earlier notification:
2024/0601/FI
11. No
12.
13. No
14. No
15. Yes
16.
TBT aspects: No
SPS aspects: No
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European Commission
Contact point Directive (EU) 2015/1535
email: grow-dir2015-1535-central@ec.europa.eu
