An operator that has been taking bets from Finnish players during the monopoly era, when targeting Finns was unlawful, will be able to carry those players into the licensed market. The transfer requires the player's consent, but the relationship survives.

Heikki Koivula of Nordic Law puts it plainly: this gives applicants who built a Finnish player base during the monopoly a meaningful advantage.

Veikkaus is in the same position, and he suggests that is probably why everyone else was allowed to keep theirs. The state operator enters the competitive market with around 2.7 million registered customers in a country of fewer than six million people.

What this does to the competitive map

It produces three tiers, and only one of them is starting from zero.

The incumbent. A registered customer base equivalent to roughly half the population, a brand everyone recognises, and long sponsorship agreements already in place.

The established offshore operators. Years of Finnish players, Finnish-language support, Finnish payment habits and, in many cases, a Finnish-speaking team. All of it built while the activity was not permitted.

Everyone else. A licence, a 29,000 euro application fee, an annual supervision fee of up to 434,000 euros, a 22 per cent gambling tax, and no players.

The third group is the one the reform ostensibly opens the market for.

Why this matters more here than elsewhere

In most market openings, a new entrant can buy its way to a player base. Finland has closed the channels that make that possible.

Affiliate marketing is prohibited. Influencer marketing is prohibited. What remains is television, radio, newspapers and an operator's own channels, which deliver reach rather than targeting, and are bought in advance at national-campaign prices.

So the rules that restrict acquisition compound the advantage held by whoever already has the players. An operator with a database can market to it on day one through its own channels, which is the cheapest permitted route. An operator without one has to buy a national audience to find the same people.

This is a competition effect of a player-protection rule. It was not the purpose, and it is not obviously a flaw, but it is a consequence.

The uncomfortable version

Stated at its sharpest: the reform allows operators that broke the monopoly to monetise the customer relationships they built while doing it.

There is a defensible answer. Transferring a player into a licensed, supervised environment where identification is mandatory, deposit limits are player-set and a national self-exclusion register applies is better for that player than leaving them offshore. Channelisation is a stated objective of the Act, and the quickest route to it is bringing existing players inside rather than acquiring new ones.

Koivula makes exactly this point about the channelisation arithmetic: many players currently counted outside the system are already on applicants' sites, and will move inside with minimal effort. The target is to raise channelisation from around 50 per cent to 80 or 90 per cent, and a large part of that movement is bookkeeping rather than behaviour change.

Both things are true at once. The mechanism that delivers the channelisation target is the same mechanism that rewards the companies that created the channelisation problem.

What an applicant should be doing about consent

The transfer depends on the player agreeing to it, which makes consent the single most valuable operational project between now and July 2027.

  • Consent is a conversion funnel. Not every player will say yes. The share who do is the difference between launching with a book of business and launching without one, and nobody has published a benchmark.
  • The ask cannot be marketing. Soliciting consent from Finnish players before a licence exists runs into the same rules that are currently producing conditional fines. The timing and framing of the request are legal questions, not CRM questions.
  • Enforcement during the transition counts against the application. Koivula is explicit that action taken against an operator during this period may be weighed when its suitability is assessed. An aggressive consent campaign is precisely the kind of activity that creates a record.
  • Data has to survive the move. A player transferred to a new licensed entity arrives with history that matters for anti-money laundering, responsible gambling and tax reporting. Which parts transfer, and under what legal basis, is a question for counsel rather than for the platform team.

What we do not know

  • The legal mechanics of the transfer: what consent must say, when it may be sought, and whether the regulator has published a position.
  • What proportion of players consent in practice. No comparable Finnish benchmark exists.
  • Whether any applicant has been assessed negatively for conduct during the transition period.
  • How many of the 75 applications come from operators with an existing Finnish base, as against genuine new entrants.

Our Licence Tracker records the applicants identified so far.