Most coverage of Finland's reform concerns operators. The provision that matters most to suppliers is the gambling software licence, and its timetable runs a year behind the market opening.
The dates
Applications for a gambling software licence open on 1 July 2027, the same day the market opens. From 1 July 2028, licensed operators may only run their Finnish offering on software supplied by a holder of a gambling software licence.
That creates a twelve-month window. A supplier without a licence by July 2028 cannot serve licensed Finnish operators, regardless of any commercial agreement already in place.
Who needs one
The licence covers the development, supply and customisation of gambling software used by licensed operators. Suppliers should not assume that a platform or aggregation relationship removes the obligation; the question is whether the company supplies gambling software into the Finnish licensed market. Where a supply chain runs through an aggregator, both parties should establish which of them the obligation attaches to rather than assuming it sits with the other.
Duration and fees
A gambling software licence is granted for up to five years at a time, as is a gambling licence; the exclusive licence runs for ten. Those durations come from published legal commentary rather than from the authority's own summary.
Software providers will pay supervision fees, reportedly at a significantly lower level than B2C operators. No figure for the software tier has been published that we can verify, and we do not have one. Treat any number you are given for it as unconfirmed until the regulation is checked.
The unresolved question
The authority has not published the application requirements for the software licence, because the process does not open until July 2027. That leaves a real gap for suppliers planning now: the obligation is dated and certain, and the requirements to satisfy it are not yet knowable.
What can reasonably be assumed is that the process will mirror the operator one: corporate structure, ownership, financial standing, personnel reliability and technical verification. That is an assumption, not guidance.
Why the timing is commercially awkward
Operators are choosing platforms, payment providers and content suppliers now, ahead of a July 2027 launch. Those decisions are being made before any supplier can hold a Finnish software licence, and roughly a year before the obligation bites.
Operator procurement in 2026 and early 2027 therefore involves a compliance assumption rather than a verified fact. Suppliers who can demonstrate readiness are in a stronger position than those who cannot, and operators are likely to seek contractual protection against a supplier failing to obtain a licence. A termination right tied to the July 2028 date is the obvious mechanism, and suppliers should expect to be asked for one.
What suppliers should be doing now
Establish whether the obligation applies to the specific service supplied, and document the reasoning. Build the Finnish reporting capability into the roadmap rather than treating it as a launch task, since operator clients will need it before their own licences take effect. Expect to support independent verification of gambling systems.
Status of this guide
The dates and the existence of the licence are established in the Act and confirmed by the National Police Board and the Ministry of the Interior. Licence duration and the relative level of supplier supervision fees come from secondary sources. Application requirements do not yet exist in published form, and this guide does not invent them.
