Prospects for partial liberalization

The Polish gambling market traditionally relies on a state monopoly in online casinos and strict control over betting, lotteries and the offline segment. However, in the coming years, pressure is growing towards "smart" liberalization: the state seeks to increase sewerage (transfer of players from the gray sector to the legal one), stabilize budget revenues and at the same time maintain the bar for responsible play. Below are key drivers, scenarios and a possible roadmap.

1) Change drivers

Demand sewerage. Strict restrictions do not eliminate online demand, and part of the traffic goes to foreign platforms. Partial liberalization with strong compliance can return turnover to the tax base.

Fiscal goals. A transparent GGR tax with a predictable rate (vs negotiable taxes and scattered fees) creates a stable cash flow.

Technological factor. The widespread adoption of e-ID, behavioral analytics and AML tools allows you to safely expand admission without increasing social risks.

Regulatory convergence. Most mature EU markets go to the model of "limited competition under strict rules" - Poland can adapt best practices.

2) What "partial" liberalization means

• Admission of private operators in separate verticals (for example, online slots and live casinos under a local license) while saving the state platform as a benchmark.
• Quota of licenses (limit on the number and types of products, mandatory integration with state registers and RG tools).
• Pilot programs ("sandbox") for new products and responsible advertising with measurable sewer KPIs and RGs.

3) Possible scenarios

Scenario A - "License partnerships" with the state platform.

Private operators receive limited licenses, integrate with the state monopolist via the KYC/RG bus, part of the proceeds is distributed through royalties/fee.

Pros: quick launch, risk control. Cons: lower competition, limited product innovation.

Scenario B - Multi-license.

2-6 full-fledged local licenses for online casinos with strict compliance and advertising code, mandatory integration with central registries and anti-fraud hub.

Pros: sewer growth, innovation, greater budget contribution. Cons: supervision is more difficult, regulatory infrastructure needs to be strengthened.

Scenario C - "Step-by-Step Extension" along the verticals.

First - live casino and RNG slots for betting/time limits and hard RG, after 12-24 months - KPI revision.

Pros: manageability and the possibility of adjustments. Cons: Stretched budget and business benefits.

4) Tax configuration stimulating sewerage

The base is GGR (gross gambling income), not turnover: this reduces the incentive to circumvent the rules and makes the market predictable.

Bet in the "attractiveness corridor." Too high - feeds the gray sector; too low - reduces the fiscal effect. The balance is achieved by calibration 1-2 times a year according to the actual KPI.

Earmarked contributions to RG programs, addiction treatment and sports/culture - for the public legitimacy of reforms.

5) Player protection as a condition of liberalization

e-ID/BankID/mojeID default, verification before first deposit.

Mandatory personal limits (deposits/expenses/time) with "cooling" upon increase.

Central register of self-exclusion and "reality checks" on all licensed sites.

Unified anti-fraud/AML gateway, matching payments and accounts, blocking anonymous sources of funds.

Strict advertising code: ban on targeting vulnerable groups, limit bonuses, transparent T & C.

6) Economic impact and industry

Budget. Increased collection due to sewage and reduced leaks into the gray sector.

Investments and jobs. Growth of vacancies in marketing, data-science, compliance, responsible game design.

Local ecosystem. Development of payment providers (including Blik), iGaming studios, cybersecurity, RG startups.

Sports and media. More sponsorships under "clean" advertising rules.

7) Risks and barriers

Social concerns. Require data-driven communication: proportion of problem play, frequency of RG interventions, success of self-exclusion.

Political cycles. Liberalization should be "supra-political," based on KPIs and annual reports.

Enforcement. We need resources from the regulator, quick blocking procedures and cross-departmental interaction.

8) Roadmap (conditional) for 24-36 months

1-6 months: public "white paper," market consultations, design of advertising code and RG standards.

6-12 months: running sandbox with 1-2 verticals, centralized RG hub, sewer test metrics.

12-24 months: issuance of limited licenses/quotas, AML/KYC stress test, audit of marketing practices.

24-36 months: expansion of KPI licenses, adjustment of the tax rate and bonus rules, publication of annual reports.

9) Reform Success KPI

Sewerage (share of turnover in the licensed market).

RG metrics:% of players with active limits, number of "reality checks" triggered, self-exclusion coverage.

Fiscal indicators: GGR base, stability of fees, budget predictability.

Enforcement: blocking speed, reduction of advertising violations, share of repeated incidents.

Consumer quality: NPS/CSAT, verification time, payout speed.

10) Withdrawal

Partial liberalization in Poland is not a rejection of control, but a controlled expansion of access with strict KYC/AML standards and responsibility. The optimal model combines a limited number of licenses, central RG infrastructure, GGR taxation and a KPI-linked "pilot approach." This format helps to simultaneously increase budget revenues, return players from the gray segment and keep social risks within acceptable limits.