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Ukraine tells the PlayCity Agency and the Ministry of Digital Transformation to build AI player risk-tiering by 2027, and PlayCity alone to build AI ad-detection by 2028
Two numbered tasks in the operational plan turn on artificial intelligence, and both are assignments to state bodies rather than duties on operators or platforms. The instrument shows you how to tell the difference: when you cannot work out who a foreign instrument binds, look for the clause where the drafter switched verbs.
Bottom line: The Cabinet of Ministers endorsed a gambling policy strategy to 2035 and approved an operational plan for 2027 to 2029. Task 40 gives the PlayCity Agency and the Ministry of Digital Transformation until 2027 to introduce AI-based automated analysis of player activity that sorts players into risk groups. Task 85 gives the PlayCity Agency until 2028 to introduce AI tools detecting hidden casino advertising in streaming and video-hosting content. Both are duties on state bodies.
Who this affects: Ukrainian gambling operators and the platforms carrying gaming content, as the environment the state will be analysing. Also compliance counsel tracking where AI monitoring obligations sit, because this instrument is a clear worked example of a duty that binds an agency and only recommends to firms.
Issue date: 26 August 2026.
What changed: Nothing binding on operators. What is new is a dated work programme for named agencies, with completion indicators, running 2027 to 2029 inside a strategy that runs to 2035.
Analysis: The useful part of this instrument is not the gambling policy. It is the drafting: the Cabinet bound its own agencies and, one clause later, switched to a recommending verb when it reached private firms. That is a test you can run on any foreign instrument whose addressee is unclear.
Primary sources: Cabinet of Ministers order No. 855-r, 26 August 2026 (landing page) · The strategy and operational plan, attached PDF
- Instrument
- Order of the Cabinet of Ministers of Ukraine No. 855-r, endorsing the gambling policy strategy and approving the 2027 to 2029 operational plan
- Citation
- Розпорядження Кабінету Міністрів України від 26 серпня 2026 р. № 855-р
- Authority
- Cabinet of Ministers of Ukraine. Implementation is assigned to the Ministry of Digital Transformation, with the PlayCity Agency named in both AI measures.
- Jurisdiction
- Ukraine
- Date
- 26 August 2026
- Status
- The strategy is endorsed and the operational plan is approved. The order is not yet in the Rada legal register, which returns a 404 for it; that is a serving gap, not evidence the order does not exist.
- Bindingness
- Clause 3 requires ministries, other central executive authorities and state institutions to carry out the plan within budgeted appropriations and to report annually by 1 March. Clause 4 recommends, and does not require, that public associations, enterprises, institutions and organisations implement the plan within their powers.
- Editorial Note
- Informational analysis for working professionals, not legal advice. Confirm how any rule applies to your situation with qualified counsel.
- Primary source
- https://www.kmu.gov.ua/storage/app/uploads/public/6a9/051/08b/6a905108bb60c565860675.pdf
The two AI tasks, and exactly what they require
The operational plan approved by the order contains two numbered tasks that turn on artificial intelligence. Both are in the plan's table, which sets out the task, the measure, the deadline, the bodies responsible and the completion indicator.
Task 40 assigns to the PlayCity Agency and the Ministry of Digital Transformation the introduction of algorithms for automated analysis of gaming activity on the basis of artificial intelligence, to identify risky and problematic gaming behaviour and to distribute players into risk groups, in particular using the State Online Monitoring System. The deadline is 2027. The bodies responsible are the PlayCity Agency and the Ministry of Digital Transformation. The completion indicator is that such a system has been introduced.
Task 85 assigns to the PlayCity Agency the introduction of monitoring of illegal casino advertising and the use of artificial-intelligence tools to detect hidden marketing in gaming content, naming streaming platforms and video-hosting services. The measure is AI algorithms analysing streams and video hosting for hidden advertising and QR codes of illegal casinos. The deadline is 2028. The body responsible is the PlayCity Agency alone.
Task 85 carries a numeric completion indicator: advertising integrations in video content detected and blocked, not less than 80 per cent. That figure needs care. It is an indicator for detecting and blocking advertising integrations, not an accuracy figure for a model, and the plan does not define the denominator, so what the 80 per cent is 80 per cent of is not stated.
Who is actually bound, and how the document says so
Clause 3 addresses ministries, other central executive authorities and state institutions responsible for carrying out the tasks in the operational plan, and requires them to ensure execution within the expenditure provided in the state budget for the relevant year, and to submit information annually by 1 March to the Ministry of Digital Transformation on the state of implementation.
Clause 4 turns to the private and civic sector, and changes verb. It recommends that public associations, enterprises, institutions and organisations implement the operational plan within their powers.
Two adjacent clauses in one instrument, one using the binding verb for state bodies and the other using the verb for recommending when it reaches enterprises.
So an operator does not acquire a duty to run AI analysis on its own players from this order, and a streaming platform does not acquire a duty to scan its own content. They are the environment the state has told its own agency to analyse. If an operator-side data duty exists it comes from the gambling legislation, not from here.
Why the instrument type matters
The document is a розпорядження, an order of the Cabinet, and not a постанова, a resolution. The distinction is visible on the face of the text three times: the heading, the number's -r suffix, and both attachment headers.
The difference is operative in Ukrainian practice. A resolution is the Cabinet's normative act, making generally binding rules for an indefinite class of persons. An order directs the executive apparatus.
The document then uses two different verbs for its own two parts. The strategy is endorsed. The operational plan is approved. The plan is the part with named executors, deadlines and indicators, and it is the part that assigns them. The binding is done by clause 3 of the order itself.
The shape of the programme
The strategy runs to 2035 in three stages, 2027 to 2029, 2030 to 2032, and 2033 to 2035. The plan approved by this order covers the first of those stages.
The Ministry of Digital Transformation is named as responsible for implementing the strategy and for monitoring and evaluating implementation. Both AI measures name the PlayCity Agency, one of them jointly with the Ministry of Digital Transformation.
The execution duty is expressly capped: clause 3 requires performance within the expenditure provided in the state budget for the relevant year. A task with a 2027 or 2028 deadline is therefore contingent on appropriation in a way that a statutory obligation would not be.
The neighbouring tasks help calibrate what this is. Around task 40 sit self-restriction through a player's personal cabinet and electronic registers of operators, neither AI-based. Around task 85 sit an automatic data-exchange protocol with electronic-communications providers and digital platforms for immediate blocking, and deanonymisation work on virtual assets. The AI measures are two components of a broader digital enforcement build-out.
What to do about it
If you operate in the Ukrainian market, read this as a statement of what the state intends to be able to see by 2027 and 2028, rather than as a compliance obligation landing on you now. The practical exposure is that risk-tiering of players via the State Online Monitoring System implies data flowing to that system, and the terms of that flow are set by the gambling legislation rather than by this order.
If you run a streaming or video-hosting service reaching Ukraine, task 85 describes your content being analysed for hidden casino advertising, with a detection and blocking indicator attached. Nothing in this order requires you to do the analysing.
For compliance teams elsewhere, this is a useful specimen. It shows a government writing an AI monitoring programme where the duty sits entirely on the agency, and marking that choice with a different verb one clause later. When you read a foreign instrument and cannot tell who is bound, look for whether the drafter switched verbs.
The dates to diary are 2027 for the player risk-tiering system and 2028 for the advertising detection, with annual reporting to the Ministry of Digital Transformation each 1 March. Diary them with the caveat clause 3 attaches: both are contingent on appropriation in a state budget under wartime pressure, and neither is a statutory deadline. Watch for the order appearing in the Rada register, which is where a consolidated text would eventually sit.
Ukraine's Cabinet of Ministers endorsed a gambling policy strategy to 2035 by order No. 855-r of 26 August 2026, and in the same instrument approved the operational plan for 2027 to 2029. Two numbered tasks in that plan turn on artificial intelligence. Task 40 assigns to the PlayCity Agency and the Ministry of Digital Transformation, by 2027, AI-based automated analysis of gaming activity to sort players into risk groups, in particular using the State Online Monitoring System. Task 85 assigns to the PlayCity Agency alone, by 2028, AI tools to detect hidden casino advertising in streaming and video-hosting content, with a completion indicator of not less than 80 per cent of advertising integrations detected and blocked, on a denominator the plan does not define. The duties fall on state bodies: clause 3 requires ministries and state institutions to execute the plan within budgeted appropriations and report by 1 March each year, while clause 4 only recommends that enterprises and organisations implement it within their powers. An operator does not acquire an AI monitoring duty from this order.
Source File
https://www.kmu.gov.ua/storage/app/uploads/public/6a9/051/08b/6a905108bb60c565860675.pdf
The order is served across two surfaces on the Cabinet of Ministers site and you need both. The landing page carries the order and its five clauses; the attached PDF carries the strategy and the operational plan. Note that the landing page is rendered in the browser, so a plain command-line fetch of it returns a short shell containing none of the clause text; open it in a browser. Confirm four things. The heading РОЗПОРЯДЖЕННЯ and the number від 26 серпня 2026 р. № 855-р. Clause 3, requiring ministries, other central executive authorities and state institutions to ensure execution в межах видатків, передбачених у державному бюджеті, and to report annually by 1 March. Clause 4, which begins Рекомендувати and reaches public associations, enterprises, institutions and organisations. Then in the ОПЕРАЦІЙНИЙ ПЛАН table find row 40, with responsible bodies Агентство ПлейСіті and Мінцифри and deadline 2027 рік, and row 85, with responsible body Агентство ПлейСіті and deadline 2028 рік and the indicator не менш як 80 відсотків. Note that the plan contains five separate headings reading Операційна ціль 3, so locate the tasks by their row numbers rather than by the heading.
впровадження систем моніторингу за рекламою незаконних казино та використання інструментів на основі штучного інтелекту для виявлення прихованого маркетингу в ігровому контенті (стримінгові платформи, відеохостинги). In English: introduction of systems for monitoring illegal casino advertising and the use of artificial-intelligence tools to detect hidden marketing in gaming content, on streaming platforms and video-hosting services. Операційний план, затверджений розпорядженням № 855-р від 26 серпня 2026 р., завдання 85
FAQ
Does this require Ukrainian casinos to run AI on their players?
No. Task 40 assigns the building of an AI risk-tiering system to the PlayCity Agency and the Ministry of Digital Transformation, and the order's clause 3 places execution duties on state bodies. Clause 4 only recommends that enterprises implement the plan within their powers.
Does it require streaming platforms to detect casino advertising?
No. Task 85 assigns AI detection of hidden casino marketing in streaming and video-hosting content to the PlayCity Agency alone. Platforms are the environment being analysed, not the body carrying the task.
What is the 80 per cent figure?
A completion indicator for task 85: advertising integrations in video content detected and blocked, not less than 80 per cent. It is not a model accuracy figure, and the plan does not define the denominator, so what the figure is measured against is not stated in the document.
Is this binding at all?
On state bodies, yes, and within a limit. Clause 3 requires execution within the expenditure provided in the state budget for the relevant year, and annual reporting by 1 March to the Ministry of Digital Transformation. On private parties it is a recommendation.
Why does it matter that this is an order and not a resolution?
In Ukrainian practice a resolution is the Cabinet's normative act making generally binding rules, while an order directs the executive apparatus. The document identifies itself as an order three times, including the -r suffix on its number. The strategy is endorsed and the operational plan is approved, and the plan is the part carrying named executors and deadlines.
Why is the order not in the Rada legal register?
The register returned a 404 for it as at 1 September 2026. On a document six days old that is a serving gap rather than evidence of non-existence, and the Cabinet's own site carries the full text as an attachment.
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