When Quiz Apps Become Gambling: Czech Licensing, Risks and Compliance

28.4.2026 | ARROWS law firm

Quiz and competition apps are evolving rapidly, but many publishers fail to recognize the moment when a game becomes regulated gambling requiring a licence from the Ministry of Finance of the Czech Republic. This article clarifies the legal boundaries, risks, and steps to understand the regulatory framework so you can avoid fines and legal disputes.

In the image, we see a lawyer consulting on gambling regulation.

How Czech legislation distinguishes between games and apps
When quiz apps become gambling
Licensing requirements and registration procedures
Risks and penalties for breaching the Gambling Act
Criminal liability
Table of rights and risks
Practical steps for publishers and entrepreneurs

Czech legislation distinguishes between purely knowledge-based and skill-based games (which are not gambling) and games where the outcome is influenced by an element of chance—these fall under the Gambling Act and require a licence.
The key test consists of three cumulative elements: placing a stake, non-guaranteed return of the stake, and a decision by chance or an unknown circumstance; if all three are present, it is gambling.
In practice, the app’s actual operation is decisive—authorities and courts assess whether the player can genuinely influence the outcome through their knowledge and skills, or whether chance is predominant or materially co-determinative.
A fine for operating unlicensed gambling can reach tens of millions of Czech crowns, the app will be blocked, and the operator also risks criminal liability.

How Czech legislation distinguishes between games and apps

The basic legal framework for all gambling in the Czech Republic is set out in the Gambling Act No. 186/2016 Coll., which replaced the previous legislation and entered into force in January 2017. This regulation is not an academic formality—breaching it has dramatic consequences for entrepreneurs and publishers. That is why understanding its scope is critical already at the initial stage of app development.

The Gambling Act primarily defines what constitutes a gambling game. Games that do not meet this definition generally fall outside its scope. In practical terms, we can speak of three categories of games from the perspective of the presence of an element of chance.

The first type consists of purely knowledge-based games, where the outcome is determined solely by the player’s objective knowledge of a particular topic. An example is a classic quiz in which players answer questions about history, geography, science, or other fields. In such a case, the outcome depends entirely on what knowledge the particular player has. If the player can look up the answers or return to the question text and verify the correct answer, there is no room for chance.

The second type consists of purely skill-based games, where the outcome depends exclusively on the player’s individual abilities—their reflexes, combinational abilities, strategic thinking, or motor skills. Such games include chess, go, tic-tac-toe, or modern strategy games where players can plan and execute their tactics entirely on their own. In these games, there is also no element of chance determining who wins.

The third—and decisive—type consists of mixed games that include an element of knowledge or skill, but also an element of chance. This is precisely where the boundary lies between regulated gambling and a freely available app.

Definition of a gambling game under Czech law

Act No. 186/2016 Coll., in Section 3(1), defines a gambling game very precisely. It is a game, bet, or lottery ticket into which the bettor places a stake, the return of which is not guaranteed, and in which winning or losing is determined wholly or partly by chance or an unknown circumstance. This definition contains three cumulative elements, all three of which must be present at the same time for it to constitute a gambling game.

The first element is placing a stake. A stake means money or other property value (e.g., virtual currency, gaming tokens, points) that the player puts into the game knowing that they may lose it or that it may be increased in value. The stake does not necessarily have to be money, but it must have economic value.

The second element is a non-guaranteed return of the stake. This means that when a player places a stake, they are not guaranteed to get it back. Either they place it and may lose it entirely, or they get it back in the form of a prize that is higher, or partially. The key point is that the return is not guaranteed—this distinguishes it from an ordinary commercial transaction, such as purchasing goods or services.

The third element is a decision by chance or an unknown circumstance. This is where the most common mistaken conclusions often arise. The law requires that winning or losing be determined wholly or partly by chance or a circumstance unknown in advance. Chance does not have to be predominant—it is sufficient that it carries some weight and that there is an element the player cannot fully influence.

When all three elements are met, the legal definition of a gambling game is satisfied and the app or game falls under regulation by the Gambling Act.

When quiz apps become gambling

Quiz apps are exceptionally popular in the Czech business environment. The simple rationale: a quiz is a business model with low acquisition costs, high monetisation potential, and millions of potential users. However, the moment you start thinking about how to monetise the app and how to add gamification elements and competitive mechanics, you enter legally risky territory.

Case 1: A quiz with no stake and no prizes—a safe model

The simplest and safest model is a classic quiz without any monetary elements. The user downloads the app, answers questions, sees their score, and shares results with friends. If there is no stake, no prizes, and no money going in or out, then this app is very likely not subject to the Gambling Act. In such a case, you are entirely outside the regulation of the Ministry of Finance, although you may still be subject to other laws—for example Regulation (EU) 2016/679 (GDPR) on personal data protection or Act No. 634/1992 Coll., on consumer protection.

Many publishers make a living from this through advertising, in-app purchases (for example unlocking advanced questions), or premium versions. Such a model is safe and common.

Case 2: A quiz with an entry fee and prize draws—a risky model

Here the situation changes radically. Let’s say your quiz has the following mechanics: “I pay CZK 50 to enter, answer 10 questions, and have a chance to win CZK 500.” In this case, all three elements of gambling are met.

The user pays CZK 50 as an entry fee (a stake). They do not automatically get the money back—they can lose it (non-guaranteed return). If prizes are awarded by a draw (i.e., random selection from those who answered all questions correctly, or even from those who achieved at least a minimum score), then there is an element of chance.

In such a case, the app is considered to involve operating a lottery (which is one type of gambling game under Section 3(2)(a) of the Gambling Act). Without a licence from the Ministry of Finance, this is prohibited and exposes you to an administrative fine as well as criminal liability.

Case 3: A quiz with an entry fee and a deterministic outcome – an unclear model

Now imagine a version where the user pays CZK 50, answers questions, and prizes are awarded exclusively based on the points achieved. So first place gets CZK 500, second place CZK 300, and everyone else gets nothing. In such a case, the outcome is entirely determined by the player’s knowledge and skills – there is no chance. In theory, this model should not fall under the Gambling Act.

The practical question is how to distinguish whether this is a quiz based on “pure knowledge” or a quiz with an “element of chance”. For example, if the quiz is difficult and only a few people achieve a perfect score, then multiple people may share first place with the same result. If you then allocate prizes by drawing lots among those with the same score, you are back in the realm of gambling.

Similarly, if the quiz includes questions that can only be guessed (because they are too difficult or involve speculative knowledge without a clear answer), the element of chance increases and the app moves closer to the definition of gambling.

Case 4: A consumer-type competition – specific rules

A separate category consists of so-called consumer competitions. These are governed by Act No. 634/1992 Coll., on Consumer Protection, rather than the Gambling Act, provided they meet the statutory exemptions.

Since January 2017, when the new Gambling Act took effect, there has been a significant change. The new regulation in Section 3(2)(g) of the Gambling Act explicitly excludes from the definition of a gambling game so-called prize competitions, other competitions, or events in which the participant receives a prize or other winnings wholly or partly based on chance, provided that:

participation is conditional on purchasing certain goods or services;
all participants who meet the competition conditions receive a prize or other winnings; or
the value of the prize does not exceed CZK 1,000 and the organiser does not undertake to pay the prize in money or other monetarily assessable performance.

This means that today you can run a competition that you sponsor and that forms part of an advertising campaign, even if prizes are awarded by a draw, provided it meets one of the above conditions and is not formally a gambling game. However, it is crucial that the competition is organised in compliance with the Consumer Protection Act, in particular that it must be transparent, truthful, and must not include misleading or aggressive practices.

Licensing requirements and registration procedures

If you have concluded that your app constitutes gambling, then the first and most important step is to obtain a licence from the Ministry of Finance. Without it, you are operating illegally and risk enormous penalties.

Basic authorisation

The Ministry of Finance issues a so-called basic authorisation to operate gambling games. This authorisation is the first level of regulation – it is a general approval that the entrepreneur or company is eligible to operate gambling games. The basic authorisation includes verification that the applicant:

is a legal entity with its registered office in the Czech Republic, another Member State of the European Union, or another state that is a contracting party to the Agreement on the European Economic Area, or in the Swiss Confederation.
meets all professional, technical, staffing, and security requirements set by law.
has sufficient financial security (e.g., for operating an online technical game, a security deposit of CZK 50,000,000 is required).
has no procedural defects – for example, is not insolvent, and its statutory bodies and persons with significant influence have not been finally convicted of selected criminal offences.

The basic authorisation is issued for a maximum period of 6 years (Section 18(1) of the Act). If your circumstances change during the validity of the authorisation – for example, the ownership structure changes, insolvency proceedings are initiated, or you no longer meet any of the conditions – you must inform the Ministry of Finance immediately.

Second level: Operating permit

After obtaining the basic authorisation, the operator must also obtain an operating permit for the specific type of gambling game (Section 72 of the Act). While the basic authorisation verifies the entity’s eligibility, the operating permit relates to the technical and software solution of the specific game and its compliance with the law.

In the case of physical gaming equipment (casinos, gaming halls), there is then an additional level – placing a specific game in a specific location, where municipalities issue permits for the placement of bingo, technical games, and live games. For online gambling, the situation is simplified – if you have a basic authorisation and an operating permit for an online game, you can make it available to everyone in the Czech Republic without additional permits from individual municipalities.

Special rules for online applications

Special rules apply to online applications, set out primarily in Section 7 of the Act. If you operate a gambling app online, the app and the operator must, among other things, comply with the following obligations:

include functions for reliable verification of players’ age and identity, preventing access by persons under 18 (KYC – Know Your Customer).
have responsible gaming features implemented, enabling the player to set limits for play (e.g., bet amounts, frequency of play, net loss) and to use self-limiting measures (so-called self-exclusion – temporary or permanent blocking of access to the game).
ensure technical protection against manipulation and the proper functioning of the gaming system.
ensure that all game documentation, player information, and the user interface are available in the Czech language.
use transparent and secure payment methods and ensure compliance with obligations arising from Act No. 253/2008 Coll., on certain measures against the legalisation of proceeds of crime and the financing of terrorism (AML – Anti-Money Laundering).
the operator is obliged to maintain a list of registered players and other data for the period prescribed by law.

The Ministry of Finance publishes on its website a list of authorised online gambling operators. This list is key – if you are on it, you can operate in compliance with the law. If you are not, you are operating illegally.

Risks and sanctions for breaching the Gambling Act

When a publisher or operator breaches the Gambling Act, the legal consequences are serious and specific. State supervision over gambling is carried out primarily by the Ministry of Finance and the Czech Customs Administration. Their inspectors actively search websites and mobile applications for illegal operators.

Administrative fines

The Ministry of Finance may impose a fine of up to CZK 50 million (§ 116(1)(a) of the Gambling Act) for operating a gambling game without a basic permit. In some cases, where the breach is particularly serious or long-term, fines reach tens of millions of Czech crowns. Lower fines (e.g., up to CZK 2 million) are set for breaches of other obligations, for example failure to comply with responsible gambling rules or insufficient system security.

For disseminating advertising for prohibited gambling games, a fine of up to CZK 2 million may be imposed (§ 116(1)(g) of the Gambling Act).

The operator also faces the risk of forfeiture of proceeds of crime or of an item used to commit an offence or a criminal act. This means that money obtained through illegal gambling operations may be seized by the state. At the same time, users are entitled to a refund if the app was operated without a licence – and on the state’s side there is the right to treat the matter as a potential criminal offence.

Blocking of the app and payments

The Ministry of Finance has the authority to maintain a list of unauthorised internet games (§ 84 of the Act). If your app is on this list, internet service providers (ISPs) are required to block access to the app’s domain name (web address), and banks and other payment service providers are required to block payment transactions to accounts associated with illegal gambling (§ 84a of the Act). This means that although the app formally exists, no one can actually use it from the Czech Republic or deposit money into it.

Criminal liability

In the most serious cases – especially where there is long-term operation without a licence, attempts to conceal the activity, or fraudulent conduct – criminal liability may also arise. The Criminal Code (Act No. 40/2009 Coll.) in Section 253a (Unauthorised operation of a gambling game) provides that anyone who unlawfully operates a gambling game will be punished by imprisonment for up to two years or a monetary penalty. In the event of more serious circumstances (e.g., large scale, committed by an organised group), the prison sentence may be significantly higher, up to ten years.

Practical consequences

In addition to official sanctions, you must also be aware of the practical consequences:

Your business partners (e.g., payment gateway providers or cloud service companies) may terminate you once they learn that you are operating illegal gambling.
Your investors or bank lenders may view you as high-risk and restrict your financing.
Users will be afraid of losing their money, and the app will lose credibility.
Reputational damage is significant and long-lasting.

Table of rights and risks

Potential issues	How ARROWS helps (office@arws.cz)
Uncertainty as to whether the app is gambling or not; risk of incorrect categorisation	ARROWS attorneys in Prague will carry out a detailed legal analysis of your app model and determine whether, and to what extent, it falls under the Gambling Act. We will prepare an expert legal opinion for you.
Missing licence and risk of fines of up to tens of millions of Czech crowns for operating without authorisation	ARROWS will help you prepare an application for a basic permit and a permit to operate a gambling game from the Ministry of Finance, secure the relevant documents, and represent you throughout the entire licensing procedure.
Removal of the app from app stores and its blocking	ARROWS will represent you in communications with the Ministry of Finance and connectivity providers to prevent inclusion on the list of unauthorised internet games, or help with removal from this list after remediation.
Users complain about transaction issues; concerns about a legal dispute	ARROWS will set up transparent terms of service and responsible gambling rules that protect you while also meeting statutory requirements.
Uncertainty regarding monitoring, compliance and reporting	ARROWS will provide ongoing consultations and ensure that your app complies with all obligations set out in the licence and the Gambling Act, as well as related regulations (e.g., AML).

Practical steps for publishers and entrepreneurs

If you are an app publisher and want your app to be legally compliant, follow the plan below.

Step 1: Clearly define your app model

First, you must clearly understand how your app actually works. Create a simple table:

What is required from the user? (Answers to questions? Payment? Nothing?)
What does the user deposit or pay for? (Money? Points? Nothing?)
How are results assigned? (By score? By drawing lots? Automatically?)
What are the potential winnings? (Money? Prizes? Nothing?)
How are winnings paid out? (To an account? In cash? They are not?)

Based on the answers to these questions, you can form an initial idea yourself as to whether it is gambling.

Step 2: Consult experts

Never underestimate legal assessment. Also, do not rely solely on generally available articles. Lawyers from ARROWS, a Prague-based law firm, have experience with dozens of such cases and know which details are decisive. A quality consultation costs you less than a single fine – office@arws.cz.

Step 3: After the assessment, decide on the next steps

You have three options:

Option A: Change the model. Remove the element of a stake, uncertain return, or chance. For now, it is the highest time to change the game and keep the app outside regulation. For example, cancel the entry fee or switch to a knowledge-based model without a draw.

Option B: Apply for a licence. If you like the model and want to keep it as it is, apply for the basic authorisation and the operating permit from the Ministry of Finance. Procedurally, it will take time and cost money, but you will be compliant and your business will be sustainable.

Option C: Do not operate. If you do not want to change anything or apply for a licence, then do not operate the app in the Czech Republic, or operate it only in jurisdictions where it complies with local legislation and is not considered gambling.

Step 4: Meeting obligations (for licensed operators)

If you are in Option B and have a licence, you must:

Implement responsible gambling features (limit settings, self-exclusion measures, mandatory breaks).
Carry out robust KYC (identity verification) and AML (anti-money laundering) checks.
Create a secure, encrypted system for transactions and data protection.
Keep detailed records of all games, results, and players for the statutory period.
Report data regularly and comply with all other administrative obligations.
Be careful with advertising (it must not be misleading or aggressive).
Ensure the app is in Czech and complies with all technical standards set out by .

This administration is demanding, and the attorneys at ARROWS, a Prague-based law firm, can assist you on an ongoing basis.

FAQ: Frequently asked questions

1. Do we need a licence even for a simple quiz app where users answer questions and share their result on social media?
No. If users do not pay a stake with asset value and there are no prizes, or there is no element of chance with an uncertain return of the stake, then it is not gambling. You only need a licence once the element of a stake (money or other asset value), prizes, and chance (with an uncertain return of the stake) enters the picture.

2. We have a mobile app with in-app purchases (the user buys special questions for CZK 50) and can then play an enhanced version of the quiz. Do we need a licence?
It depends on the mechanics. If the user is only buying content (new questions) which they can then access without any gambling element, no licence is required. But if they buy a “draw ticket” or another element that enters them into a prize draw with an element of chance, then it is gambling. The ARROWS team will guide you in the right direction.

3. What is the difference between an app I operate from the Czech Republic and an app I operate from abroad but which is accessible to Czech users?
Both cases are subject to Czech law if the app is in fact offered to Czech users or is clearly intended for the Czech market. Likewise, both cases should have a licence from the Czech Ministry of Finance. Being located abroad is not a safeguard—the Gambling Act applies to activities that take place in the Czech Republic or are targeted at Czech users.

4. We have a competition that people register for via the app, but we do not take any money; the competition is part of marketing. Do we need a special permit?
If it meets the conditions of the exemption from the definition of a gambling game (see Section 3(2)(g) of the Gambling Act), then you are outside the scope of the Gambling Act. But you still must comply with the Consumer Protection Act, which means the competition must be transparent, the rules clear, and never misleading. ARROWS will prepare proper competition terms and conditions for you.

5. What are the most common mistakes publishers make?
The most common is that publishers think that if “no one knows” it is gambling, then it is not. That is a tragically mistaken assumption. The second mistake: cutting corners on legal advice and hoping they can “do without it”. The third mistake: changing the app’s mechanics mid-operation without legal consultation. ARROWS attorneys protect you from all of these mistakes.

6. How much does it cost to obtain a licence from the Ministry of Finance?
The administrative fee for the licence proceedings itself is not high, but you must prepare extensive documentation, arrange a software audit, demonstrate sufficient financial security, and meet other technical and staffing requirements. Total costs are typically in the tens to hundreds of thousands of Czech crowns, depending on complexity. The process typically takes several months. ARROWS will prepare you so that the process is as smooth and fast as possible.

7. What should a publisher planning to launch a new quiz app know?
They should understand what “gambling” means under Czech law and clearly define their app model. If they are not 100% sure, they should consult an expert. ARROWS attorneys will guide you through all key issues and provide a clear legal assessment – office@arws.cz.

8. What are the most common reasons why apps become illegal gambling?
Publishers often start with an innocent app, but then want to monetise it, so they add an entry fee and a prize draw with an element of chance. At that moment, the app becomes gambling, but the publisher sometimes does not even realise it. ARROWS attorneys will help you find a safe path to monetisation without breaching the law.

9. How long does it take to obtain a licence from the Ministry of Finance?
The proceedings typically take 2–4 months, but it depends on how complex your model is and how quickly you submit all required documents. ARROWS has experience in preparing all documents correctly the first time, which significantly streamlines the process.

10. What if I am not sure whether my app is gambling?
Do not hesitate to contact ARROWS. The worst that can happen is that we have a consultation. The best that can happen is that we help you avoid a multi-million-crown fine and ensure lawful operation. Get in touch at office@arws.cz.

Notice: The information contained in this article is of a general informational nature only and is intended to provide basic guidance on the topic based on the legal status as of 2026. Although we take the utmost care to ensure accuracy, legal regulations and their interpretation evolve over time. We are ARROWS advokátní kancelář, an entity registered with the Czech Bar Association (our supervisory authority), and for maximum client protection we are insured for professional liability with a limit of CZK 400,000,000. To verify the current wording of regulations and their application to your specific situation, it is necessary to contact ARROWS advokátní kancelář directly (office@arws.cz). We accept no liability for any damage arising from the independent use of the information in this article without prior individual legal consultation.

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