When the state determines which employees must remain at their posts during wartime, it is a matter of allocating limited human resources. Therefore, reserving staff from companies that develop software for the gambling industry requires a convincing public explanation. The story of Favbet, the group’s founder Andrei Matyukha and residency in ‘Dія.City’ illustrates just how different the legal definition of ‘criticality’ can be from the public perception of it.
In October 2025 Hromadske has published an investigation entitled ‘The Booking Game’. Across five companies linked to gaming software and social casinos, journalists identified a total of 58 employees with bookings for the periods under investigation, 2024–2025. The best-known name in this story is ‘Favbet Tech’, later renamed ‘Highload Solutions’. But the issue extends far beyond a single brand: on what grounds exactly does the state grant businesses the opportunity to retain staff, and how does it justify its decision? [2]
‘Critical infrastructure’ and a critically important enterprise: a distinction on which the meaning of the story hinges
The phrase ‘casinos have been recognised as critical infrastructure’ confuses the issues. The term ‘critical’ is used in the context of exemptions. Whether a facility is classified as critical infrastructure relates to its vital functions and the consequences of any disruption to its operations. These are different legal mechanisms. [4][6]
In the case of ‘Favbet Tech’, the first mechanism applies. The official explanation from the Ministry of Economy dated May 2024 concerns the recognition of companies as critical to the economy. It does not mention the inclusion of casinos in the register of critical infrastructure facilities. [4]
The strength of the criticism depends on this precision. The state must answer a specific question: why has a particular commercial activity been granted access to the booking system, and has its economic significance been explained clearly enough? Such a question does not require us to ascribe to the decisions a meaning that is not there.
Andrei Matyukha and Favbet: who’s behind the tech-sounding name?
Andrei Matyukha — founder of the Favbet group. His biography, corporate roles and the history of the companies are examined in A separate dossier on KARTEL KHIMPROM. In this article, Matyukha’s surname serves as a key reference point for understanding the business associated with this well-known brand. [9]
That said, the group’s founder, the owner of a separate company, the head of an IT firm and the employee who received the booking all hold different roles. An examination of the staff lists does not automatically allow one to attribute personal involvement to the founder in the approval of each deferral. To substantiate such a decision, documents from the relevant legal entity are required: an application, an order regarding criticality, the grounds for approval and the timeframes.
This is particularly important for groups in which technological services and the organisation of games may be divided between different companies. A journalist needs to trace the links between them: who commissions the development, who owns the product, and for which market it is intended. A shared brand helps to raise these questions, but it does not provide the answers.
According to hromadske, ‘Favbet Tech’ developed software for Favbet and, following the rebranding, remained within the group’s sphere of influence. The company was granted residency in ‘Diya.City’ in March 2022. The renaming itself does not explain either the economic function of the business or the grounds for its critical importance. It is necessary to scrutinise the activities of the legal entity and the decisions concerning it. [3]
Yulia Sviridenko: what was actually abolished in May 2024
The initial incident concerned 15 employees of ‘Favbet Tech’ who were placed on reserve duty in April 2024. The order was made public by a Member of Parliament Alexander Fedienko. Following the publicity, Favbet linked its operations to the Ukrainian cyber army, whilst the then Minister for Digital Transformation Mikhail Fedorov explained the need to retain high-calibre specialists. [1][3]
In Ministry of Economy announcement dated 16 May 2024 A specific document has been named — Order No. 8572 of 8 April. The then head of the department Yulia Sviridenko announced its cancellation in order to clarify the circumstances and analyse the decisions relating to each company. ‘Favbet Tech’ was on the list. [4]
The ministry also explained the procedure in force at the time: the Ministry of Digital Transformation determined the criticality, the General Staff approved the lists, and then the Ministry of Economy formalised the reservations. The specified grounds for criticality were: no arrears in social security contributions, salary levels, and residency in ‘Dія.City’. This is a description of the mechanism applied at the time, not a set of instructions for all subsequent years. [4]
The authorities have thus publicly responded to a specific order. However, the revocation of a single document does not amount to an indefinite legislative ban on the company submitting staff for booking again. This is precisely where the key point of scrutiny arises: what was the outcome of the promised analysis, and on what grounds were the subsequent decisions taken?
In the wake of the scandal: why the reinstatement of the booking system required an explanation
According to hromadske, between July 2024 and August 2025, 20 employees of ‘Favbet Tech’ were granted deferrals. Journalists reported that they had worked with a list of critically important resident companies and verified the information obtained from two independent sources. [3]
This sequence of events leaves the outcome of the May review open to question. There are various possible explanations: the company has once again confirmed its compliance with the criteria; the decision was made in accordance with updated rules; or the initial revocation was limited in scope. To distinguish between these explanations, the relevant orders and their grounds are required. The mere fact of a new booking is not sufficient.
A public conflict arises when a high-profile announcement of cancellation is easy to find, whilst the subsequent administrative history has to be pieced together through journalistic investigation. If, following an inspection, the business once again meets the requirements, the authority that made the decision can explain the substance of the matter: what was checked, over what period, and why the previous concerns no longer prevented the licence from being granted.
The revocation of the order is a visible political act. The rationale behind the subsequent decision is to ascertain whether this act was part of a consistent policy.
58 employees: which companies were included in the study
The figures below reflect data from hromadske for the periods specified by the publication. This is a historical sample, not the number of active bookings as at October 2026. [2]
| The company | Study period | Staff with bookings |
|---|---|---|
| ‘Favbet Tech’ / ‘Highload Solutions’ | July 2024 – August 2025 | 20 |
| ‘Billtech Games’ | July 2024 – August 2025 | 10 |
| ‘Computer Service’ | August 2024 – August 2025 | 7 |
| ‘Product Mednes Ukraine’ and ‘Playtika Ukraine’ | January 2024 – August 2025 | 21 together |
| Just five companies in total | 58 | |
It is not worth automatically adding the 15 employees from the Favbet incident in April to this figure. Without a comparison by name, it is unclear whether the groups overlapped. Furthermore, the figures for different time periods do not provide a clear answer as to how many deferrals were in effect at the same time.
The size of the sample is important, but its structure is no less so. A single table lists gambling technology providers and social casino developers. To assess government policy, it is essential to recognise these differences, rather than lumping all five enterprises together as a single hypothetical company.
Andrei Rutkovsky and ‘Billtech Games’: questions regarding a specific business
Hromadske has named the owner of ‘Billtech Games’ as Andrei Rutkovsky, a former patrol officer with the Vinnytsia Regional Police. The company became a resident of ‘Diya.City’ in October 2023. Rutkovsky did not respond to calls from journalists whilst this investigation was being prepared. [1]
His former profession is merely a biographical detail. It does not prove that he had privileged access to the booking. To verify such an assumption, specific documents or confirmed contacts that influenced the decision would be required.
Following the publication, ‘Billtech Games’ set out its position to hromadske. The company emphasised that its licence relates to the supply of software for the gambling sector, not to the organisation and operation of gambling activities. The publication added this comment on 19 October 2025. [2]
In the case of the company ‘Komp’yuterniy Servis’, journalists also described its operations in the gambling sector; company representatives confirmed that staff had been booked in at the time of the enquiry. This comment relates to the time of the investigation. [1]
A general question regarding such enterprises is: exactly what functions do the retained specialists perform, and how do these relate to the criteria for criticality? The answer should describe the nature of the activity, its continuity and its significance for the economy. The name of the sector alone is not sufficient to assess a specific decision.
Social casinos: why they need to be considered separately
In the study, ‘Product Mednes Ukraine’ and ‘Playtika Ukraine’ are classified as social casinos: users play with virtual resources that cannot be converted into real money, but can be used to purchase additional resources or features. This is a different model to games where players can win real money. [1]
This distinction affects the content of the article. Whether it makes sense for a company that creates such games to offer betting services is a matter of economic priorities. However, the nature of the game does not provide grounds for classifying its developer as a gambling operator in the legal sense.
The wider debate centres on how the state compares the economic contributions of different digital products. Are employment figures, salaries and payments sufficient indicators? How important is the end use of the development? Should such an assessment be the same across the entire IT sector? These are questions regarding the rules, which must be clear before an application is submitted.
How can a gambling IT company even be a resident of ‘Dія.City’?
Law No. 1667-IX on promoting the development of the digital economy distinguishes between the organisation or operation of gambling and the provision of services in this sector. In paragraph 12 of Part 2 of Article 5, the restriction on residency contains an exception for such services. Therefore, a connection to the gambling market does not automatically mean incompatibility with ‘Dія.City’. [5]
In a comment to hromadske, a spokesperson for the ‘Dія.City’ project office Alexei Dobronravov explained his position by drawing this distinction: companies develop software, rather than running the games themselves. [1]
This general explanation is sufficient for assessing a specific resident only at the initial stage. It is then necessary to ascertain whether the legal entity’s actual activities correspond to the stated model. A separate question is whether he had grounds for his criticism. The legitimacy of residency and the validity of the booking are interlinked, but require different decisions.
Recognising this distinction makes the discussion more focused. Rather than asserting that any developer of a gaming product cannot, a priori, be a resident, one can examine the application of specific regulations and demand clear reasoning specifically on the issue of reservations.
Mikhail Fedorov, taxes and retaining skilled workers: how convincing is the response?
There is an economic rationale for retaining skilled teams. The loss of key expertise could cost a company contracts, jobs and tax revenue. The balance between defence needs and the functioning of the economy was also reflected in the official explanation Yulia Sviridenko in May 2024. [4]
In its response following the investigation, Favbet Tech confirmed its status as a critical business and explained that the tax deferral was necessary to ensure uninterrupted operations. The company reported paying over 766 million UAH in taxes for 2024 and over 650 million UAH for the first nine months of 2025. These figures were provided by the company itself; no independent tax audit was carried out for the purposes of this article. [3]
This argument merits consideration. However, to justify a government decision, it is important to understand which legal entity the figures relate to, the period over which they are calculated, and the role they play in the relevant criteria. The brand’s total payments and the applicant’s figures may reflect different scales of business.
A similar clarification is needed with regard to high qualifications. These explain an employee’s value to the organisation. Public policy must further explain the principle by which this need is balanced against mobilisation requirements. Otherwise, any debate will boil down to a back-and-forth repetition of two obvious points: the army needs people, and the economy needs specialists.
A fast digital service is not responsible for setting priorities
In July 2024, an online booking system went live on the ‘Diya’ portal. The official announcement described an automatic check of employment and military registration details, the submission of lists by managers, and the receipt of results online. Access was intended for businesses and organisations with the appropriate status. [7]
This is an important division of responsibility. A digital tool is capable of quickly verifying information and carrying out the established procedure. The rationale for why a business has been classified as critical lies in the rules and decisions of the authorised body.
Therefore, the speed of the service does not answer the question of public expediency. Nor does the transparency of the interface for the applicant equate to the clarity of government policy for the public. A business may be able to clearly see the status of its application, whilst the public cannot see the grounds on which its activities have been given the relevant priority.
A useful point to examine is each of these stages individually: the rules for determining criticality, individual decision-making and the booking process. This makes it possible to identify exactly where further justification is needed, rather than attributing all inconsistencies to a single application.
Restrictions on casinos and supporting the economy: how to balance the two objectives
In April 2024, the government was simultaneously working on another aspect of its gambling policy. Decree No. 234/2024 has implemented the National Security and Defence Council’s decision on countering the negative consequences of online gambling. [8]
The very coexistence of these two objectives — minimising the negative consequences of gambling and supporting the economy — is not a contradiction. A legitimate business can contribute to tax revenue and employment even in a sector requiring stringent regulation. However, the state must explain how it reconciles these objectives and where it draws the line in terms of support.
This is particularly sensitive when it comes to bookings. Here, economic arguments clash with decisions that directly affect people’s lives. The public is entitled to expect greater certainty than the phrase ‘the company meets the criteria’, if the content of the criteria themselves and the procedure for applying them remain a matter of dispute.
A convincing response must demonstrate the link between the established requirements and the purpose of the booking. It must also allow for a comparison of the state’s treatment of businesses in similar circumstances. It is precisely the consistent application of the rules that provides grounds for speaking of a level playing field.
What answers are still missing following the Favbet saga?
The public scrutiny of this case should continue by posing verifiable questions about the decisions and documents involved. We are talking about information capable of explaining the policy without disclosing employees’ personal data or sensitive information about defence work.
- To the body responsible for determining the severity: By what decision and on what criteria did the company obtain or retain its status following the revocation of the April order? What has changed compared with the previous review?
- To the Ministry of Economy regarding the 2024 incident: What was the documented outcome of the promised analysis? Did you formulate a general approach to similar enterprises based on its findings?
- On to business: What roles did the staff members included on the lists fulfil, and what publicly available indicators explain the need for the continuity of these specific roles?
- To the authorities responsible for the rules: How are the actual operations of a gaming software provider and their compliance with the declared model verified? What are the grounds for, and how often is the criticality assessment reviewed?
- To all participants in the proceedings: Is it possible to publish anonymised statistics by sector and summarised grounds for decisions, in order to assess the consistency of policy?
These are questions for further investigation, not a report on enquiries already submitted by the editorial team. Their value lies in the fact that each one allows for a specific answer: a date, a document, a criterion, an indicator or an explanation of the restrictions on access to information.
Andrei Matyukha, Favbet and the cost of clear rules
The history of the gambling IT sector raises a broader question about the quality of decisions made during wartime. Businesses need predictability: what requirements must be met, and will the outcome remain unchanged following public outcry? Citizens need clear reasoning: why exactly do these requirements grant a company access to booking services? Defence needs require a policy that takes into account the limited availability of human resources.
In Favbet’s case, these expectations have converged around the well-known brand and the surname of its founder. However, it is necessary to assess specific legal entities and specific administrative decisions. The materials cited confirm the subject of public debate; they do not establish the illegality of every booking or instance of personal interference Andrei Matyukha into the proceedings.
The most convincing follow-up to the May announcements would be a clear explanation of the outcome of the review. If a business met the requirements, the government must explain the reasoning behind its decision. If the requirements proved to be insufficient, it must explain how they were amended and how these changes apply to everyone.
The status of a critically important enterprise requires a clear justification. The more sensitive the sector and the greater the cost to the country of a staffing decision, the more convincing the state’s argument must be.
This material is based on publicly available sources, verified on 20 October 2026. The figures relate to the period 2024–2025 as reported in the hromadske investigation. Further questions and assessments of government policy constitute editorial analysis.
Gambling market dossier: related articles
For a more in-depth look at the gambling market — the dossier Dmitry Punin and By Marina Ilina. These are separate articles about a different business; they are not included in the sample of bookings provided. [10]
