In an industry as vast as gaming, it is rare that you will find a common, unanimously agreed-upon theme across all verticals and sectors. Rare and unlikely, indeed, but not impossible. Player protection isn’t the hottest phrase in the industry right now. Compliance, AI, Brazil, microbetting, sweepstakes, personalisation all yield a weightier respective presence among the discourse. Yet something we can all agree on is that, without the players, there is no industry.
It is common to hear professionals in gambling eulogise about the many wonderful people that work within the industry. Indeed, this is certainly not untrue and, if any one of those individuals were posed a question on the importance of player protection, they would all but unanimously agree it is paramount. Despite this, it can be argued that many of the players that fund our industry, quite simply, aren’t protected.
But where does the responsibility for that protection lie? Well, at the root of things, gambling products filter through a lifecycle that contains three major groups of stakeholders; those who consume the products – the players – those who provide the products – which can be referred to as the operators – and those who regulate the products – governments, regulatory bodies and such.
All three of these parties are responsible for – and benefit from – ensuring safe gambling practices. In the same vein, all three parties bare their own unique conflict of responsibility.
SELF-CARE: MIND, BODY, SOUL
Taking responsibility for one’s own actions is a key life-lesson that transcends geographical boundaries – and one reinforced from an early age. Consumers that engage with gambling products will, by the time they’re in their mid-twenties, most likely be fully aware of the potential risks affiliated with the practice of gambling. Of course, this does not account for younger players that can in many countries engage with gambling from the age of 18.
There are enhanced protection measures – such as deposit and loss limits – which are particularly effective and highly enforced across the European market for this younger demographic, often ranging from 18-24 years of age. However, on the side of the players not included in this bracket, they remain responsible for exercising their own cautious gambling practices to protect themselves from any harmful outcomes.
Sustainable & Safer Gambling Lead at Casino Guru, Šimon Vincze, touches on the unique conflict of responsible gambling from the player’s side. He tells Gambling Insider: “Players cannot meaningfully manage their play without understanding fundamental gambling principles. This can be referred to as gambling literacy, and it is vital for having fun with gambling in the long run. For example, understanding that a big win is just chance that cannot be easily repeated can have a profound impact. That said,” he continues, “industry stakeholders must actively support players in embracing it as their responsibility rather than passively informing them about the addictive nature of gambling.”
This point is further backed up by Tracy Parker – Vice President, Policy, Standards and Accreditation, Responsible Gambling Council. She tells us: “Players have a responsibility to be aware of their own, personal limits regarding the frequency and amount of time and money spent gambling. It is also important for players to be mindful of their gambling and the impact it’s having on their lives. It is not always easy to do this, so being aware and using the available resources, such as self-assessments and play history, is important for players to gain valuable insights into gambling patterns. Educating themselves about gambling – such as understanding that winning is largely based on randomness, not luck or skill – can help players view gambling more as a form of entertainment and less as a way to earn.”
As evidenced here, players must therefore utilise their knowledge to exercise self-control via limiting spending to what they can afford, alongside setting time limits, not chasing losses, remaining aware of their feelings/reactions, taking regular breaks and – crucially – being honest about the nature of the habit with those closest to them. They are likely to see something as a problem long before an individual sees a problem themself.
Daniela Johansson, Paf Deputy CEO & Chief Regulatory Officer, clarifies the importance of recognising the signs and taking the first steps towards addressing compulsive behaviour to Gambling Insider: “We know from experience that it is difficult to encourage players to seek help for problem gambling. The first step is to help them recognise that they have a problem; for example, through interventions and easy-to-use reality checks. Once a player acknowledges their problem, there is often a critical window where they are more likely to follow advice and seek help, especially if the process is simple and not too complicated.”
Examining one’s own ethical position before stepping onto the casino floor is paramount for players looking to ensure their own safety. Even within a nation such as the US, which yields extremely relaxed gambling advertising restrictions – almost every single gambling product or advertisement will come complete with a warning message that seeks to encourage safer play. Therefore, a player that is fully cognizant of the risks cannot expect to be protected by any external source, as they have been alerted to the potential dangers of their engagement.
However, none of these aspects account for the vicious hereditary, psychological and physiological nature of addictive compulsion. Unfortunately, addiction –despite being accepted in all medical, psychological, physiological and public health fields, alongside having widespread cultural acceptance – cannot be used as a legal defence.
Herein lies the player’s key conflict of responsibility. Some players can be trusted to protect themselves and others, through no fault of their own, simply cannot. Vincze explains: “Problem gambling is a spectrum, and the worst-case scenario is a person who gets to the addiction end of that spectrum with zero understanding of how gambling works, the kind of reactions it causes in the brain, or how to manage gambling behaviour. Such players would subsequently be seeking help after there is considerable damage already having been done.”
Duncan Garvie, Founder & Trustee of self-exclusion RG service BetBlocker, explains to Gambling Insider why protection from the player’s side needs to be enforced as a ‘second nature’ response: “I would suggest that our biggest challenge is with language. When you climb into your car, do you consider buckling your seatbelt a ‘responsibility?’ Or is it just something you do without ever really thinking about it?
“The problem here is that the language we’re using is creating an undesirable response before we even start. ‘Responsibility’ implies a burden we take on. We don’t want players to see the tools and support that are available to them this way. There will always be players who are not capable of managing their own engagement. Operators need to step in to help these players. But for everyone else, we need to embed in the public consciousness a view that this is just something you do when gambling. Without thinking about it. Without it feeling like a responsibility.”
Evidently, the blurred lines between a healthy pastime, frequent habit and debilitating addiction can, at times, make for a difficult ethical conundrum around player responsibility.
If operators are going to personalise any approaches, they have a responsibility to ensure they are not targeting people who are vulnerable to experiencing gambling harms – Sally Gainsbury
THE LEGAL IMPERATIVE
Laws pertaining to responsible gambling and player protection vary across global jurisdictions. This makes it more difficult to determine what the law stipulates with regard to the responsibility of responsible play – and whose shoulders it rests on. A region that is recognised across the gambling industry for being at the front of the battle for responsible practices is the UK. Taking a look at the law here, then, provides a valuable insight into how the legal land may lie on a more global scale as responsible initiatives continue to progress in the future.
Of course, unpicking the full UK Gambling Act 2005 would be a little – shall we say, dry? Cherry picking a handful of key stipulations, though, presents an interesting picture of the framework that, bear in mind, is one of the strictest in the world when it comes to ensuring player protection.
Vulnerability: Caution when preparing campaigns must be exercised by operators. The protection of children, which are defined clearly into age groups, is specified alongside ‘vulnerable persons.’ However, the latter remains undefined, presenting a grey area for protection initiatives. The law also advises that men aged 18-34 are more likely to experience problems with compulsive gambling, but does not specify any requirements not to target this demographic.
Misrepresentations: Advertising must not glorify or misrepresent gambling as an activity without risk, as an activity based on skill, as a way to be part of a community, or any other means of creating an unrealistic perception as to the outcomes of the practice.
Encouragement via trivialisation: In the UK, advertising must not encourage repetitive or frequent participation, play down the potential risks through the use of humour, encourage people to spend more than they can afford, or present unrealistic portrayals of winning.
As previously mentioned, a deep dive into responsible gambling law is perhaps for another day. The legislation included above, though, acts as a demonstrative tool for where the bar has been raised to for player protection, particularly within the EU market – and particularly regarding advertising restrictions.
It is evident, then, that federal and local governments do yield a power in authorising responsible practices when it comes to gambling. Further, they also yield their own responsibility to motivate change via legislation. While it is true that many operators will pursue change without regulatory impetus, it is equally true that many simply will not. This, therefore, places both the successes and failures of governmental enforcement when it comes to player protection under the microscope.
TAX GENERATION VS HARM MINIMISATION
In an industry often dressed up in glitz and glamour, the player protection sector could almost be referred to as an area where the ‘dirty work’ gets done. Essential? Yes. Glamorous? Not so much.
This is where a government steps in to do the heavy lifting. However, its own conflict of responsibility is one that is akin to that of an operator, as gambling is an industry that generates billions for economies across the globe every year. This money then gets pumped back into economical and infrastructural development, education, welfare and industry. It could be going towards protecting the most vulnerable sectors of a given society.
On the other side of the coin, much of this tax revenue generated by the industry will, indisputably, be generated by compulsive problem gamblers. Some may shy away from this fact and, while it almost certainly doesn’t even come close to making up a majority of gambling profits, it is a reasonable assumption that it will account for financial figures in the tens of millions. This, by the standards of 99% of the population, is a lot of money.
Sally Gainsbury, Director at Gambling Treatment & Research Clinic & Professor of Psychology, University of Sydney, pulls back the veil on the prevalence of problem gambling – explaining to Gambling Insider where the regulatory responsibility lies: “A notable proportion of gambling customers experience negative consequences and harms from their gambling ranging from mild to severe. This is not 1%, which is a figure based on population prevalence and includes many who do not gamble at all. The actual proportion of regular gambling customers who experience moderate harms is closer to 6-16% depending on the product and around another 4-10% experience severe harms, which again varies between products.
“Regulators have a responsibility to ensure that the product and environment is not harmful, does not encourage gambling beyond what is affordable, and does not encourage irrational or erroneous beliefs about the likelihood of winning or other product characteristics. Unfortunately, there are many instances where the operators and regulators fail in their responsibilities, which makes it difficult for more vulnerable consumers to control their gambling and essentially resist the potentially manipulative strategies used against them.”
One solution to tackling the conflicting ideologies of tax generation and harm minimisation is through non-monetary restrictions, such as implementing time limits, self-assessment tests, self-exclusion & enforcing requirements that demand operators carry out enhanced data collection and player observation techniques. Further, ensuring that operators report their RG initiatives and player protection techniques, providing statistics that display continuous progression, remains potentially game changing.
Critics from the operator side will argue that these can be hard to measure – and even harder to then report back to the government. This, however, should be beginning to change with the ever-increasing sophistication of AI and player monitoring techniques. Technological advancements within gaming seem to be changing the way we approach almost everything year-upon-year. Now, with the rise of AI, new player acquisition and retention techniques have exploded. Concepts like personalisation or microbetting have such powerful applications for keeping players betting, so there must be a way to utilise this kind of technology for protection. The impetus, though, remains on global governments to introduce regulatory measures that can curb the potentially destructive powers of these techniques. The manner in which they introduce these regulatory measures still remains up for debate.
Johansson: “In general, I don’t believe every new gambling innovation should go through a rigid RG vetting process before being released. Overregulating through excessive administrative hurdles and added complexity could stifle innovation within the industry. A dynamic and competitive market requires room for technological advancements and product evolution.
“That being said, it is essential that regulators keep pace with emerging trends, and ensure that regulatory frameworks remain relevant and effective. Instead of a pre-approval process, a better approach could be continuous monitoring and adaptation – where both operators and regulators collaborate to assess potential risks and make data-driven adjustments when necessary. Ultimately, player protection should always be a priority, but it is crucial to strike a balance between responsible gambling measures and fostering innovation.”
Providing protection in a rapidly changing online landscape, where compulsive gambling is at times seemingly encouraged – one only has to look as far as microbetting for an example of this – is now a monumental challenge that lies before international lawmakers in the industry. This point is accentuated when one observes the sheer financial power of some of the largest conglomerates in the industry. Examining whether some organisations are too deeply entrenched in government interest is, though, another subject entirely.
Johansson continues: “For me, the most pressing concern is the rising prevalence of problem gambling among young players. It is well established that younger individuals are a high-risk group for gambling-related harm. Today, we see an entire generation growing up with gaming experiences that include gambling-like features, such as loot boxes and skin gambling. This trend is deeply concerning, as it blurs the lines between gaming and gambling from an early age. “As operators, we must take this issue seriously and implement safeguards to protect young players. However, regulators also have a significant responsibility – regulating the largely unregulated gaming industry to prevent harm before it occurs.”
Weighing up wellbeing and wealth-generated welfare is a tricky line to walk, yet it is the job of any good government to examine its own moral imperative before every single decision it makes.
Parker suggests that governmentally affiliated stakeholders, such as financial institutions, could have a role to play in improving RG approaches: “For me the most important, untapped point of leveraging RG opportunities is with financial institutions. There is mounting evidence that financial behaviours while gambling can be clear indicators of risk or harm. The way to tackle this issue is with stakeholders not traditionally associated with RG, including financial institutions who are potentially powerful new channels for player protection.”
A CHANGING LANDSCAPE
There is no doubt that the responsible gambling sector, like the wider industry itself, is changing. Those who have been in the field since it first began to be taken seriously around 20 years ago will tell you just how much attitudes have indeed changed in that time. This is clearly represented by the American Gaming Association’s recent report which recorded that $472m is now invested in RG annually, up 72% from figures reported in 2017.
Moreover, the swinging pendulum of shifting attitudes is well represented by two juxtaposing legal cases, one of which saw former patron Arelia Tavares unsuccessfully chase a $20m racketeering lawsuit in federal court against six Atlantic City casinos in the mid-2000s. Tavares claimed that the casinos neglected their duty of care, failing to notice her compulsive behaviour as she accumulated nearly $1m in total losses.
In comparison, a case from January 2025 saw almost the exact same occurrence from an unnamed patron wagering with Sky Betting & Gaming, mostly placing bets on football online. In this case, it was revealed that, despite numerous attempts from the player at self-exclusion, the operator still targeted them with advertisements and labelled them as a ‘high-value’ customer.
In this instance, though, Sky Betting and Gaming lost the case but is currently in the process of appealing the decision. Whether or not this antithesis in outcomes represent a shift in wider attitudes toward recognising player protection is subjective. However, the latter of the two underlines the growing power modern-day operators now yield via the vast amount of data they have on their players – a theme explored by Gainsbury: “Operators have a wealth of information about customers that is highly disproportionate. That is to say, they have information on a customer they do not share with the customer. This information is often used for marketing purposes, including to send personalised promotional offers. “If operators are going to use a customer’s personal information as a way to incentivise and encourage further gambling spend and activity, I believe they have a responsibility to ensure they are not creating any harm through encouraging excessive gambling. Individuals may be trying to control their gambling, take a break or reduce their spend and individuals experiencing problems, by definition, have reduced ability to control their gambling. These are the individuals who will find it difficult to control their responses to promotional offers.
“If operators are going to personalise any approaches, they have a responsibility to ensure they are not targeting people who are vulnerable to experiencing gambling harms.”
REVENUE GENERATION VS HARM MINIMISATION
The question, then, is do operators prioritise their bottom line over the safety of their players? Here, Garvie gives his two cents...
“Yes. And no. As a corporate body considered as a single entity, it’s reasonable to say that commercial concerns can and do trump safer gambling considerations at times. I know many of the people who occupy the Head of Safer Gambling-type roles across the sector and it’s fair to say the conflict between commercial considerations and player safety is a common friction point that reduces their job satisfaction.
“But these organisations in practice aren’t single entities, they’re an amalgamation of people. Therefore, if you have a strong or weak Head of Safer Gambling, that makes a difference. If you’ve got an entrenched, commercially exclusionary leadership team, or a team with more progressive attitudes, that alters the landscape. The approach an operator will take is a reflection of the personalities that make up their team.”
CONFLICT OF RESPONSIBILITY
Despite unanimously promoting safe practices through advertising and agreeing that players with addiction issues need to be protected, operators can and will utilise mass amounts of data to target their highest rollers who, in many cases, bet thousands a week with them – regardless of whether or not they are aware of these players’ backgrounds or financial situations.
Some of these players may be in a financial position strong enough to afford to lose significant amounts of money day-in day-out. However, many will not be in that position and encouraging those already sliding down the rabbit hole to take the first step towards additional ‘responsibility’ is something of a catch 22 at best.
The struggle and subsequent failure of admitting there is a problem is one that is frequently noted by recovering gambling addicts, exemplifying the crucial requirement for operators to always be willing to take the first step.
Parker underscores the importance of the operator’s first step: “It is fundamental, not only to take action when gambling harm is suspected, but also to actively monitor player behaviours for warning signs and markers of harm. With access to player data, operators can detect early signs of risky play patterns and intervene promptly to ideally prevent harm from occurring. Although players, regulators and operators all play a role in fostering a safe gambling environment, operators are in a unique position of having access to player information, and the ability to engage with players directly and in a timely manner. Operators first need to educate themselves and their staff on the variety of help and support available to players and their communities. Making this information highly visible and easily accessible, as well as removing barriers for those seeking help, is essential.”
In many countries, these kind of initial protection incentives are becoming more commonplace and even federally enforced. This, of course, depends on exactly how you define a ‘first step.’ As stipulated in UK law, and clarified by the Gambling Commission, managing customer relationships falls under the umbrella of an operator’s commitment to social responsibility. Therefore, by this definition, encouragement to interact with gambling tools via including responsible gambling products in gambling advertisements could be counted as a first-step initiative.
Garvie explains: “There are clear times and places where operators both can and should be intervening to protect a player that has become a risk to themselves. There’s no excuse for not doing so. At times, I see appalling practices in the unregulated and weakly regulated markets. Operators who aren’t simply failing to intervene at the appropriate times but are actively encouraging and exaggerating harm. We have to do more to combat this.”
Indeed, as the industry advances, operators must look further than simply ‘first steps,’ a point that is rigorously emphasised by Garvie: “We don’t need to encourage players to seek help. We’ve a decade of messaging about the risk of gambling and the support services that are available. Though, admittedly, the industry could improve their signposting. We need to do better to encourage players who do not identify as impacted by gambling harm to engage with tools and strategies to help them stay within their affordability bracket.
“I was speaking with Professor Sally Gainsbury at ICE Barcelona, and she blew my mind by suggesting that Deposit Limits should be in the banking section of a player’s account, not the responsible gambling section. We want players to view these limits as just a normal part of gambling, not as something for people who have a problem. Common-sense genius.
“Despite all this, the overriding truth is that if we also get better at empowering players to play safely, there will be less need for operators to intervene. This is a double-edged conversation, and all stakeholders are responsible for behaving reasonably to minimise the harms associated with gambling.”
Players, regulators and operators all play a role in fostering a safe gambling environment – Tracy Parker
A TECHNOLOGICAL APPROACH
While both enhanced monetary and nonmonetary protection measures – such as time limits, self-exclusion lists or enhanced deposit limits – are a step in the right direction, it would appear that major operators in the modern industry have access to world-class data analysis and AI implementation tools, which they utilise for player acquisition and retention 24 hours a day. How, then, can this kind of technology make a difference when it comes to player protection?
Vincze tells us: “AI has proven to be very helpful in analysing and evaluating player behaviour, as it can handle many data points at once. Furthermore, AI can learn from this data and apply it to future decision-making, which is very promising for reducing errors down the line. Nevertheless, we are entering an era of AI assistants where communication with robots will become standard. I see significant advantages in such communication with players, as it can be automated through behaviour triggers. Moreover, when it comes to problem gambling, people might be less reluctant to talk to robots than humans.”
This point is further emphasised by Parker, who continues: “The opportunities for highly targeted player interactions before harm occurs, or is exacerbated, are more accessible than ever before due to AI’s ability to collect, monitor and analyse data. One of the more exciting RG applications is real-time risk monitoring paired with personalised messaging based on patterns of play. In addition, AI has the potential to capture those players who might be there are almost unlimited operators, products and abilities to pay. It is up to operators and regulators to decide whether they want to adopt a ‘churn and burn’ approach and attempt to monetise all players, or whether they want to establish a sustainable, responsible industry that is trusted and valued by consumers. “I believe that respecting and valuing customers is an enormous opportunity showing early signs of gambling harm so that early interventions and nudges can be provided to prevent harm from actually occurring.”
Fear of driving players to the unregulated and potentially dangerous black market is one argument that is always on the table when it comes to discussions around more stringent player protection measures. Indeed, this fear has been voiced by many in response to affordability and credit checks for online players, which have been trialled in the UK and suggested to help curb the debilitating slot addiction crisis in Australia. Further, fears of an affected bottom line for industries such as horseracing that are still very much financially recovering from the Covid-19 pandemic have also been voiced.
While some of these initiatives do have the potential to affect profit growth, many will argue that a long-term view of a healthier industry, with happier and protected players, breeds a much more productive space within which operators can also thrive. Gainsbury adds: “Consumers have ultimate choice; there are almost unlimited operators, products and abilities to pay. It is up to operators and regulators to decide whether they want to adopt a ‘churn and burn’ approach and attempt to monetise all players, or whether they want to establish a sustainable, responsible industry that is trusted and valued by consumers.
“I believe that respecting and valuing customers is an enormous opportunity and point of differentiation for gambling operators. Research demonstrates that consumer protection measures enhance customer loyalty and lifetime retention and value of customers. By putting players first, encouraging them to spend only what is affordable to them, operators can develop a loyal customer base who they can retain over time.”
There are also examples of success stories where an increase in revenue has been evidenced following the introduction of more stringent player protection measures. An example of this includes Norsk Tipping’s mandatory pre-commitment loss limit introduced in 2014 – as part of a full suite of RG measures including time limits and self-exclusion options.
Evidently, if these kinds of initiatives are not implemented on a broad-scale trial basis, a definitive conclusion will never be reached. The impetus for achieving this, alongside consistently making the first steps towards protecting players and utilising AI for these purposes, falls indisputably under the operator’s umbrella of responsibility.
WHOSE RESPONSIBILITY IS IT, ANYWAY?
Conclusively, findings would suggest that all three parties are implicated. The players stand to benefit the most from responsible practices, as simple credit check regulation, enhanced monitoring techniques and financial restrictions could massively curb the issue of compulsive betting without inhibiting the experience of the recreational bettor. The operators, however, benefit the least; as many ‘high roller’ customers display habits of compulsion which any kind of stringent restrictions are likely to flag – and their bottom line will likely suffer. These factors make it that bit harder for either of these two groups to remain objective.
Yes, there is a duty of care on the operator’s side and, indeed, the player’s, too. However, as much as you cannot trust a compulsive gambler to walk away from a slot machine, you cannot trust major corporations to walk away from advancing their revenue streams. Enforcing regulation does come with the caveat of risking a rise in black-market activity, although, on balance, those in government bear the smallest conflict of responsibility of our three stakeholders. This could therefore suggest the impetus for player protection falls largely on governmental and regulators’ shoulders as, put simply, it’s their job.
However, Garvie’s parting thoughts present an opposing argument to this conclusion, as he states, “I don’t view any one party as more responsible for protecting vulnerable players. There have certainly been failings within the industry. Speak to anyone who’s held a decisionmaker level role around player protection in the industry and you’ll quickly become familiar with the dichotomy that exists within businesses between profitability and protection. But regulators have failed too, turning a blind eye to problems and deploying ineffective policy for political reasons. And the ‘third’ sector has not always engaged a supportive or collaborative approach.
“There’s more than enough blame to go around. We all need to do better.”
