Responses to a Finnish government consultation on the country’s forthcoming gambling market have revealed a sharp divide between gaming operators and the country’s charitable sectors.
Stakeholders included the Blue Ribbon Association, a charity for homeless and vulnerable people in Finland; the Finnish Gambling Consultants Oy,, a consultancy and development firm; and iGaming firms SkillOnNet, Wildz Group and Vana Lauri OÜ.
The responses came to recommendations made by the Gambling Risk and Harm Assessment Group, part of the Ministry of Social Affairs and Health. The Ministry’s main recommendation is a structuring of player protection initiatives.
Recommended measures include annual loss limits of €1,800 for 18-19 year olds and €2,500 for 20–24 year olds, and requirements for operators to send a notification, whether via a pop up or email, when deposits exceed a certain amount.
Other measures include players being shown an unprompted logout option and information about self-exclusion options after gambling for over three hours, which is repeated after 10 hours with the addition of personal contact.
Around deposits, a variety of measures are proposed for when customers meet different deposit thresholds – starting at a link to test for gambling risks and a suggestion for a review of personal gambling history when €25 per month is deposited, all the way up to an annual deposit limit when €5,000 per year is deposited.
In its statement, the assessment group stated that the framework, which includes various other measures, is proposed to serve “as a tool for planning, implementing, developing and assessing measures and responsible gambling practices related to the statutory prevention of gambling-related harm”.
“The assessment group considers that rather than relying on statistical models that are still under development, the monitoring of gambling behaviour and measures targeted at players should be defined primarily through selected key harm indicators,” the group added.
The industry – or perhaps it would make more sense to use the term prospective industry as no operators will be legally live in Finland until July 2027 – does not quite see things the same way, however.
Banging the drum
Unsurprisingly, Finnish betting stakeholders have cited a familiar argument – the black market. In all fairness, confronting the black market is one of the main motivating factors behind the Finnish government’s desire to overhaul the gambling framework.
Finland has been struggling with channelisation for many years, with the Veikkaus Oy monopoly struggling to compete with unlicensed overseas firms. The government, with Veikaius Oy’s backing, decided that replacing the monopoly with a mulit-licence market is the best way of getting the black market under control.
Finnish market stakeholders are warning that the measures will do the opposite, and continue to drive players to the black market despite the best efforts of the government and the regulated industry.
“In our experience, the tighter the loss limits are set, the greater the proportion of players will switch to gaming companies outside the official system,” said Jari Vähänen. Founding Partner of Finnish Gambling Consultants.
“Based on Veikkaus customer data, a problem in 2018–2019 was a situation where a customer encountered a loss limit that they had set themselves or that was defined as a maximum. If the customer wanted to continue playing after this, they had to switch to playing outside Veikkaus.”
Antti Tiihonen, a Vana Lauri OÜ board member, also argued that the proposals will fail to achieve both goals of the de-monopolisation – prevent and reduce gambling harm and improve Finnish channelisation.
The Tahlin headquartered enterprise has backed its claims with a population survey conducted by the Finnish Institute for Health and Welfare. This study found that 4.2% of respondents gambled at a ‘moderate risk of problem gambling level’ in 2023.
“In practice, such gambling would no longer take place within the legal system, but that part of gambling would be practically completely removed from the system,” Tiihonen wrote. “Of course, it is possible that some customers would stop gambling altogether, but there is no evidence internationally that this part would be of any significant size.”
Similar arguments were echoed by SkillOnNet, a Malta-based casino software developer, and Wildz Group, also a Malta-based firm and operator of the Rootz casino platform. Rantala Lasse, a Wildz board member, argued that restrictions in Germany have led to only around 20%-30% of gambling taking place within the regulated market.
Pöntinen Matti, a Country Manager with SkillOnNet, wrote: “Gambling on a licensed gaming site should be more attractive, more sensible and smoother for Finnish consumers than gambling on an unlicensed site.
“The purpose of the assessment group is important and correct, but unfortunately we do not see the positive effects it aims to have with the proposed care model.”
Difference of opinion
The assembled Finnish iGaming stakeholders have a difference of opinion not just with the Ministry of Health but also with one other respondent – the abovementioned Blue Ribbon Foundation, the Sininauhaliitto.
In contrast to the iGaming stakeholders, the Sininauhaliitto praised the Ministry’s proposals as being backed by ‘extensive research data on the risks of gambling’ a,d for having a ‘strong preventive perspective’.
“Intervening in gambling only at a stage when problems have already arisen and gambling has become uncontrollable is too late,” the charity’s statement read. “At this point, the harm to the individual can already be quite significant and it is difficult to break away from gambling.”
The charity has backed low loss limits, citing the fact that bettors often gamble with multiple companies at once – this is hard to disagree with. It also argued that many high-risk games will become available to Finnish customers post-market launch, high-risk games which will be concentrated around problem gamblers.
For these reasons, special attention should be paid to the protection of players and the restrictions on gambling should be sufficiently strict,” the charity added – though it does not think that the Ministry’s proposals are actually strict enough.
“The Blue Ribbon Association expresses its concern that the recommendations are not sufficiently binding and that companies are not implementing them,” its statement continued.
“The Blue Ribbon Association believes that their binding nature should be strengthened. The Blue Ribbon Association believes that a mandatory and centralised system should be implemented in Finland for both consumption limits and the duty of care.”
The charity and gambling organisations have found themselves very much on opposing sides of the aisle. The Blue Ribbon Association argues that measures should be strict to ensure adequate customer protection, while the operators argue that such measures will push customers to unregulated operators – where there is no protection.
“When the goals of a gambling system are to prevent gambling problems and have high channeling capacity, it is important to understand that the latter is a prerequisite for the former to be achieved,” said Vana Lauri OÜ’s Tiihonen.
The issue the industry may have is its dependence on the black market argument. While the government clearly sees that unrealized activity is extensive in Finland, there are some doubts.
An academic review published last month identified data gaps in efforts to measure the size of black market activity. Industry reliance on H2 Gambling Capital data was also criticised by the academics, who came from universities in Finland, Denmark, Sweden and Norway.
Regardless, the Finnish market will launch in July 2027 – it has been approved by the President, after all. Operators will be able to apply for online betting, gaming and bingo licences from March next year.
The question mark hangs on how the market will develop beyond this, with doubts and uncertainties remaining around player protection measures, as outlined above, as well as marketing and advertising.