Author: jarivhnen8322

Gambling professional and sport fan already more than 30 years.

FINALLY, IT IS READY

Unfortunately, the changes to the Finnish gambling system have kept me so busy this year that I haven’t had time to write blogs. However, here is a new text that I wrote on behalf of http://www.finnplay.com.

When the Finnish government submitted a proposal for new gambling legislation to Parliament in early April, it was hoped that Parliament would make the decision before the summer holidays. However, this did not happen, and the discussion of the matter was postponed to the autumn. At times, it appeared the Parliament’s decision would be made before the summer holidays, but in 2026 rather than 2025. However, the discussion is complete, and the law’s official approval is a formality. The President’s signature will be required to confirm the law later this year, but it is just a standard part of the process. Fortunately, the postponement of the decision-making did not directly affect the planned schedules.

The delay in the parliamentary process was primarily due to a few potential constitutional issues and disagreements over the timetable for the law’s implementation. There was no significant political debate over the need to change the gambling system, but the parties’ views on the emphasis on responsible gambling and on business opportunities differed as expected. The current right-wing government places a slightly higher emphasis on business than the left, which emphasises responsibility. This is also reflected in the two dissenting opinions: the Left Alliance proposed starting the legislative preparation from scratch, and the Greens proposed adding several elements of responsibility to the legal text. The Parliament voted by a clear margin (153-21) in favour of the Administrative Committee’s report, which clearly illustrates the parties’ unanimity on the matter.

The law will take effect on January 1, 2026, and the application process for gambling licenses will begin on March 1, 2026. The most significant change concerns the timing of the practical transition from the current gambling system to license-based operations. Initially, this was scheduled for the beginning of 2027, but the go-live date has now been moved to July 1, 2027. At the same time, it was decided to move the introduction of the gambling software license (B2B license) to July 1, 2028. The schedule change will also affect the start date of the new supervisory authority. The current supervisory authority, the National Police Board, will oversee the licensing process and serve as the regulator until the end of June 2027. After that, the new Licensing and Supervision Authority, which operates under the Ministry of Finance, will become the supervisory authority.

Finland is an interesting market for gambling operators

The legislation aims to establish a system in which the channelisation rate is maximised (approximately 90%). This should be done in a way that does not increase gambling problems and allows gambling companies to conduct reasonable business in Finland. In my opinion, the creation of this entity was at least sufficiently successful. At least the Finnish Gambling Industry Association, PAF, and the current monopoly company, Veikkaus, seem reasonably satisfied with the outcome. There has been more criticism from smaller operators, but at this stage, there is no compelling reason to critique the system.

I have already discussed the content of the upcoming law in my previous blogs, and there were no significant changes to matters that would affect business opportunities during the parliamentary debate. If you want to learn more about the content of the law, you can read the blog post I wrote at the beginning of April. At this stage, however, the most significant change to the bill concerns the authorisation for search engine marketing. Games and the gambling license holder that operates them may be marketed in online search engines when the search term is directly related to the license holder or the game it operates. In practice, this enables, for example, the use of Google Ads as a marketing tool.

Finns spend more money on gambling per capita than most countries. I don’t know Finland’s exact ranking on that statistic at the moment, but we have been among the top 3 countries and are likely still in the top 10. So, the market is attractive to gambling companies. The new legislation enables a wide range of products to be sold through digital channels, and betting products can also be sold in retail channels. In addition, marketing opportunities are strong, particularly in mass media, where brand-level advertising can be conducted relatively freely. The same applies to sponsorship. The volume of gambling is not restricted; customers are required to set deposit limits for each operator they use, but there is no upper limit on these limits. I believe that, given these opportunities, we will see a surge in gambling marketing, at least in the first year of the new system’s operation. However, based on experience in other countries, it can be assumed that advertising volume will plateau at a level significantly lower than during the initial boom.

Although the business opportunities appear favourable to gambling companies, there are also risks to their operations. There is a risk that marketing will become so extensive that public opinion will turn against gambling. At present, Finns have a reasonably favourable attitude towards gambling. It is crucial for the entire gambling industry that operations ensure Finns are satisfied and that the climate remains positive. One of the most significant threats is related to the supervision of gambling activities. To achieve the most critical goals of the reform, the supervisory authority must make every effort to prevent companies operating outside Finland’s license-based system from doing so. In Sweden, the regulator has, in practice, focused on supervising only the operations of licensed companies, which is why “black market” operators have captured an increasing share of the digital casino market. The same must not happen in Finland.

We are on the threshold of a significant change. Finland is an interesting gambling market, but one with its own special characteristics. Finnish customers are not the same as those in Sweden, for example. Therefore, gambling companies should not copy the operating model directly from Sweden. A better approach is to develop a Finland-specific model that accounts for customer behaviour, partner networks, and specific technical operating requirements.

The result of my prediction and other notes on the content of gambling legislation

I wrote this text at the beginning of April for the http://www.finnplay.com.

In my blog, published on February 27, 2024, I made predictions about the content of Finland’s future gambling legislation. At that time, I promised to assess the success of my predictions once the bill had been passed. Parliament began considering the legislative package on March 25, so now is the right time to return to the matter, although the content of the law may still change in Parliament, at least in some details.
Toward the end of this blog, I will discuss the planned schedule for our new gambling system and highlight a few content issues that I will not cover in my assessment of my prediction skills.
So here are my guesses about 1 year and 1 month ago and my assessment of their success.

  1. License-based system games: online casino, and sports and horse betting in both sales channels. The government program states that at least online casino games and digital channel betting will be transferred to the license-based system. However, I believe sports and horse betting will be transferred to the licensed side. It is crucial for the system to function correctly that the license entitles the operator to operate games in the retail and digital channels.
    My prediction was correct. The gambling license allows for providing fixed-odds and variable-odds sports and horse betting in digital and retail channels. Licensed companies can also offer digital bingo games, online casino games (e.g., roulette, card and dice games), and digital slot games. The exclusive licenses granted for ten years, which effectively constitute a monopoly, cover scratch cards and lottery games in both channels and slot machines and casino operations in a physical environment.
  2. License: Separate licenses for casino games and betting (including fixed-odds, pool-based sports and horse betting), with a license price of approximately 50000€. I support a system where one license would allow all games within the license-based system to be operated.
    The prediction was incorrect, but the solution is a model I announced that I support. A gambling license granted for five years at a time will enable the provision of all games that have moved to the multi-license system, meaning that there will be no separate licenses for betting and digital casino games. The license application fee has not yet been published but is presumably low. The license system will include an annual supervision fee, the price of which is tied to the gambling company’s annual GGR. The minimum price is 4000€ (GGR under 100k€) and the maximum is 434 000€ (GGR over 50M€).
  3. Tax rate: 20 – 25% of GGR. I would create a system where the tax rate varies depending on how dangerous the games are. With this logic, online casino games would have the highest tax rate, fixed-odds betting a slightly lower rate, and pool-based sports and horse betting the lowest.
    My prediction was correct, but the model I saw as the best solution did not come true. The proposed tax rate is 22 % of the GGR (i.e., the money lost by customers). In addition, gambling companies operating under a Finnish license will also have to pay income tax to Finland, like other companies.
  4. Marketing: Only brand advertising (company and product) is allowed. It is possible to advertise casino games on radio, TV, and other streaming channels for a limited time. Bonuses will be strictly restricted. Affiliate activities will be restricted. Sports sponsorship is allowed, but visibility for children and young people will be minimized.
    The prediction was reasonably, but not wholly, correct. Gambling companies can advertise in mass media (TV, radio, print newspapers) reasonably freely. Still, there will be a long list of restrictions on the marketing content. In addition, advertising must include certain specified elements, such as an age limit for gambling. Marketing is also allowed in outdoor advertising and sports sponsorship, where only the operator’s brand but not products may be visible. Affiliate marketing and the use of influencers are completely prohibited, according to the bill. License holders are allowed to advertise on social media. Still, the advertising may not be interactive, meaning customers may not have the opportunity to comment, and third parties are not allowed to share those texts. Bonuses may only be given to existing customers; even then, the bonuses may not be based on gambling activity or volume. Welcome bonuses may not be used at all.
  5. Gambling limits: Initially, a company-specific deposit limit applies to casino games if Finland ends up with separate casino and betting licenses. The deposit limit may also apply to betting games. If this happens, customers can apply for a higher deposit limit based on their income or other assets. In the coming years, the company-specific deposit limit may be replaced by a customer-specific limit when the monitoring system allows this. I think that a deposit limit is a better solution than a gambling or loss limit.
    The prediction was reasonably accurate. A gambling company-specific deposit limit is coming into effect, which customers must set themselves before they can start gambling. No upper limit has been set for the company-specific deposit limit, at least for now. The bill allows the Government to issue a decree later on, which can tighten the deposit limit policy. Initially, there will be no other limits on gambling. Still, the Ministry of the Interior will have the right to issue a decree, which will later allow it to impose maximum bets and other restrictions on high-risk gambling products.
  6. B2B license: The B2B license will not be implemented immediately, at least not when the system changes. Instead, technology and game suppliers will be set certification requirements that they must meet. The B2B license may be implemented at a later date if, for example, the experiences in Sweden show it to be a good solution.
    The prediction was almost entirely wrong. The new gambling system is expected to come into practice at the beginning of 2027 when companies that have received a gambling license can start operating and marketing gambling activities. Finland will also introduce a gambling software license, the same as the B2B license. This system will be introduced at the beginning of 2028, i.e., with a one-year delay compared to the B2C license. Since 2028, gambling companies with a gambling license may only use gambling technology and products offered by B2B license companies. B2B licensees may not provide their technology and games to operators that have Finnish customers but do not have a Finnish gambling license.
  7. Cooling-off: Finland will not introduce a cooling-off period. Since the gambling system’s practical entry into force seems to have been postponed to early 2027, the risk of using a cooling-off period has increased somewhat. I don’t think Finland will introduce new regulations just for one year, which I believe would be required if the cooling-off period were introduced.
    This prediction is a bit challenging to assess. Officially, there is no cooling-off period coming to Finland, so in that sense, my prediction is correct. On the other hand, the bill states that a gambling license will not be granted to an entity that has been issued a prohibition order or imposed a penalty payment for violating the current Lottery Act after September 1, 2024. The purpose of this procedure is very similar to the cooling-off period, so based on this, I judge my prediction to have been almost wrong.
  8. Supervision & Regulation: A new supervisory authority will be established in Finland. The new authority will probably no longer be under the Ministry of the Interior. It will be established under either the Ministry of Finance or the Ministry of Employment and the Economy. Supervision will require a new technological system and many new officials. The new regulator must be able to intervene more strictly than currently in gambling activities that are carried out without a Finnish license.
    The prediction was correct. The current regulator, the National Police Board, will continue in its role until the end of 2026 and will handle the transition to a license-based system. At the beginning of 2027, a new Licensing and Supervision Authority will start operating under the administration of the Ministry of Finance. The new authority will act as the supervisor of the new gambling system from the very beginning. The pre-bidding for the technical systems required for supervision work has been ongoing since the spring of 2025. I still agree with myself that it is crucial for the functioning of the gambling system that the regulator has the ability and desire to intervene in illegal activities significantly better than in Sweden, for example.
    Gambling products are not allowed to be purchased on credit, so using a credit card to pay for games is prohibited. Instead, payment applications may be used if they are based on debit payment. The use of cryptocurrencies in gambling activities is completely prohibited. Customers must be able to block themselves from all gambling with the click of a button. Blocking a specific gambling company or product group (e.g., digital casino games) must also be possible.
    Regarding the overall legislation, it is essential to note that the bill allows the Government and the Ministry of the Interior to issue decrees (regulations) that can influence practical gambling activities. The Government can, for example, set maximum loss limits for gambling companies. In turn, the Ministry of the Interior can specify maximum bets, maximum winnings, and the possibility of using the autoplay feature for the highest-risk games, for example, digital casino games. The bill does not include payment and IP blocking, but they can be returned if the channelization rate cannot be increased to the desired level.
    The bill is currently being considered by Parliament and is expected to be completed before Parliament goes on summer recess, i.e., by the end of June. The law will enter into force in early 2026 when the supervisory authority will start the gambling license process. The first phase of licenses is expected to be granted by autumn 2026. In practice, gambling operations based on the new legislation are planned to begin in Finland from the beginning of 2027.

Suomi julkaisi päivitetyn rahapelilainsäädäntöesityksen

Kuten varmasti muistatte, niin Suomi julkaisi heinäkuun alussa esityksen uudeksi rahapelilainsäädännöksi. Tuon jälkeen aloitettiin lausuntokierros, jonka aikana saatiin noin 130 lausuntoa. Lausuntojen ja poliittisen päätöksenteon vaikutus lakiesitykseen saatiin selville perjantaina, marraskuun 1.päivänä, jolloin Suomi lähetti uuden rahapelilainsäädännön EU notifikaatioprosessiin.


EU-prosessi kestää kolme kuukautta, mikäli mikään jäsenvaltio ei pyydä lisäaikaa. Jos lisäaikaa pyydetään, niin prosessin kesto on yhteensä neljä kuukautta. Tuon jälkeen laki palaa takaisin Suomeen, jossa tehdään mahdollisesti tarvittavat muutokset. Tarkoituksena on antaa lakiesitys Suomen eduskunnan käsiteltäväksi ja päätettäväksi kevään 2025 aikana. Tavoitteena on ollut, että eduskunta voisi hyväksyä lakiesityksen jo ennen kesälomaa 2025. Todennäköisempää kuitenkin on se, että laki hyväksytään syksyn 2025 aikana.


Uusi rahapelilainsäädäntö, jossa osa pelitoiminnasta säilyy monopolijärjestelmässä ja osa siirtyy monilupajärjestelmään, tulee voimaan 1.1.2026. Tuon jälkeen on tarkoitus aloittaa lisenssien myöntämisprosessi. Tarkennetussa lakiesityksessä todetaan, että laki voi tulla käytännössä voimaan aikaisintaan 1.7.2026 ja viimeistään 1.1.2027. Käytännön aikataulu riippuu ennen kaikkea valvovan viranomaisen resurssoinnista, jossa avainkysymyksiä ovat valvonnan tekninen valmius ja lisenssiprosessin aikataulu.


EU notifikaatioprosessiin lähetettyä lakikokonaisuutta voidaan pitää hyvin pitkälle lopullisena Suomeen tulevana rahapelilainsäädäntönä. Mikäli Suomen eduskunta tekisi notifikaation jälkeen merkittäviä muutoksia lakiin, niin notifikaatio ei olisi enää voimassa ja sitä pitäisi käsitykseni mukaan hakea uudelleen. Tämän vuoksi uskon, että nyt esitetty lakipaketti tulee olemaan 98 – 99 prosenttisesti lopullinen.

Monopolin ja lisenssialueen pelituotteet


Monopoli tulee jatkossa perustumaan yksinoikeuslisenssiin, joka voidaan myöntää vain Suomen valtion suorassa määräysvallassa olevalle yhtiölle. Yksinoikeuslisenssi on voimassa kymmenen vuotta, mutta rahapelilisenssin voimassaoloaika on vain viisi vuotta. Yksinoikeuslisenssiin on tehty kesän ehdotukseen verrattuna merkittävä muutos. Uuden esityksen mukaan yksinoikeuslisenssejä tulee olemaan kaksi kappaletta, joista toinen oikeuttaa lottery-pelien ja raaputusarpojen operointiin ja toinen fyysiseen kasinotoimintaan, joka sisältää myös ympäri Suomea sijaitsevat slot machines. Yksinoikeuslisenssit voidaan myöntää samalle yhtiölle, ja oletettavaa on, että ainakin aluksi ne annetaan valtion omistamalle, nykyiselle monopoliyhtiölle, Veikkaukselle.


Oman tulkintani mukaan kahden yksinoikeuslisenssin syynä on valtion suunnitelmat luopua ainakin osasta omistuksesta Veikkauksessa. Vaikuttaa siltä, että pitkätähtäimen suunnitelmissa on yhtiöittää eri rahapelituotteita operoivat yhtiöt erikseen. Tämän perusteella on mahdollista, että valtion suunnitelmissa on myydä esimerkiksi kasinotoimintaa pyörittävä yhtiö, tai osa siitä.


Rahapelilisenssi voidaan myöntää kiinteäkertoimisen ja muuttuvakertoimisen vedonlyönnin, virtuaalivedonlyönnin, sähköisten kasinopelien, sähköisen rahabingon sekä sähköisten raha-automaattipelien toimeenpanemiseen. Vedonlyönnin osalta toimilupa voidaan myöntää sekä verkon välityksellä että fyysisessä myyntikanavassa toimeenpantaviin vedonlyöntipeleihin. Kiinteäkertoimisen ja muuttuvakertoimisen vedonlyönnin kohteena voisi olla myös hevoskilpailu. Muutoksena kesän esitykseen on siis muuttuvakertoimisen hevosvedonlyönnin siirto monopolista lisenssijärjestelmään. Suomi on päätynyt ratkaisuun, jossa yhdellä rahapelilisenssillä voidaan operoida kaikki lisenssiin kuuluvat pelialueet eli tuotealueille ei tule erillisiä lisenssejä.

Jonkin verran muutoksia pelitoiminnan rajoituksiin ja vaatimuksiin


Lisenssiyhtiön tulee mahdollistaa pelaajalle näkymä pelaajan pelitilillä oleviin varoihin, varojen siirtoihin, pelitapahtumiin sekä pelaamista koskeviin rajoituksiin. Tiedot tulisi tarjota vähintään kuluneen vuoden ajalta. Uusi asia on lisenssiyhtiön velvoite tarjota pelaajalle työkalu, jonka avulla pelaaja voisi arvioida omaa pelikäyttäytymistään kuukausi- ja vuositasolla.


Heinäkuun lakiesityksessä oli kaksi kohtaa, jotka herättivät ainakin peliyhtiöiden keskuudessa paljon keskustelua ja arvostelua. Toinen näistä kohdista oli markkinointi ja siihen liittyvät bonuskäytänteet. Markkinoinnin tulee olla toimiluvanhaltijan itsensä toteuttamaa tai tuottamaa ja markkinoinnin levittämisen taustalla tulisi aina olla sopimussuhde toimiluvanhaltijaan. Lisäksi markkinoinnin tulee olla määrältään, laajuudeltaan, näkyvyydeltään ja toistuvuudeltaan maltillista.


Markkinointia on nyt tarkennettu niin, että markkinointi painetussa ja sähköisessä mediassa koskee myös painettua mediaa vastaavaa sähköistä julkaisua. Sponsorointia koskevaa säännöstä on muutettu lisäämällä siihen lisenssin haltijan velvollisuudesta varmistaa, että sponsoroinnissa ei tuoda esiin toimiluvanhaltijan rahapelejä. Käytännössä tämä tarkoittaa sitä, että sponsoroinnissa saa tuoda esille vain peliyhtiön brändiä.


Peliyhtiöt eivät saa tarjota pelaajalle pelirahaa tai tarjota rahapelejä ilmaiseksi tai alennetulla hinnalla tai yhdistetyillä tarjouksilla. Peliyhtiöille tulee kuitenkin mahdollisuus tarjota tietyin ehdoin olemassa oleville asiakkailleen bonusrahaa. Kiellettyjä olisivat siis esimerkiksi muille kuin toimiluvanhaltijan asiakkailleen tarjoamat bonukset, kanta-asiakkuusohjelmat ja muut vastaavat edut ja ominaisuudet, joilla kannustetaan asiakkaita pelaamaan enemmän tai joilla palkitaan pelaamisen määrästä taikka talletusten suuruudesta.


Määritelmän mukaan määrältään maltillisen bonuspelirahan antaminen vakiintuneen asiakassuhteen aikana yhdenvertaisin ehdoin yksinoikeus- ja rahapelitoimiluvan haltijanasiakkaiden kesken olisi sallittua. Bonuspelirahan saaminen ei saisi perustua pelaamiseen käytettyyn aikaan tai olla suhteessa rahapeleihin käytetyn rahan määrään. Myönnän, että osaa edellä mainitun kuvauksen perusteella ainakin heti kertoa, minkälaiset bonusjärjestelyt tulevat käytännössä olemaan mahdollisia. Sen sijaan bonuspelirahalle maksimi kierrätysvaatimus on todettu selvästi. Se voi olla enintään viisinkertainen.

Toinen markkinointiin liittyvä arvostelua herättänyt kohta on affiliate toimijoiden käyttäminen. Tämä on myös uuden esityksen perusteella kiellettyä. Lakiesityksessä todetaan, että sallittua on vain markkinointi lisenssiyhtiön omilla verkkosivuilla ja sosiaalisen median tileillä. Lisäksi lisenssiyhtiön on huolehdittava siitä, ettei kolmannella osapuolella olisi mahdollisuutta jakaa tai uudelleen lähettää julkaisuja. Lakitekstissä todetaan myös selvästi, että kiellettyä on hyödyntää rahapelien markkinoinnissa niin sanottua kumppanuusmarkkinointia (englanniksi affiliate marketing), joka perustuu verkkoliikenteen ohjaamiseen rahapelisivustolle.


Lausuntokierroksen kommenttien perusteella lakiesityksestä on poistettu ehdotukset maksuliikenne-estoista ja verkkoliikenne-estoista. Lakiesityksessä kuitenkin todetaan, että lain voimaantulon jälkeen seurataan rahapelimarkkinan toimintaa ja arvioidaan tarvetta maksuliikenne- ja verkkoliikenne-estoille.


Vedonlyöntitoimintaa rajoitetaan jonkin verran. Vedonlyöntiä ei saa järjestää valtiollisista vaaleista (esim. eduskuntavaalit) eikä taloudellisista muuttujista (esim. pörssikurssien kehitys). Oman tulkintani mukaan myöskään lottery betting ei tule olemaan mahdollista. Lisäksi lakiesityksessä kielletään vedonlyönti, jonka kohteena olisi kilpailun, turnauksen tai urheilulajin sääntöjen rikkomisesta seuraava seuraamus tai rangaistus. Käytännössä tämä tarkoittaa sitä, että vedonlyönnin kohteena ei siis saa olla esimerkiksi punainen tai keltainen kortti, pelirangaistus tai varoitus.


Jonkin verran keskustelua on syntynyt myös siitä, voiko nykyinen monopoliyhtiö siirtää nykyiset asiakkaansa uuteen lisenssiyhtiöön. Lakiesityksessä todetaan, että Veikkauksen yksinoikeustoiminnan nojalla kertynyttä asiakaskantaa voi hyödyntää kilpaillulla markkinalla toimivan rahapelitoimiluvan haltijan rahapelitoiminnassa osalta ainoastaan siltä osin, kun kyse olisi rahapelitoimiluvan piiriin kuuluvien rahapelien pelaajien muodostamasta asiakaskannasta.


Lakiesityksessä ei ole varsinaista cooling off periodia, mutta esityksessä todetaan, että lisenssiä ei voitaisi myöntää, jos hakijalle olisi kahden arviota edeltävän vuoden aikana, mutta kuitenkin 1.9.2024 jälkeen, annettu kieltopäätös tai määrätty seuraamusmaksu arpajaislain vastaisesta rahapelien toimeenpanosta tai markkinoinnista. Pidän tätä jonkinlaisena cooling off periaatteena, vaikka kieltopäätöksen antaminen on kohtuullisen raskas ja aikaa vievä prosessi, eikä nykyisellä valvojalla ole siihen kovin paljon resursseja.

B2B lisenssi voimaan vuonna 2028


Kuten jo heinäkuun lakiesityksessä todettiin, niin toimiluvanhaltijan tulee käyttää yksinomaan peliohjelmistotoimiluvan (B2B lisenssi) haltijoiden toimittamia peliohjelmistoja. Peliohjelmistoimiluvan haltija ei saa toimittaa peliohjelmistoja sellaiselle rahapelien toimeenpanijalle, joka toimeenpanee tai markkinoi rahapelejä lain vastaisesti ilman suomalaista lisenssiä. Tämän hetken tiedon mukaan B2B lisenssejä voidaan alkaa hakea vuoden 2027 alkupuolella ja vaatimus B2B lisenssin käyttämisestä tulee voimaan vuoden 2028 alusta alkaen.


Esimerkkejä B2B lisenssin alaisista ohjelmistoista ovat muun muassa vedonlyöntiohjelmistot, satunnaislukugeneraattorit, pelidataa sisältävät rahapelitulosten esittämiseen käytettävät ohjelmat, livekasinotoiminnassa hyödynnettävät pelitapahtumien suoratoistoratkaisut ja pelitapahtumien valvontaohjelmistot, rahapelissä laskelmia suorittavat ohjelmistot, rahapelitapahtumia hyväksyvät ja tallentavat ohjelmistot, rahapelin lopputulosta määrittävät ohjelmistot sekä rahapelivoittojen laskemisessa ja pelitilille siirtämisessä käytettävät ohjelmistot.

Yhteenveto


Edellä mainittujen asioiden lisäksi lakiesityksessä määritellään satoja muita asioita, joiden läpikäynti tällaisessa blogissa on mahdotonta. Autamme mielellämme teitä ymmärtämään vielä enemmän yksityiskohtia, mutta osa niistä ei ole vielä edes selvillä.


Kokonaisarviona sanoisin, että lakiesitys on mennyt heinäkuusta positiivisempaan suuntaan, jos ajattelen peliyhtiöiden mahdollisuuksia rahapeliliiketoiminnan harjoittamiseen Suomessa. Esityksessä on kuitenkin järjestelmän kanavointikyvyn nostamisen näkökulmasta muutama iso pettymys. Sallittujen bonusten määrittely on mielestäni vielä epäselvä, mutta se vaikuttaa rajoittavan bonusten käyttöä erittäin paljon. Toinen, vielä suurempi, virhe on affiliate toimijoiden käyttämisen kielto. Tämä rahapeliyhtiöiden yleisesti käyttämä kumppaniverkosto jää uudessa rahapelijärjestelmässä nyt kokonaan ilman lisenssiä toimivien peliyhtiöiden työvälineeksi. Uskon, että varsinkin online kasinopelitoiminnassa Suomen rahapelijärjestelmän kanavointiaste jää tämän vuoksi paljon odotuksia alhaisemmaksi.

Do the Finnish proposed marketing rules enable a competitive offering?

I originally wrote this text on http://www.finnplay.com in early September 2024.

The proposal for Finland’s new gambling legislation has finally been published, and stakeholders have commented on it. As many as 130 statements were collected during the public hearing process, and now the authorities are analyzing them and thinking about how they might affect the final content. According to unofficial information, the purpose is to complete the legal package during October 2024 and then send it to the EU notification process. At that stage, we will know even more precisely what Finland’s new gambling system will be like.

However, we can already evaluate the future system at this stage because it is assumed that the “big picture” will not change much compared to the proposal published at the beginning of July. As I have stated in my previous writings, Finland’s goal is to raise the channelization rate of the gambling system as high as possible, preferably close to the 90 % level. This is intended to be implemented so gambling companies get the best possible business opportunities. Still, even so, the number of gambling problems should at least not increase but rather decrease.

The business opportunities of gambling companies are greatly influenced by the marketing they are allowed to do in Finland. My focus in this blog is to evaluate the marketing and sponsorship content of the gambling bill. Will the operators acquiring the license have sufficient opportunities to market their brand, products, and services? Are those opportunities better than illegal companies operating without a Finnish license? Will the channeling ability of the gambling system rise to the desired level, and will the gambling problems remain under control?

Marketing will be allowed but limited

Gambling marketing will be allowed in Finland’s new system. Well-planned marketing regulation helps licensed companies attract customers and gambling into the legal system, increasing the channelization rate and enabling the authorities to regulate as much gambling as possible. Fortunately, the legislation’s drafters have finally understood how this dynamic works.

It is a pity that the starting point for marketing regulation is Finland’s current legislation, which only applies to the monopoly company Veikkaus. This shows that the law’s drafters either do not know or do not want to know the legalities of the modern gambling business. For some reason, the officials don’t understand that the current regulation that significantly limits the operation of Veikkaus is the main reason our gambling system’s channelization rate has collapsed, especially in digital sales channels. Veikkaus has been banned from several activities that offshore operators use daily. Active customers, in particular, have switched to other companies following better offers. The restrictions on the operation of Veikkaus would still be acceptable if they would have reduced gambling problems. However, the opposite has unfortunately happened, i.e., the problems have also grown.

In general, I can say that gambling marketing in mass media will be possible without any significant limitations. Still, in digital media, there would be many restrictions that offshore companies are not used to elsewhere. I am afraid that the restrictions may be so significant that at least some potential companies decide not to apply for a Finnish gambling license.

Finland wants to ban affiliate activity

Based on the bill, only the gambling company is allowed to market gambling. This marketing includes both brand and product advertising. The bill states that a “third party” is not permitted to do gambling marketing. However, the proposal does not define what marketing means in practice. Regarding this limitation, it should be noted that affiliate activity is not possible for the current monopoly company, so presumably, the law drafters have also taken this idea from the current legislation and have not sufficiently familiarized themselves with the operations of other countries.

The proposal aims to prevent celebrities and social media influencers from marketing gambling. However, the current definition also includes affiliate services common in digital channels. These services aim to provide sports punters and casino players with information about gambling content. Although these affiliates often make their income from customers’ gambling losses, these sites also offer valuable information to support gambling.

According to my understanding, the share of gambling companies’ new customer acquisition coming through affiliate operators is very high, in some cases even close to one hundred percent. Affiliate operators are search engine optimization professionals and will undoubtedly continue their activities, even if efforts are made to prevent their activities by Finnish legislation. In this case, the affiliates will serve operators outside the system, which will automatically decrease the channeling capacity of the system. This is not in Finland’s interest. Instead, a solution should be found to allow affiliate activity and bring it within the scope of Finnish legislation.

So, I’m in favor of allowing affiliate activity, even though I wouldn’t say I like it. However, I believe it is a better solution for everyone that affiliates can work in cooperation with licensed operators than that they remain tools of illegal activity.

Bonuses are going to be banned

Another common feature of gambling that I dislike is the offer of bonuses. In my opinion, bonuses are, generally speaking, “cheating” customers. However, I don’t think offering bonuses can be stopped in the world’s gambling business. For this reason, I consider the Finnish bill to be a lousy solution, based on which offering all kinds of bonuses and similar customer benefits will be prohibited.

I believe this proposal also originates from the current legislation, based on which Veikkaus is not allowed to offer bonuses, discounts, free spins, or give customers betting money. Such offers are widely used in the international gambling business. In Sweden, the supply has been significantly limited, but there is no complete ban there either. Gambling companies operating with a Swedish license consider the current bonus restrictions to be the biggest reason why the channeling capacity of the Swedish system is now rapidly decreasing. This happens especially in online casino gaming, where companies with a Curacao license take Swedish customers with bonus offers.

If affiliate operators and bonuses are prohibited, new gambling operators coming to Finland will have significant challenges getting customers. This primarily serves the interest of Veikkaus and possibly a couple of other big gambling companies, which already have many Finnish customers, and distorts the competition. Therefore, concerning bonuses, a way should be found to allow them, at least to some extent, in Finland as well.

I propose that bonuses be allowed so the gambling company can only set a wagering requirement of one round for them. The customer could, therefore, claim the bonus money for himself after he has played that amount in the company’s games once. In this model, it would be much easier for the customer to understand what he is getting than in the current offshore model, where the money has to be played dozens of times before he gets it for himself. From the point of view of the operator, the model I proposed is much worse financially compared to the current model, where the companies practically do not give out money at all.

There will be just few restrictions on mass media marketing

Based on the bill, the Finnish mass media has been highly successful in lobbying. In practice, gambling advertising in the mass media seems to be possible almost without any restrictions. Of course, there will be restrictions and prohibitions for marketing aimed at children and other groups of minors.

If the digital media marketing methods increasingly used by offshore companies are banned, there is a significant risk that the general public in Finland will encounter a lot of gambling marketing in mass media – TV, radio, and newspapers. In Sweden, this has caused public opinion to turn negative towards gambling. There has been far too much marketing in mass media, according to the opinion of ordinary Swedes. Finland should not find itself in the same situation because it is against the interests of all parties operating in the gambling business.

I propose that while digital media’s marketing restrictions are reduced, mass media marketing is tightened. One option to be considered could be a restriction according to which the mass media should only contain brand advertising of the gambling companies, which should not include an order to gamble. In this way, the gambling companies would make their brand known among Finns, but people would not have to face the “play now right now” type of advertising against their will. Operators could give such messages in their betting services when customers come to play.

Sports sponsorship will be possible

One crucial marketing tool, especially related to betting, is sponsorship. The bill allows gambling companies to enter into sponsorship agreements with sports and other parties. Restrictions are proposed for sponsorship to prevent or at least limit exposure to minors.

I have previously criticized proposals concerning marketing, but concerning sponsorship, it must be said that I think the bill is well-founded, and its content seems reasonable. However, in the proposal’s arguments, a model is presented for consideration, namely that the gambling company should not be the so-called title sponsor. If implemented, this proposal would make the current model, where Veikkaus is the title sponsor of the Finnish football league, impossible. I think that would be an unnecessary restriction.

Finnish sports, or at least the most prominent sports leagues, are already excitedly waiting for new revenue streams to open up. However, based on the experiences of Denmark and Sweden, I believe that only football and ice hockey will make up for the larger amount of money in the new model.

The Statement of The Finnish Gambling Consultants about the proposed Finnish Gambling Bill

Background

FGC would like to thank the government for the proposal, which aims to open the Finnish gambling market to competition partially. In the preliminary work section of the bill, the situation is well described to which the gambling system, according to the current monopoly model, has taken the Finnish gambling market. The channeling ability of the system in competing product groups has already sunk too low. When planning a new system, it is paramount that the channeling capacity of the system be restored to a high enough level, preferably close to the 90 % level. The responsibility measures that control gambling activities remain ineffective without a sufficiently high channelization rate because the authorities’ measures are only effective for regulated gambling.

FGC considers that there is a lot of good in the given proposal. The channeling ability of the Finnish gambling system would improve significantly if the new Gambling Act were implemented in the form presented. However, the 90 % channelization rate mentioned above would not be reached by this proposal.

Overall opinion on the proposed bill

The good side of the bill is that it aims to create a gambling system where gambling companies have the opportunity to do business, but at the same time, the number of gambling problems should not increase. The goal of expanding the channelization rate as high as possible is the only correct solution from the point of view of the realization of business and responsibility. However, FGC wonders why the essential solution for reducing gambling problems, moving all slot machines to age-restricted premises, is missing from the proposal.

According to FGC’s view, there are several contradictions between the individual sections of the bill and the overall goals. Products with a high-profit rate for the gambling company (Veikkaus) remain on the monopoly side, which is why the proposal inevitably shows that the real reasons for the presented product division are purely fiscal. Fiscal reasons, however, cannot justify a gambling monopoly according to EU law. In addition, the products, except slot machines, proposed for monopoly do not significantly cause gambling problems.

The apparent inconsistency of the bill is in marketing and operations as a whole. According to the proposal, gambling companies could not use bonuses or third parties, such as affiliates. Still, other marketing and sales promotions would be pretty accessible. This includes a significant contradiction in the pursuit of a high degree of channeling and decreasing gambling problems. FGC believes that gambling companies should be able to compete against illegal offerings specifically in digital channels. From the point of view of increasing the channeling ability, there would be no similar need for the abundant marketing of gambling in physical channels and Finnish mass media because illegal operators are not visible in these media. In the best comparison country, Sweden, gambling advertising in the mass media increased enormously some years before the actual gambling system change and has remained at a very high level after the change compared to gambling advertising in Finland. Due to abundant mass media advertising, the general opinion of citizens towards gambling in Sweden became significantly more negative than before because the media was full of gambling advertising.

Based on the proposal, the Finnish state wants to maintain a dual role, taking care of the legislation and supervision of gambling activities and, at the same time, owning the company involved in gambling activities. There is a high risk of conflict of interest in such a model. State ownership of a gambling company operating in a competitive market is at least a questionable solution. The Finnish Competition and Consumer Authority and the Chancellor of Justice have already raised this same issue in their statements.

In this statement, FGC writes its observations about the Gambling Act and proposes corrective measures and changes to the proposal.

General notes:

General note about potentially incorrect information appearing in the proposal

The material supporting the bill is comprehensive and of high quality. However, there is one very relevant piece of information in the background material that we believe is debatable, if not even incorrect. In the preliminary works, it is implied that the channelization rate of the Swedish gambling system would have remained high in recent years. The Swedish authorities’ assessments of channelization rate are used as justification for this. In Sweden, the authorities’ assessments have been strongly criticized by operators in the gambling industry. The biggest operator in the Swedish license market, ATG, the former horse betting monopoly holder, has independently investigated the system’s channelization rate with more credible methods than the authorities. ATG has analyzed and modeled the observed network traffic and mirrored it to existing accurate gambling and customer data numbers.

The total volume of the Swedish license system has remained practically constant since the end of 2020. However, according to ATG’s research, overall gambling in product groups belonging to the license-based market has increased, and all growth seems to have been directed to gambling companies outside the system. ATG does not present an exact estimate of the channelization rate of the license-based system but implies that it could move around 70 – 82 % level at the end of 2023. The channelization rate of digital casino games seems to be significantly lower than the average, and the channeling rate of betting games is correspondingly better than the average. FGC attaches to its statement a summary (Appendix 1) of ATG’s approximately 30-page research report, which FGC has received permission from ATG to distribute. FGC believes that, if needed, the full ATG research report is available for use.

FGC points out that if ATG’s estimates of the supposed weaker channeling ability of digital casino games are correct, there is a significant risk that the channeling rate of digital casino games in Finland will not rise in line with the goals if the final law is what the Ministry of the Interior has proposed. This would be particularly harmful from the point of view of addressing gambling problems. Based on the data obtained from Sweden, specifically problematic gambling tends to move outside the system more easily than other gambling.

General note on the proposed regulation

FGC points out that the proposal has left significant issues regarding the final implementation of the gambling system behind the regulatory powers. This applies, in particular, to items under section 31. From the point of view of ensuring the functionality of the system and its channeling ability, the appropriateness of the parameters behind the settings can decide the success of the final result. Suppose the parameters given through the settings are adjusted incorrectly. In that case, the success of the entire reform may be at stake, and the result may be the worst possible – a license-based system with weak channeling capabilities.

FGC’s improvement proposal: To maintain the gambling system’s overall objectives, overall control should be maintained when making regulatory-level decisions. The Government, not individual ministries, should issue the final regulations (settings) on gambling.

General note on the tax treatment of unlicensed gambling winnings

The proposal contained in the bill to regulate unlicensed gambling winnings as taxable requires changes. FGC considers the proposed goal of extending taxation to all digital gambling outside the system to be correct and consistent. However, it includes shortcomings and challenges to the fair treatment of citizens. According to the proposal, stakes used for lost games may not be deducted from taxation. This creates an unfair situation, especially for players with gambling problems who gamble outside the system more often than other customers. If a person with a gambling problem loses, for example, 10 000 euros in unlicensed digital casino games, he could, for example, have gambled 200 000 euros and received winnings of around 190 000 euros. About three out of four rounds may have been ones in which the player won nothing, and those stakes are not tax deductible. As a result, a problem gambler who lost 10 000 euros receives a taxable income of around 140 000 euros in this example, in addition to the losses. (Appendix 2 opens up the example case a little more). This unfair outcome significantly worsens the situation of the problem gambler.

FGC’s improvement proposal: Regulated tax penalties should apply to the net winnings generated from gambling during one calendar year. This means all taxable gambling winnings the player has achieved during the calendar year, minus all bets and losses of the corresponding period.

General note on Veikkaus’ group structure from a competition law point of view

Customer base and technology

Based on the bill, the part of Veikkaus that continues in the license-based market may have a competitive advantage due to Veikkaus’s monopoly operation. This cannot be considered an action acceptable under competition law. The draft of the proposal even admits that the chosen solution seeks synergy between the operation that will remain a monopoly and the company that will switch to the license-based side.

In FGC’s opinion, there should be a clear policy on whether Veikkaus’s current customers can be transferred to a company continuing in the license market in a way that it cannot be considered a benefit from customers obtained from the monopoly operations. The calculated value of the customer base is at least hundreds of millions of euros. FGC also points out that if the part of Veikkaus continuing into the license market were allowed to utilize all of Veikkaus’ current existing customer base, Veikkaus’ license company would be given a substantial competitive advantage compared to the operators entering the market.

A company operating in a competitive market may not use the same resources as a monopoly company from the same group in a way that distorts competition. Dividing Veikkaus into several companies includes a plan to establish a separate technology company. The plan consists of the risk that the monopoly company and the license-based company will use common technology, for which, according to the plan, compensation will be paid at the market price. Determining the amount of such compensation will be challenging and, in some cases, even impossible.

FGC’s improvement proposal: To avoid problems with competition law, it would be stipulated that the Veikkaus group companies should not use joint technical solutions related to gambling. That would be the same rule as in Sweden.

The games in physical slot machines

According to the bill, slot machines, which would continue to be thousands all over Finland, continue to be covered by Veikkaus’s monopoly. These machines would have the same casino games developed mainly by Veikkaus, which Veikkaus’s license-based company would offer in the competitive license market. Those slot machines would be a significant marketing channel for the games in question, from which Veikkaus’s license company would also gain a significant competitive advantage.

FGC’s improvement proposal: A single product or game would be offered only in the monopoly or license-based market so that the customer knows which group’s game he is playing. Veikkaus’s monopoly and license companies should not offer the same product or game.

Detailed considerations:

Note on mandatory limits

Based on the proposal, the customer would be forced to set limits on gambling when setting up a betting account, which would aim to prevent harmful gambling. FGC wants to point out that although ideologically, the idea sounds valid, the practical experiences of the gambling industry have been different. In practice, it has been noticed that when a problem gambling customer hits the limits, he rarely stops gambling. Instead, gambling continues either with another official operator or, in the worst case, outside the legal system. Mandatory limits are not a good way to curb problem gambling but an excellent way to weaken the channeling ability of the gambling system.

FGC points out that making gambling limits mandatory was the biggest reason that Veikkaus’s channeling rate, especially in digital casino games, started dropping rapidly at the end of 2018. In the new system, the effect of the obligation to set limits to the channelization rate would not be as dramatic because the customer could continue gambling with the service of another licensed operator. In practice, however, players would be forced to change gambling operators. In connection with such a change, the risk of the customer switching to gambling for an operator outside the system is always tangible.

FGC’s improvement proposal: Setting gambling limits should be suggested to the customer during registration, but setting them should not be mandatory. The Ministry of the Interior should consider implementing gambling limits, for example, according to the Estonian model. In Estonia, the gambling operator must give customers the opportunity to set their limits during the customer registration process, but if the customer does not want to set them, he can, by his active decision, not set the limits.

In this context, FGC would also like to point out that if a solution is decided in the future where standard mandatory gambling upper limits are set for all players, customers should be able to increase their limits if they wish if they can demonstrate that their financial situation allows this. Such a solution ensures that the system’s channeling ability is maintained so that the risk of gambling problems does not significantly rise.

Note on bonuses

In FGC’s view, the categorical ban on all bonuses in the proposal is problematic when considering the system’s channeling ability. FGC agrees with the Ministry of the Interior that bonuses that encourage gambling can increase problematic gambling and, thus, gambling problems. Still, that would be a significantly smaller disadvantage than leaving the bonuses only for operators outside the system and helping channel gambling outside the system.

The importance of bonuses, especially for the customer experience of digital casino games and the profits of gambling companies, is enormous. The more active the customer is, the more critical the customer considers bonuses and other loyalty rewards offered by the operator. In general, the most active customers are problem gamblers or players whose gambling problem is developing. Suppose operators redeeming their licenses are denied all bonuses. In that case, the system’s channeling ability will fall significantly below the target level, as customers who are used to bonuses will move to gambling companies outside the system. It will be especially problematic if the players, who the system should be able to protect, move to play for operators outside the system.

FGC would also like to highlight that at most current international gambling companies, the implementations of bonuses and loyalty systems are often so complicated that not all players even understand how bonuses work and are available. If bonuses were partially allowed in the license-based system to improve consumer protection, it would be possible to demand clarity and simplicity from them so that consumers could understand the structures of the bonuses in detail.

FGC’s improvement proposal: The Ministry of the Interior should consider allowing bonuses in legislation so that bonuses can be given to the player, but their complicated wagering conditions would be prohibited. The bonus recycling condition should only require the customer to play the bonus money he received once through games, after which he could withdraw the remaining money for himself if he wished. With the presented change, the competitive conditions of legal operators would improve against supply outside the system, and the channeling capacity of the system would improve considerably. From the point of view of gambling problems, the legal offering would cause a few more disadvantages than the current one, but keeping customers who gamble especially problematically within the scope of the gambling system would bring a significantly more significant benefit. The society remains informed about possible problem gambling and can target actions to reduce problems only when the customer plays games from a legal operator.

Note on the categorical ban on marketing by third parties

The bill proposes that gambling marketing can only be done by licensed gambling operators. FGC considers that the categorical ban on the marketing of gambling by third parties is problematic and causes significant problems when evaluating the legality of various activities. To some extent, the regulation could be improved by defining illegal marketing more precisely, but such a solution will not completely eliminate the problems.

Affiliate activity – business-like marketing

In the categorical ban on marketing by third parties, problems arise, especially with regard to various affiliate sites. These are typically international online sites that directly or indirectly advertise gambling services. It is not always clear which country’s regulation the affiliate operates under. FGC points out that the gambling legislation of many other countries allows the use of affiliate services.

FGC points out that leaving the entire affiliate activity outside of Finland’s official gambling system poses a significant risk to the system’s channeling ability. Existing affiliate operators already have an extensive customer base of Finnish customers. In Finland, a lot of searches related to gambling are made through search engines, especially Google, which direct people to affiliate sites. People do not stop such searches, and the direction of internet traffic to affiliate sites does not stop, even if affiliate activity is prohibited in Finnish gambling operations. In this case, affiliate operators would direct customer traffic to the pages of gambling companies operating without a license, weakening the gambling system’s channelization rate.

The bill has defined strict boundary conditions for all gambling marketing. If affiliate activities were allowed in Finland, these companies would have to follow the same marketing regulations as gambling operators and media companies. Affiliate activity should become significantly cleaner compared to the current practically completely unregulated situation.

FGC’s improvement proposal: The Ministry of the Interior should look for an implementation method to bring affiliate operators into the scope of official regulation. An alternative to be considered could be, for example, the Romanian model, where affiliate operators are required to have a separate business license, which could be part of the proposed supplier license.

Note on the presented product groups in exclusive and multi-license systems

In FGC’s opinion, the arguments for leaving certain product groups under exclusive rights seem artificial. The reasons given are that there is currently no competition in the product groups in question and that transferring those products to the multi-license system would increase the marketing of these products. This, in turn, would increase the gambling problems caused by these games. However, based on the proposed law, the monopoly would mainly be in those product groups that, according to studies, cause little or no gambling problems. Only physical casino and slot machine operations are an exception in this respect. For example, the inclusion of lottery game operations in the scope of monopoly cannot be credibly justified with these arguments.

In particular, FGC considers leaving pool-based horse betting and digital eInstants within the scope of Veikkaus’s exclusive right to be an incorrect solution, and no credible justifications have been presented for the proposal.

Pool-based horse betting (Tote games)

In the case of Tote games, the existing high channelization rate and the fact that competition could increase the marketing of the products, and thus, the resulting gambling problems are presented as justifications. FGC points out that in the studies of both The Finnish Institute for Health and Welfare and the helpful line, Peluuri, Tote games have been one of the product groups that cause the least harm. Releasing them to the license-based system could increase the marketing of the products, but this could be considered mainly to direct the demand for less harmful gambling. In addition, concerning the channelization rate of Tote games, it must be understood that the high channelization rate is realized only because Veikkaus has a cooperation agreement to offer Swedish horse races with the Swedes in a common pool for Veikkaus’s customers. If the agreement were to cease to be valid for some reason, the majority of existing betting would be transferred to other operators operating without a Finnish license, and the high channelization rate of Tote games would collapse immediately.

Tote games are currently part of the license-based market in Sweden and Denmark. This is the digital sales channel situation in all European countries that have switched to a license-based gambling system. In the Netherlands, only one company can operate pool-based horse betting, but even that has gained its status through bidding. In Denmark, Tote games were initially on the side of the monopoly system. Still, that arrangement was found to be problematic and dysfunctional, as a result of which Tote games were moved to a competitive market in 2018.

FGC would also like to point out that section 26 of the draft law prohibits the organization of betting for gambling events/draws that are used in the monopoly business. In practice, the operating model would mean that operators applying for a business license in Finland would no longer be allowed to offer fixed-odds betting at those races where Tote games would be organized. This can be considered a significant regulation aimed at limiting competition because large international listed companies would apply for a Finnish license, and they compete against pool-based horse betting in Sweden with fixed odds betting products.

FGC assumes that section 26 and its justifications are written mainly from the point of view of lottery games. If Tote games were to be left as a monopoly, the proposal should be supplemented so that fixed-odds betting on the outcome of horse races would be possible. If Tote games are moved to the side of the multi-license system, this definition problem does not exist.

FGC’s improvement proposal: Pool-based horse betting/Tote games will be transferred to a multi-license system.

Digital eInstants

Regarding eInstants, FGC wants to point out that with the proposed regulation, Finland would return to the situation that led to the merger of three gambling companies at the beginning of 2017. The main reason for the merger was the weakening of the differentiation of Veikkaus’s and RAY’s products in the digital channel. The proposed regulation would do the same – not least because the proposal would allow eInstants draws to be made at the time of game purchase (RNG technology), just as in digital casino games. The visual implementation of eInstants and digital slot machines can be very identical. FGC wonders how the separation of these products can be handled reliably and how the consumer has the opportunity to identify which product group’s game he is playing.

FGC’s improvement proposal: eInstants would be included in the category of digital casino games and would, therefore, be moved to the side of the license-based system. Alternatively, eInstants could be arranged to be implemented technically so that their technical and visual implementation would differ significantly from the implementation of digital casino games.

Note on the possibility of the supervisory authority to regulate the activities outside the system

FGC considers it good that the bill aims to give the supervisory authority the means to intervene in the offering and marketing of unlicensed gambling in Finland. However, according to the FGC’s view, it seems that the vast majority of the proposed measures would affect the operations of license companies in particular. However, blocking payment and online traffic (IP) can be a reasonably effective way to reduce gambling outside the system.

FGC does not identify measures in the bill and its explanatory text that the supervisory authority could use to monitor gambling outside the Finnish system. According to FGC’s understanding, gambling outside Veikkaus is significantly more significant than the authorities estimate. It is practically impossible for the authorities to intervene in illegal supply if that supply is not even recognized. Technical systems and services would be available for monitoring and intervening in gambling, which could be used to significantly improve the system’s channeling capacity and increase the state’s tax revenues.

In the bill, great attention is paid to preventing betting-related incidents. At worst, match manipulation and other abuses are a problem for sports comparable to doping, or even worse. The bill says that Veikkaus’s own measures, FINCIS’s (Finnish Center for Integrity in Sports) operations, and ULIS’s (United Lotteries for Integrity in Sports) cooperation are excellent and sufficient measures to prevent abuses. In FGC’s opinion, this is unfortunately not the case. Finnish sports are likely also currently being used to organize illegal activities. Monitoring and preventing match manipulations should not remain the responsibility of the betting companies. Still, the authorities should take a more significant role in the matter than at present.

FGC has requested a description of the benefits of a modern monitoring system from Sportradar, which focuses on monitoring international gambling activities and preventing sports manipulation. That description is included in the appendices to our statement (Appendix 3).

FGC’s improvement proposal: The authority supervising gambling activities would be obliged to acquire technological systems that monitor and supervise gambling activities outside the license system. In addition, the regulator or other separately defined authority should join an international network that could be used to monitor global betting activities and identify possible abuses related to Finnish sports.

Minor notes

The proposed ban on using a credit card for money transfers does not protect those with gambling problems, even though that has been the explanation. In practice, that means the customer first transfers the money from the credit card to his bank account and then to his betting account. In practice, the regulation intended to protect those with gambling problems mainly results in a small additional cost for them. The ban on the use of credit cards, and especially debit cards, causes problems, especially for transactions at retail channels. In addition to the customer, the affected parties are especially retail outlets and Veikkaus, which offers gambling products in the retail channel.

The proposed procedure for lifting the indefinite gambling ban is problematic. When a customer wants to start gambling again after a break of at least a year, he is given the option of waiting three more months or moving to gamble outside the system. FGC considers that a person who hasn’t gambled for more than a year should have the opportunity to lift an indefinite ban immediately. There must be a separate consideration period to cancel short and fixed-term bans. However, if bans are valid indefinitely and have continued for over a year, that three-month consideration period will not accomplish anything other than the player moving to play outside the system.

Sincerely yours,

Jari Vähänen

Partner

The Finnish Gambling Consultants Oy

Finland has submitted the new Gambling Act for consultation

On Wednesday, July 3, we finally found out what kind of gambling legislation the Finnish government is planning for Finland. The published proposal has more than 400 pages, and I have only been familiar with it for a working day. So, my observations and opinions in this text are only preliminary, but I still want to share them with you. Finland has started the public hearing/consultation process, which will last until August 18. In principle, anyone can express their opinion on the bill during that time. According to the information I have received, this time, based on the consultation process, Finland is still ready to make changes to the gambling legislation. Because of this, it is not yet time to make assessments about how right the guesses I presented at the beginning of the year about the content of the law turned out to be in the end.

The schedule of the process has been specified. After the consultation process, changes are made to the law, after which the bill is sent to the EU notification process. After the EU notification, the proposal will proceed to the Finnish parliament in the spring of 2025, and the law is supposed to be approved during the next year. Part of the content of the bill will enter into force already in 2026, but in practice, Finland will switch to a partial license-based gambling system from the beginning of 2027. Some things will not be implemented until 2028, so there should be enough time for the preparation.

Monopoly and other licenses

In current Finnish legislation, Veikkaus’ gambling monopoly is defined in law. In the new system, monopoly games will be granted an exclusive license for a period of ten years, which can only be given to a company under the direct control of the Finnish state, i.e., Veikkaus in practice. According to the proposal, the product areas covered by the monopoly are scratch cards (including eInstants), lottery games (e.g., lotto products and Keno), slot machines, physical casinos, and pool-based horse betting. The product areas that will be transferred to the license system are fixed odds betting (also includes horse racing), pool-based sports betting/games, digital casino games (roulette, craps, card games – poker), and digital slot machines and digital bingo. A gambling license is granted for five years.

In the list of monopoly products, pool-based horse betting, which accounts for 3-4 percent of all gambling in Finland, is the most surprising. It is not an important matter from the point of view of the whole, and therefore, keeping it within Veikkaus’ monopoly is strange, especially when the horse racing industry would like to transfer the games to the licensing side. I’m sure it will be a hard-fought battle in the coming months. I guess that pool-based horse betting will eventually be moved to the license side, where pool-based sports games already are.

The price of the gambling license is tied to the size of the operator’s gross gaming revenue. The minimum payment is 4000 euros, and the maximum price is 265000 euros if the GGR is over 50 M€/year. The gambling tax will be 22 % of the GGR, which is quite reasonable.

B2B license in 2028

Finland also introduces the “Game software license.” However, this license is not required immediately in connection with the change in the gambling system but from the beginning of 2028. The B2B license application process will be started at some point during 2027, and the license will be valid for five years. A game software license practically means that the license holder is obliged to use only the software and games of the game software license holder. The price of the license will be very affordable, i.e. only 1500 euros.

As a general rule, gambling IT systems must be located in Finland. There are two exceptions when IT systems can be somewhere else. If the supervisory authority of the country of location has a cooperation agreement with the Finnish supervisory authority, or the Finnish authority can verify the gambling IT system and its operation via a remote connection.

The supervising authority will issue all licenses. The current regulator, the National Police Board, is responsible for the legislation’s practical preparation. Still, a new agency, the Finnish Supervisory Agency, will be established under the Ministry of Finance to supervise the new gambling system. The new agency will start operating at the beginning of 2027.

Marketing is allowed but limited

Gambling marketing is allowed, but there are restrictions. The law has a list of prohibited gambling marketing, such as describing gambling as a way to solve financial problems. Sports sponsorship is also allowed, but there will be restrictions related to minors.

Marketing regarding the brand gambling companies and games may only be done by the gambling company itself. The law states that no other entity may do marketing related to gambling. This will significantly complicate the position of affiliate operators. On the other hand, the definition of advertising and communication will be complex, thanks to which, at least in betting, affiliates will also find their place in the Finnish market.

Gambling services and sites must not use interactive marketing. That means companies cannot discuss gambling issues with customers on social media, and operators are not allowed to offer customers the possibility of forwarding the gambling company’s publications.

Customers must give permission for direct marketing on their own initiative. The gambling terms must not automatically contain direct marketing permission, but they do require the active approval of the customers themselves.

The most interesting thing, and certainly one that receives a lot of criticism from current offshore companies, is the banning of bonuses. According to the law, gambling companies may not offer bonuses, either free games or games at a reduced price. In addition, the law has separately stated that using bonuses in all gambling marketing is prohibited.

Some other relevant matters of legislation

There is currently an option for payment blocking in Finland, which targets money transfers from Finland to gambling companies. In the new legislation, payment blocking is possible in both directions. Legislation has also specified that the blocking will also apply to cryptocurrencies, even though cryptocurrencies may not be used to pay for gambling at all. You also cannot pay for gambling with a credit card or buy it as a debt anyway. In addition to payment blocking, Finland can also implement network traffic blocking for gambling companies operating without a Finnish license.

There will be gambling company-specific money transfer limits, which the player must set (day and month) and can change. Those limits mean the amount of money that can be transferred from a bank account to a betting account. The state can set operator-specific maximum loss limits (daily, monthly, and annually) if it wishes, but this is not an automatic assumption.

The customer must have the option to set centralized prevention for all gambling, like Spellpaus in Sweden. In addition, the customer must be able to set himself a prevention for a particular gambling company’s games or part of them (a specific game or group of games).

JARI VÄHÄNEN

jari.vahanen@finnishgc.fi

A watched pot never boils

Unfortunately, I still have nothing new to share about Finland’s future gambling system officially. As I explained in my previous blog, the authorities preparing the legislation have not shared any interim information during the process. However, some additional information has leaked out during the process, and I have also helped, at least to a small extent, in planning and preparing the new gambling legislation. As an entrepreneur, I want compensation for my work, but when the motherland asks, I am ready to make an exception. I hope my work was helpful for the upcoming change.

As you may remember, according to the original schedule, the working group had to finish its work by the beginning of March, and the public hearing process was supposed to start at the beginning of June at the latest. As I guessed last time, the work of the working group was not completed according to the schedule, and the ready part did not correspond to the will of the Finnish government. Because of this, Prime Minister Petteri Orpo and his government decided to take the monitoring of the legislative project directly under their control. The preparation is still handled by the same working group, whose steering group remained unchanged, but now the matter will be reported to the Ministerial Committee on Economic Policy. This change seems to have accelerated the preparation of the legislation.

According to unofficial information, the policies presented by the working group at the beginning of March contained overly strict restrictions on gambling activities. Based on them, it would not have been credible to assume that the channelization rate of the Finnish gambling system could have risen even close to the target level of 90%. An optimally functioning system must have a balance between responsible gaming and business opportunities. This is also the goal of the Finnish government so that the number of gambling problems does not increase, and the largest possible share of gambling takes place within an officially controlled system.

No new timetable has been given for the preparation of the legislation, so it is assumed that the government will still stick to the original goal of having the new gambling system come into effect from the beginning of 2026. Since the work of the working group has been delayed in any case, it can be assumed that further delays will be avoided, and the schedule will be tightened in other respects. According to unofficial information, the goal is for the working group to finish its work by the end of May, or at least before the civil servants’ summer vacation period. Based on this, it can be assumed that the public hearing process could start in August at the best and the beginning of September at the latest.

A ready legislative text is needed for the public hearing so that when the process starts, we know what kind of system the government wants for Finland. In principle, it is possible that as a result of the public hearing process, there will still be significant changes to the legislative proposal. Still, it is more likely that the proposal’s content will remain approximately the same. For this reason, I consider the proposal of the Lottery Act that will be made public in August – September as an important basis for gambling companies’ and system suppliers’ assessment of whether it is worth it to start preparing to enter the Finnish market.

Of course, it is unfortunate that the schedule has already been at least somewhat delayed. On the other hand, in the big picture, a delay of 2-3 months means nothing in the end. However, it would be easier to adapt to that additional time of a few months if there was a certainty that it was indeed an official schedule. Unfortunately, this is not the case because the time estimate is only my “best guess” at this point. I understand that they want to do the preparatory work properly, but information about the progress of the process could have been done more openly.

In my previous blog, I made guesses about the future system. Even now, just two months later, I would be ready to change a few points. Veikkaus is trying to hold on to its monopoly in horse betting, eBingo, and eInstant areas. The influence of the state-owned company regarding gambling has been enormous, and that weight is still not small. For this reason, I suppose that at least some of those product areas remain within the scope of the monopoly system.

Finland’s legislative work progresses, or does it?

According to the target schedule for reforming Finnish gambling legislation, we live in exciting times. The working group responsible for the preparation should finish its work within a couple of weeks. After this, Ministry of the Interior officials should be able to write the law, which should be ready and translated during May so that the public hearing can begin in June. So, at the latest, we should have information about what kind of new gambling legislation is being planned for Finland by the beginning of June.

So far, no official information has been received about the working group’s work, so unfortunately, I don’t know what they have planned. However, there is quite a lot of unofficial information (rumors). Unfortunately, the message of all these rumors is the same: the working group is badly behind schedule and has not agreed on the most critical issues. If this is the case, it is unfortunate but not so surprising. The differences of opinion between those who emphasize responsibility and those who emphasize business are reasonably significant. However, the result should be a compromise in which a balance is found between these two crucial issues. Without a balanced solution, the new system becomes unusable.

As I already stated, the working group’s schedule problems are just rumors, about which we will get more information in early March, when the working group must be given more work time if the rumors are true. If the rumors are false, the working group will complete its work, and the process will proceed according to schedule. A steering group has also been set up for the working group’s work, which should provide political guidance for the planning. The political goal set by the Finnish government is to create a gambling system, thanks to which the degree of channelization of the system increases significantly, but in such a way that gambling problems do not increase but decrease. The steering group must ensure that the proposed legislation fulfills this goal. Ultimately, however, the Finnish government must decide whether the legislation is such that it can be submitted to a public hearing process. After that, it will be sent to the EU notification process and finally given to the parliament for a decision.

If the rumors about the working group’s major scheduling problems are true, then there is a high risk that the practical implementation of the new gambling system will be moved to the beginning of 2027. At the moment, however, the official goal is to get the system into effect by January 1, 2026, at the latest.

Since no preliminary information has been received about the working group’s work, we still do not know the details of the legislation. Based on the official schedule, the assumption is that the details will be precise by the beginning of June. Here, I present my guesses and opinions on the most significant issues. When the legislation is published, I promise to go through my guesses and find out how wrong I was once again.

License-based products: online casino and sports and horse betting in both sales channels. The government program states that at least online casino games and digital betting will be transferred to the license system. I believe that all sports and horse games will be moved to the license side. In terms of the system’s functionality, the license must entitle the games to be operated in both the digital and retail channels.

License: Separate licenses for casino games and betting (includes both fixed odds and pool-based sports and horse betting), license price around 50 000 euros. I support a system where one license could be used to operate all games belonging to the license-based system.

Tax rate: 20 – 25% of GGR. I would make a system where the tax rate would vary depending on how dangerous games are from a gambling problem point of view the games are. With this logic, online casino games would have the highest tax rate, fixed-odds betting would have a slightly lower tax rate, and pool-based sports and horse games would have the lowest tax rate.

Marketing: Only brand marketing (company & products) is allowed; on radio, TV, and other live-streaming channels, it will be possible to advertise casino games for a limited time; there will be strict restrictions on bonuses; affiliate activities are restricted; sports sponsorship is allowed, but visibility aimed at children and young people should be minimized.

Betting limits: A company-specific deposit limit initially applies to casino games if Finland has separate casino and betting licenses. The deposit limit will also apply to betting products if Finland has one license that covers all license-based gambling. If this happens, customers can apply for a higher deposit limit based on their income or other assets. In the coming years, the company-specific deposit limit may be replaced by a customer-specific limit when the regulatory system will be able to monitor this. I think that a deposit limit is better than a betting or loss limit.

Self-exclusion system: Finland will have a system where customers can prevent all gambling activities for themselves. The system will be similar to the Swedish Spelpaus.

B2B license: The B2B license will not be implemented from the beginning of the system change. Instead, technology and game suppliers are set certificate requirements that they must meet. The B2B license can be introduced sometime later if, for example, Sweden’s experiences show that it is a good solution.

Cooling-off: There is a risk of having a cooling-off period in Finland. Since the entry into force of the practical level of the gambling system seems to be moved to the beginning of 2027, the risk of using the cooling-off period has increased somewhat. The state-owned monopoly operator Veikkaus appears to support the cooling-off, and politicians are used to listening to Veikkaus’ opinion. Cooling-off would require a new regulation, which might be why not to have a cooling-off.

Supervision & regulation: A new supervisory authority will be established in Finland. It is not sure if the new regulator would continue under the Ministry of Interior control or if it would move, for example, to the Ministry of Finance. A new technological system and plenty of new officials are needed for regulation. The new regulator must be able to intervene more strictly than the current one in gambling activities without a Finnish license.

Finnish Online Gambling License Process Begins

I haven’t added text to the Gambling Guru blog for a long time, but I have written thoughts about the change in the Finnish gambling system on Finnplay’s website. This and the following three other texts were published between December 2023 and July 2024.

Why does Finland want to change the gambling system?

The Finnish state-owned company Veikkaus currently has a monopoly on all gambling in Finland. Veikkaus’ product range includes lottery games, betting (both sports and horses), and casino games in retail and digital channels. However, Veikkaus’ monopoly is realized in practice only in the retail channel, where no other gambling companies exist. On the other hand, Veikkaus faces tough competition in digital channels from offshore operators. Because of this, Veikkaus’ market share of all digital gambling is around 50 %. In online casino games, offshore companies control about 2/3 of the market, and in fixed-odds betting, the share of foreign companies is already 90 %.

Veikkaus’ weak revenue development and collapsed market share are why the Finnish government has decided to reform its gambling system and move from a monopoly to a partial license-based model. In fact, the biggest driver for the progress of the change was Veikkaus’ announcement, in which the company said it wanted to give up its monopoly position in the area of digital casino and sports betting.

At the beginning of 2023, the Finnish government appointed an investigation group to analyze possible changes to our gambling system. The investigation resulted in two alternative models, one of which was an increasingly strict monopoly system, as has been done in Norway. However, the primary model ended up being a partial license-based system according to the Swedish and Danish models. Based on this, the new government that started in the summer recorded its government program as the goal of moving to a partial license-based gambling system by the beginning of 2026. The government program states that betting on digital channels and online casino games would be transferred to the license-based system.

The details will be worked out in the preparatory work

Unfortunately, the Finnish government had more important tasks than gambling matters in the summer and early autumn, so the official preparation work of the gambling system was only started at the end of October when a working group and a steering group were appointed. The starting point for the preparatory work is the approximately one-page entry on gambling matters in the government program. The target schedule is still by the government program; the new system should be valid from the beginning of 2026. Due to the delayed start and the significant content of the change, the schedule looks pretty tight.

All the details of the future legislation are still open, so nothing has been decided so far. Even the big questions, such as the division of product groups between monopoly and license systems and the division of different sales channels, are still open. In this situation, there is no information about even more detailed questions. However, due to the tight preparation schedule, information is expected to start coming in during the winter, as the first version of the law must be ready by March 2024.

The lobbying to influence the content of the future legislation will, therefore, take place during the next three months. In principle, you can try to influence the content of the legislation until the parliament has approved the new Lottery Act. In practice, however, it is difficult to influence the details during the public hearing round, the EU notification process, and the parliamentary hearing. In those stages, the focus is usually on the legal aspects of the legislation. If the schedule plans come true, the parliament will take up the official bill in the spring of 2025 and approve it by the end of 2025.

In the last week of November, the Ministry of the Interior, which is in charge of the legislative project, organized a hearing that lasted all day, where the different parties could present their views on the most critical issues of the reform. All the most significant parties were present, among whom was Finnplay’s CEO, Jaakko Soininen. I also had the honor of presenting my views there. Based on the event, I can say that, at this stage, there is no unified vision about anything. Only the strict schedule did not lead to a disagreement, but the conclusions were different in that matter as well. Others would want more preparation time, but others do not want to postpone the legislation’s entry into force.

The unfortunate fact is that the planned schedule is really tight. The working group has only four months to complete the content of the law. After the three-month opinion/hearing round, the law must be sent for EU notification, which takes 3 to 4 months and should be ready by the end of 2024, according to the plans. After this, a few more months will be needed to prepare an official bill for the parliament, ideally completed in February 2025. It is a large package of laws, which will take at least six months to process in the parliament, possibly more. I believe that the parliament will approve the new law in 2025. Still, it does not necessarily mean that the license-based system will be implemented immediately from the beginning of 2026. The changes in supervision (new regulator and technology) and the granting of licenses take time, which may postpone the practical start.

With the help of the future gambling system, the aim is to raise the channelization rate of Finnish gambling as high as possible. In principle, the target level should be 100 %, which means that all gambling should take place in Finland within the framework of the legal system. In practice, however, the system has been highly successful if the channelization rate can be raised close to 90 %. When almost all gambling takes place within the framework of the system, then responsibility measures aimed at preventing gambling problems can also have an impact.

The degree of channelization can only be increased in a situation where gambling companies have an interest in applying for a Finnish license. The generation of interest is particularly affected by the level of taxation, the strictness of marketing regulation, the limits on gambling, and any product restrictions. As I already stated, at this stage, it is still too early to speculate on what the restrictions will be. I will return to these issues in my future blogs once we have more information on the system details.

I believe gambling companies will apply for a Finnish license if they feel they can do profitable business in Finland. In addition, one significant factor is probably the extent of the bureaucracy and, in general, the ease/difficulty of working with the regulator. Many minor issues exist, such as a possible cooling-off period and technology requirements (e.g., certificates and B2B licenses). I will return to these details during the winter and spring.

It’s time to move from product-based to customer-based thinking

I have written this column for http://www.lotterydaily.com, and Ted Menmuir has edited it. This was, at least for now, the last column I wrote for Lottery Daily.

As lottery operators move to expand their product offerings, Lottery Daily’s Jari Vähänen identifies that too many businesses are stuck on a legacy approach when evaluating their product offerings and customer impacts.

Gambling companies, including lotteries, have traditionally been built based on their specific product groups. The reason for this is the gambling companies’ origins and background, which usually focuses on a particular product area.

As such, lotteries began with the sale of lottery draws, casinos with their games, and horse and sports betting companies with wagering markets. However, over the years, most operators have diversified their operations to other areas to enlarge their business units – hence a product-based organization almost automatically leads to product-based decision-making, which does not produce optimal results for gambling operators.

We often hear gambling companies announce that they are utilizing a ‘customer-based strategy’. In my previous company, Veikkaus, we launched a customer-based business strategy almost twenty years ago, in 2004 – in retrospect, it wasn’t a real customer-oriented strategy, even though we were very serious about it.

The problem then was the inability to adapt to a new way of thinking. Our internal approach emphasized that customer orientation carried a lot of weight, but in reality, the measurement and the control of operations were ultimately still based on the products.

As a business consultant, I have observed several companies’ operations from the sidelines for a few years now. Unfortunately, many seem to be in the same situation as Veikkaus was decades ago. There is a lot of talk about customers, and the aim is to use customer data in all decision-making processes. Yet, in reality, they remain quite far from developing their desired real customer-oriented solutions.

It’s easy to notice, for example, by reading annual reports of lottery operators, in which the reporting continues to be based on sales and GGR of individual products.

When applied, product-based thinking and management can lead to partial optimization, which naturally does not produce optimal results. Worse still goals can be based on product areas or even individual products that generate wrong business decisions that can go unnoticed.

For example, many gambling companies end their customer relationships with winning sports bettors, even though, in some cases, those same customers lose money in other product areas. A customer can be productive for the business. Still, for the manager responsible for betting, the same customer can produce a loss and be defined as a risk regardless of his overall qualities.

These types of negative decisions will cause a decrease in income for the entire company, yet it appears that no one cares about it due to the absence of total customership.

The dominance of online gambling and its compliance duties should see operators have sufficient customer data; thus, a better understanding of customers should be achievable. In addition, several gambling companies have also acquired the necessary resources for processing customer data, but this is not enough if there is no understanding involved in processing customer data.

Customer planning must start from a business case based on the overall data feedback, on which a practical objective and goal setting must be assigned. Of importance, employees do well in what they are rewarded for. Because of this, partial optimization is still far too common.

With the help of management decisions based on customer data, results should outperform standard business practices and improve customer care. These improved outcomes are based on customer-specific offerings, which increase sales and improve customer satisfaction.

In a well-functioning model, the customer does not feel he is faced with sales measures but receives better personal service. With the help of customer data, it is possible to identify players suffering from gambling problems and those who seem to be at risk of getting into harms – and of course, sales and marketing measures should never be aimed at these problematic customer groups.

Lotteries are usually based on lotto games and scratch cards, both of which have a high rate of return. For a long time, the payout percentages of lotto games were around 40%, and they are still around 50-60%.

In a product-based business model, this can lead to the idea that players of other product groups are recognized as worse customers since payout rates of sports and casino games are now more than 90%

However, this kind of thinking causes lotteries to make wrong business decisions, which should be eliminated using customer data.

Lotteries should use a model based on customer data, in which customers are separated into groups according to which product they play the most.

Customer segmentation is therefore based on the primary game product that could be considered the main reason to be a customer. Based on such a straightforward division, it is easy to notice the shortcomings and errors of traditional product-oriented thinking.

The information I have received from lotteries offering multiple products expresses that the value of customers who mainly play betting is many times higher than those who play lotto games as their primary product.

This dynamic should be accounted for when comparing the importance of lotto games and betting products in traditional product-based thinking. Lottery games generate more money for lotteries than compared to sports games. With this kind of thinking, you can end up with a solution where you don’t invest and develop betting products because they generate just a small profit.

The worst scenario is that your solution transfers profitable players to your competition… I can’t tell the concrete figures of any lottery, but I dare to give one example because the information is already so old.

Fifteen years ago, Veikkaus ran two large pool-based horse betting products in Finland. At the same time, Fintoto, a company focused on horse betting, wanted those games. The decision-makers wondered why Veikkaus opposed that move, even though Veikkaus’ annual profit from horse betting was around 10 million euros, only about 1% of the company’s profit.

At that time, we already had customer data available. We noticed that the total revenue for Veikkaus from customers who primarily play horse betting was 6–7 times bigger than the money collected from horse betting alone. We were afraid of losing the customers who were valuable to us.

This granular understanding is available to all gambling companies with modern data systems, so use them to develop your overall business, as benefits are tangible and long-standing.