end of the road for the gaming monopoly?

Transcription

END OF THE ROAD FOR
THE GAMING MONOPOLY?
– a report on future gaming policy
GAMING REPORT 2014
2
Betsson/Gaming Report 2014
CONTENTS
FOREWORD
Magnus Silfverberg, CEO & President, Betsson Group
........................................................
4
CHAPTER 1:
Facts and history concerning the European gaming market. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
1.1 The history of the Norwegian gaming market.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
1.2 The Norwegian gaming market.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
"Gaming Policy in Norway and Europe",
Contribution from Reidar Nordby Jr, Former CEO of Norsk Tipping AS
and previously President of the World Lottery Association . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
1.3 The Current gaming market. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
CHAPTER 2:
Norwegian gaming policy.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
2.1 The Norwegian gaming monopoly.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
2.2 The marketing prohibition.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
2.3 Financing of good causes from gaming funds. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
2.4 A gaming market in flux. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
20
21
23
24
25
CHAPTER 3:
Gaming regulations in Europe. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
3.1 Developments in Europe.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
3.2 What is a licensing system?.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30
3.3 Tax schemes.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30
3.4 How do different countries operate their licensing systems?. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
3.5 Deregulation of Danish gaming policy. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
"Danish sport benefits from the licence scheme",
Interview with the Chairman of the National Olympic Committee and Sports Confederation
of Denmark (DIF) Niels Nygaard. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
"Time for new gaming regime",
Contribution from Joakim Marstrander, lawyer and partner at Deloitte Advokatfirma. . . . . . . 41
CHAPTER 4:
How can we prevent gambling addiction?. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
4.1 What is gambling addiction?. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
4.2 Experiences from other countries with licensing systems. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
4.3 Managing gambling addiction under a licensing system. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
42
43
46
47
CHAPTER 5:
Norway's last monopoly?. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50
5.1 Globalisation changing society. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51
Betsson's recommendation for the Norwegian authorities,
Contribution from Kim Rud Petersen, spokesperson for the Betsson Group in Norway.. . . . . . . 54
3
FOREWORD
4
Betsson welcomes the review, and
believes the introduction of a
licensing system would benefit the
Norwegian gaming market
Betsson is proud to publish the first Norwegian gaming report
focusing on the Norwegian and European gaming market. The
report is intended to inform public authorities, politicians
and other stakeholders of the reasons for the current gaming
monopoly, of ongoing developments in Europe, and why we
believe the Norwegian gaming monopoly should be changed.
Following changes over the last few years, as much as onethird of online gaming in Norway takes place on the websites
of international gaming companies.
The government wishes to adapt to these developments, and
the government's political platform states that it will examine the issue of licensing systems for Norwegian and foreign
gaming companies. Betsson welcomes this review, and believes that the introduction of a licensing system would benefit
the Norwegian gaming market. We hope that this gaming
report will help to shape this process moving forward, at
the same time as helping to boost knowledge of the gaming
industry.
Betsson operates in more than 20 different countries, mainly
in Europe, many of whose markets have been subject to
re-regulation through national licensing systems. Most
countries whose markets have not yet been deregulated
have committed themselves to re-regulation. Consequently,
we have extensive and positive experiences of such processes
to draw on. The vast majority of these countries have introduced a licensing model that can be adopted by all gaming
companies and forms of gaming provided these satisfy the
licensing requirements. This has made the licensing systems
commercially viable for gaming providers. The right conditions will encourage most operators to apply for a licence, thus
ushering gaming towards the licensed section of the market,
including in Norway, in the process maximising state control.
However, if the industry is deregulated to too great an extent,
operators and players would not be covered by the licensing
system, which in turn would reduce state control of much
of the gaming market. Hence we would not be much further
forward at all. Therefore it is important that both authorities and the industry work together to establish an optimum
licensing system for all parties.
One important topic in the forthcoming review will be the
effect of deregulation on the extent of gambling addiction.
In this context we would like to emphasise that all reputable gaming companies are taking active measures to combat
gambling addiction. Betsson is constantly developing fair-play
measures in order to help counter gambling problems, money
laundering, bribery and similar. Betsson is a member of the
European Sports Security Association (ESSA), which works
closely with UEFA and FIFA to prevent match-fixing and corruption. We are going to much greater lengths than most of
our competitors – including the monopolies – in these areas,
because we believe that gambling problems are simply not
acceptable for anyone.
With almost 50 years' experience of the gaming industry,
including more than 15 years in the online sector, and with
licensing and operations in several other European countries,
Betsson is highly qualified to act as a sounding board for
the Norwegian authorities in this matter. We look forward to
a productive and constructive dialogue with the Norwegian
authorities, and hope you find this report informative and
interesting.
Magnus Silfverberg
CEO and President, Betsson Group
5
PHOTO: OSLO MUSEUM
1
6
FACTS AND HISTORY CONCERNING
THE NORWEGIAN GAMING MARKET
PHOTO: LEIF HØE
1.1 The history of the Norwegian gaming market
Despite being totally prohibited for
several centuries, gambling was nonetheless practised in unorganised form
the length and breadth of Norway
throughout this period. Consequently,
in the early 20th century the authorities
decided to introduce regulated forms
of gambling.
From protecting participants from gambling "the shirt off their backs", more
recently gaming legislation has focused on facilitating controlled forms
of gambling in order to prevent related undesirable social consequences.
Ensuring that funds are channelled
1
2
3
towards socially beneficial causes has
also been a primary consideration from
the outset.
Over the last ten years the Internet
has globalised gaming, and a number
of foreign companies have established
a strong foothold in the Norwegian market.3 The development and administration of today's gaming market cannot be
viewed independently of changes that
have occurred over the last century.
Consequently, in order to understand
the current situation, we first need to
take a look back in history.
Anyone making a living from
games of chance that are not
permitted by a particular Act,
or in connection therewith, can
be punished with imprisonment
of up to one year.
§298, General Civil Penal Code of 1902.
The Remote Gaming Report 2012, 2012. Report from the Norwegian Gaming and Foundation Authority
7
1931
1946
The first Norwegian
gaming machines
introduced by the
Norwegian Red Cross.
Norsk Tipping established.
Tender beginnings 1913–1940
Following the decision one year earlier
to allow all Norwegians to take part in
regulated gambling, the first "Norske
Pengelotteri" (national Norwegian lottery) draw was held in March 1913.4 5
From the start surpluses were distributed to socially beneficial causes,
for example, tuberculosis treatment.
A total of 60,000 tickets were sold,
where as today, the idea was to match
as many numbers as possible with those
drawn. One-third of the tickets were
sold over the counters of the national
lottery's offices in Oslo, and two-thirds
from other agents. With monthly draws,
the organised national lottery proved a
great success.
Over the next decade betting on horse
4
5
6
7
8
9
1 0
11
12
8
races was also legalised6, with the first
race being run on the opening of Bjerke
Racecourse on 28 June 1928. Here too
the focus was on socially beneficial causes, in that "Approval....(was) granted
to the organisations and companies that
have been approved by the relevant
department and whose object includes
supporting horse breeding". 7
Several years later, in 1937, Norway's
first gaming machines appeared in the
guise of "Payazzo" machines that used
five øre coins. The Norwegian Red Cross
was responsible for the around 1,800
machines that were located around
Norway.8
The post-war years: 1945–1970
English football was extremely popular
in Norway as long ago as the 1920s, and
Store Norske Leksikon, 2005-2007. Rolf Bryhn: http://snl.no/Det_norske_Pengelotteri
Act of 28 August 1992 no. 103 on Gaming: http://lovdata.no/dokument/NL/lov/1992-08-28-103
Act of 1 July 1927 no. 3 on gambling through tote or pari-mutuel games http://lovdata.no/dokument/NL/lov/1927-07-01-3
Act of 1 July 1927 no. 3 on gambling through tote or pari-mutuel games http://lovdata.no/dokument/NL/lov/1927-07-01-3
Game over for gaming machines, 2007. Kjell- Olav Hovde, Red Cross: http://www.rodekors.no/nyheter/
nyhetsarkiv/2007/juni/Game_over_for_automatene/
Norsk Tipping A/S 1948 - 1973: In the Service of Sport and Science, 1973. Nilsen and Moen. Norsk Tipping.
The History of Betting in Norway, Norsk Tipping: https://www.norsk-tipping.no/selskapet/om-norsk-tipping/historie
Store Norske Leksikon, 2005-2007: http://snl.no/bingo
1963
1965
Bingo extremely widespread
and popular in Norway by
the middle of the 1960s.12
1927
Betsson established.
1913
Legal horse racing
introduced via the
Norwegian Tote Act.
Norwegian National
Lottery draw in 1956
The Norwegian National
Lottery launches a lottery.
Aftenposten, 14 April
1913
many Norwegians placed illegal bets
on these games. While Sweden established an official gaming company in
1934, Norwegians had to wait until 24
October 1946 for the formation of Norsk
Tipping.9 The company was founded to
channel Norwegians' gaming inclinations towards moderate and responsible
products that did not create social problems.10 Naturally, this also significantly
reduced the scope of illegal gambling.
The first pools competition featured
twelve English games on 13 March
1948, and attracted stakes totalling
NOK 52,892.50. Regardless of where
participants lived, coupons had to be
posted by Tuesday or Wednesday to be
certain of reaching Norsk Tipping by the
time the football matches kicked off on
Saturday. In the first year of operation
total turnover amounted to NOK 18 million.11 All coupons were registered and
checked manually at Norsk Tipping's
head office in Oslo.
Betting on Saturday football matches
continued to gain popularity over the
next decades, establishing itself as a
phenomenon of Norwegian sport. Norsk
Tipping expanded significantly, chalking
up turnover of NOK 155 million in 1965.
The success of the football pools was
accompanied by establishment of bingo
as an extremely popular form of gambling and by the middle of the 1960s
bingo halls had sprung up all over
Norway.13
A number of private gaming companies
were set up abroad, including Betsson.
13
14
15
Betsson was born in 1963 when Bill
Lindwall and Rolf Lundstrom opened
their first casino in the Elegant Palace
Hotel in Gothenburg, under the name
AB Restaurang Rouletter.
"The first technological
revolution" – 1970–2000
Having triumphantly swept across the
rest of Europe, the first national Lotto
was launched in Norway in 1986. Here
for the first time the culture sector
also received funding from the surplus.
The Lotto draw has been a fixture of
Norwegian state television broadcasting
since 1987, which has only helped to
boost the game's popularity. In the first
year the top prize was NOK 500,000,
an amount that was doubled to NOK 1
million in 1988, a year in which Norsk
Tipping generated turnover of NOK 3
1994
1995
Flax scratch card game
introduced.
1993
Oddsen is launched on
1 February offering the
games Langoddsen,
Vinneroddsen and
Resultatoddsen.
1992
Norsk Tipping becomes a
state-owned limited
company. The joint Nordic
lotto game Viking Lotto
introduced.
1986
In 1995 Norsk Tipping AS
assumed responsibility for
operating Flax
Online games introduced at
agents.
1982
Lotto launched in Norway.
The Viking Lotto involves eight
nations
The Norwegian National Tote
foundation is established
following the merger of the
Norwegian Jockeys' Club and
the Norwegian Trotting
Association.
Online gaming was introduced at
agents in 1992.
billion.14 Norsk Tipping was affected
by a number of significant technological developments in the 1990s. Online
gaming was introduced at agents in
1992, allowing participants to hand in
coupons until just before the start of
games or lottery draws. New forms of
sports betting were introduced with the
launch of Oddsen on 1 February 1994,
and the Flax scratch cards that were
introduced with great success in 1995.
The last major development in the
1990s saw the launch of Norsk Tipping's
online information service. This offered daily updated information, including a results service and other news
for players and other stakeholders. This
boosted the availability of gambling.15
Store Norske Leksikon, 2005-2007: http://snl.no/bingo
Gambling and Gambling Problems in Norway, 2003. Lund and Nordlund, The Norwegian Institute for Alcohol and Drug Research.
9
The Norwegian Gaming and
Foundation Authority was
established on 1 January 2001.
Betsson entered the
Norwegian market in 2004.
1999
2001
2003
Norsk Tipping launches
online information service.
Norsk Tipping starts a trail
project for online games.
The Norwegian Gaming
Authority is established.
The Norwegian Parliament
(Storting) votes to give
Norsk Tipping sole rights to
operate gaming machines in
Norway. The operators who
missed out on these rights
maintained that the reform
was illegal, and brought the
case before the Supreme
Court and EFTA Court in
2006. Norsk Tipping won
the case, and the reform was
introduced in 2006.
Globalisation of the gaming
market 2000 onwards
Most Norwegian homes were connected
to the Internet by the 2000s, a development that exposed the Norwegian
gaming market to an international
landscape. In 2001 Norsk Tipping further ramped up its online operations
with the launch of a trial of its existing
games in an online format. After a oneyear trial, the scheme was introduced
on a permanent basis. The Gaming and
Foundation Authority was also established in order to secure better control of
the expanding market16
Turnover from gaming machines
peaked in 2003, when 219 private
companies with 18,500 machines posted
16
17
1 8
19
2 0
21
10
turnover of just under NOK 23 billion.17
After a lengthy political struggle, Norsk
Tipping became the sole operator of
gaming machines, on the condition that
it halved the number of machines. The
new reform went live in 2006.18
As long ago as 2001 the Norwegian
Ministry of Culture issued a report
entitled "Norwegian Gaming in a Digital
Future" This addressed competition
from abroad and the potential financial
and administrative repercussions of
developments on the Norwegian gaming
market.
2004 was the first year in which
foreign gaming companies seriously
began to challenge the Norwegian
2004
state-controlled
gaming
monopoly, having attracted an increasing number of Norwegians to set up
gaming accounts. The Swedish online
gaming company Betsson entered the
Norwegian market in 2004, offering
customers both traditional sports betting as well as casino and poker games.
While Norwegians could legally gamble
on foreign websites, the Norwegian
gaming monopoly's legislative framework imposed strict limitations
on companies' marketing activities
In Norway.
In the same year, Ladbrokes instigated
legal proceedings against the Norwegian
government, citing that Norway was
obliged under EU/EEA law to deregulate
Gambling in Norway 2003, 2003. Statistics on state-controlled gaming, private gaming and lottery, the Norwegian Gaming Authority
Norwegian Gaming in a Digital Future, 2001. Report prepared by expert group established by the Ministry of Culture.
Oslo District Court – TOSLO – 2004- 91873, The Remote Gaming Report 2012
Foreign gaming
companies launch
themselves wholeheartedly
on the Norwegian market to
challenge Norsk Tipping.
1996
Norwegian National Tote
granted licence for all horse
racing in Norway.
Lotteri- og
stiftelsestilsynet
the market and introduce a licensing
system for gambling. Ladbrokes lost
the case when in 2008 the court ruled
that the government had ensured that
Norwegian gaming legislation was based
on legitimate socio-political considerations.20 21 One of the main arguments for
the ruling was that Ladbrokes' games
were more aggressive than those offered by Norsk Tipping.
The Gaming Authority's calculations were based on the premise that
foreign gaming companies generated
turnover of around NOK 4 billion in
Norway in 2005, a figure that rose to
around NOK 6.3 billion in 2007.22 This
was a significant proportion of total
gaming revenues for the year of NOK
33.7 billion.
In an attempt to further regulate the
gaming market, a minimum age of 18
was introduced for all Norsk Tipping
games in 2011. Players were also given
the opportunity to set own maximum
limits for their gaming.
"The Remote Gaming Report 2012 highlighted that globalisation of the lottery
and gaming market was limiting the
Norwegian authorities' ability to manage
and control their own national gaming
market. In order to compete with the
new solutions abroad, Norsk Tipping
launched simplified payment solutions
and new variants of its games, including live odds and new types of lotto
games. Another significant measure was
introduced in January 2014, when Norsk
Tipping launched 65 new online casino
games in order to counter competition
2012
2014
Norsk Tipping introduces
online games (similar to
those of the foreign gaming
companies) in a number of
new categories including
Casino, Bingo and Flax
(scratch cards).
2011
Liveoddsen is launched,
allowing participants to
bet while games are in
progress.
2009
A more user-friendly
solution was introduced for
online gaming, with no
player card required.
2008
Launch of the Grass Roots
funding scheme.
2007
The new gaming machines,
Multix machines, launched.
In January 2014 Norsk
Tipping launched 65 new
online casino games.
Keno numbers game launched
featuring daily draws on
national TV station NRK.
With Liveoddsen players
can play in real time.
New forms of gaming appear,
and a new and powerful private
gaming sector has emerged.
These developments have
created problems concerning
national administration and
enforcement of national
gaming legislation. They have
also put pressure on the
traditional gaming market, and
reduced the opportunities for
individual countries to control
income from gambling
themselves.
The Remote Gaming Report 2012
2 2
Act relating to Amendments to the Gaming and Lottery Legislation, Proposition to the Odelsting no. 80 (2007-2008): http://www.regjeringen.no/nb/
dep/kud/dok/regpubl/otprp/2007-2008/otprp-nr-80-2007-2008-/3/1/2.html?id=526867
11
Percentage of turnover in the Norwegian
gaming market in 2013 by gaming area.
Bingo through
professional
organisers
Others regulated
by Norwegian law
4
10
Norwegian
National Tote
8
%
45
Norsk Tipping
33
Foreign
websites
1.2 The Norwegian gaming market
The Norwegian Gaming Authority splits
the gaming market into companies with
a Norwegian licence that are regulated
by Norwegian law and companies with
a non-Norwegian licence that are
regulated within the EU.
Turnover in the gaming
companies with a Norwegian
licence
In 2013 Norwegians spent a total of NOK
30.8 billion on gambling regulated by
2 3
2 4
2 5
12
Norwegian legislation. This is the gross
amount staked before deduction of any
winnings. Turnover increased by 7 per
cent compared with 2012.23
There was a significant reduction in
turnover from gaming in the period
2006–2008. This was a result of efforts
to reduce the use of gaming machines
in Norway. Norsk Tipping assumed sole
responsibility for gaming machines in
2006, and turnover rose again in 2008
following the introduction of Norsk
Annual Report 2013, 2013. The Norwegian Gaming and Foundation Authority
Annual and Social Report 2013, 2013. Norsk Tipping: http://2013.norsk-tipping.no/rapport/statistikk/
Tipping's gaming machines.24
Since 2001 Norsk Tipping and the
Norwegian National Tote have also given
their customers the opportunity to play
online. Norsk Tipping has significantly
expanded its games on digital platforms
in recent years, with growth of 25 per
cent from 2012– 2013.25 A further strong
increase is expected following the introduction of 65 new games in January
2014. In 2012 total Norsk Tipping and
Norwegian National Tote turnover on
digital platforms amounted to NOK 4.1
Turnover, games regulated by Norwegian law
2006–2013
Norsk Tipping and National Norwegian Tote
turnover on digital platforms 2008–2013
Norsk Tipping
Norwegian National Tote
Million
40 000
Million
4 000
35 000
3 500
30 000
3 000
25 000
2 500
20 000
2 000
15 000
1 500
10 000
1 000
5 000
500
0
2006
2007
2008
2009
2010
billion. Figures are not yet available for
the National Tote for 2013; however,
Norsk Tipping alone posted total turnover of NOK 3.56 billion.26
Turnover, gaming companies
without a Norwegian licence
The Norwegian Gaming Authority's
calculations are based on the premise
that Norwegians spent between NOK
11 billion–NOK 15 billion on gaming
on foreign websites in 2013.27 These
amounts are significantly lower than
26
2 7
2 8
29
2011
2012
2013
0
2008
2009
the figures of NOK 4 billion–NOK 7
billion seen in previous years.28 The
Norwegian Gaming Authority believes the change is attributable to
new and more detailed calculations,
rather to any increase in real terms.
However, what is clear is that around
33 per cent of all gaming turnover in
Norway was made on foreign websites
in 2013.
2010
2011
2012
2013
two foreign websites on which more
than 10 per cent of the respondents
had played. With a market share of 10
per cent, Betsson is one of the largest
and most high-profiled of the foreign
gaming companies operating in Norway,
and the company has several brands in
its portfolio.29
A survey carried out on behalf of the
Norwegian Gaming Authority revealed
Annual and Social Report 2013, 2013. Norsk Tipping: http://2013.norsk-tipping.no/rapport/statistikk/
Gambling in Norway 2007; 2008; 2009; 2010; 2011.
Statistics on Norwegian gambling and lottery, the Norwegian Gaming and Foundation Authority
13
GAMING POLICY IN NORWAY AND EUROPE
Reidar Nordby Jr. is the former CEO of Norsk Tipping AS and former President of the World Lottery Association
There was a good reason why the Norwegian General Civil Penal
Code from 1902 contained a paragraph prohibiting gambling in
Norway unless this was permitted in statute. At that time far too
many forestry smallholdings and farms had changed owners as a
result of poker games, something that had to be stopped.
A century later technology has effectively erased national boundaries and severely tested national and international legislation.
It is no longer possible – or desirable – to exclude nations from
e-commerce and information from flowing over national boundaries. And naturally, products that do not need to be physically
distributed are the most attractive to offer online. Gambling
belongs in this category.
At the same time the gaming monopolies, which have helped to
finance important socially beneficial causes for generations, have
been subject to increasingly stringent supervision and control
from national and international authorities. This has resulted in
an understandable reticence with regard to positioning and marketing, but also to a limited ability to innovate.
The technological, financial and institutional forces that have
played a key role in driving societal changes, have at the same
time tended to restrict innovation in the gaming sector to companies in the competitive market, away from the state-regulated
gaming market. In recent years international bookmakers have
launched much more advanced sports games offerings than the
state-controlled companies, and today also offer monetary prizes
for games of chance that have satisfied the expectations of the
vast majority of gamers. Businesses such as Richard Branson's
Virgin Group have embraced the market in imaginative ways,
while large media houses have thrown their full weight behind
the market. The latter's marketing is massive and likely to totally
eclipse that of the state-regulated companies.
14
How can we address these challenges? While it is naturally up
to politicians to decide, there is no escaping the fact there is
an imbalance in the market that is skewing competition. This has
arisen due to technological changes and diverse regulation regimes. If this imbalance is not addressed, innovation and thus public
appeal will continue to increase in the deregulated market, but dry
up in the state-regulated companies. This will be a result of both
externally- and self-imposed restrictions on innovation, marketing
and profiling in the monopolistic markets.
The objective must be to ensure that gaming continues to be
offered in a secure manner in future, but at the same time with an
innovative impetus that satisfies future gamers on their own terms,
and which ensures that national socially beneficial causes continue
to be allocated surpluses from gaming activities into the future.
Norway is currently being bombarded with marketing from international bookmakers through Norwegian TV channels abroad.
This is naturally something we need to address. One approach
could be the one adopted in Denmark and a number of other
European countries, which have allowed the licensing system at
the same time as tightening controls of licensees. Another way
would be to continue to try and combat these changes, though
this would arguably be simply chasing shadows. In the last reckoning it will be the players who decide, and future gamers have
already embraced a digital world that is here to stay. Players will
be attracted to providers with the ability to innovate, who are
exciting and offer competitive terms. Norsk Tipping is one of the
organisations that has shown that the gaming industry can be
regulated using available technology in a way that does not lead
to gambling addiction or offer games to minors, but rather to the
delight of many sections of the population. We do not wish to
return to the time of the introduction of the General Civil Penal
Code in 1902, but to a time of excitement, entertainment and fun!
1.3 The current gaming market
Norsk Tipping remains Norway's largest
gaming company, but is facing tougher
competition from international online
gaming companies. Here the greatest
challengers are clearly the listed
Swedish gaming companies, Betsson
AB and Unibet.
Norsk Tipping has been responsible for
efficient distribution of the surplus to
various socially beneficial causes for
several decades and has also generated an important source of financing
for Norwegian sport.30 The globalisation
of the gaming market in recent years
has resulted in Norsk Tipping adopting
a sharper focus on its online offering
in recent years – from the introduction
of online versions of traditional Norsk
Tipping and Norwegian National Tote
games in 200231, to Norsk Tipping's
major new initiative in January 2014
which saw the launch of 65 games in
four categories: online casino, online
scratch cards and entertainment
games.32
On the following pages we take a look
at various games currently offered by
Norsk Tipping and foreign companies,
including Betsson.
"We were mandated by the
Ministry of Culture to develop
an online gaming offering that
would help to ensure that
Norwegian players use a secure
and regulated gaming offering
subject to official controls. We
were thus mandated to offer
games at least as exciting as
games from our foreign
competitors, but in a way that
minimises the risk of gambling
addiction, and which
additionally ensures that
surpluses are reinvested in
socially beneficial causes.
CEO Norsk Tipping, Torbjørn Almlid
3 0
31
3 2
Gambling in Norway 2012, 2012. Statistics on Norwegian gambling and lottery, the Norwegian Gaming and Foundation Authority
”Major focus on Online Gaming, 2014.” Jødahl, Norsk Tipping: https://www.norsk-tipping.no/selskapet/vi-satser-stort-p%C3%A5-nettspill
15
THE THREE LARGEST GAMING COMPANIES IN NORWAY
NORSK TIPPING:
A state-controlled limited company reporting to the Ministry of Culture
Started in 1946
Has a monopoly in the Norwegian gaming market
In recent years has focused more strongly on digital platforms
BETSSON GROUP:
Started in 1963 in Sweden. The company is now licensed in Malta and headquartered in Stockholm
The bulk of the company's customers are in Northern Europe
Most important brands: Betsson, Betsafe, NordicBet, CasinoEuro and Norges Automaten
Listed on the Stockholm Stock Exchange NASDAQ OMX Nordic Mid Cap List
Member of the European Sports Security Association (ESSA) and BOS (Industry Association for online gaming)
UNIBET GROUP PLC:
Started in 1997, and registered in Malta
Most important brands Unibet and Maria Bingo
Claims to have 8.9 million customers in the European market
Listed on the Stockholm Stock Exchange NASDAQ OMX Nordic Mid Cap List
Member of the European Gaming and Betting Association (EGBA)
16
DIFFERENT VARIANTS OF GAMES OFFERED TODAY
Casino
The online casino variants comprise
several types of online gaming machines. These include Black Jack, Roulette
and traditional, more visual, gaming
machines. Similar games can be found
live and online in casinos all over the
world.
Norsk Tipping: Roulette
Betsson: Roulette
Betsson: Treasure Island
Norsk Tipping: Pirates of the Caribbean (Død
Manns Kiste)
Betsson: Secret of the Stone
Norsk Tipping: Simsalaspinn
17
DIFFERENT VARIANTS OF GAMES CURRENTLY OFFERED CONTD.
Sports betting
There are several types of sports
participants can bet on in the sports
betting genre. The most common form
is betting on games at fixed odds. If
the result of a game has odds of 1.5,
then players will receive 1.5 times
the amount they bet if this result is
achieved. Players can bet on one or
several games, on the full-time and halftime result, first goal scorer etc. There
is normally an upper limit on how much
players can bet on a match.
Norsk Tipping
Betsson
Lotteries/Flax scratchcards
Both Norsk Tipping and Betsson offer
online lotteries and scratch cards.
These are categorised as games of
chance
Norsk Tipping: The Gold Rush
Betsson: Golden Fortune
Other types of game: Online
poker
Here participants play against other
people in actual tournaments and
games.
Betsson: Online poker
18
Norsk Tipping does not currently
offer online poker, in contrast to the
state-operated gaming companies
in Norway's neighbours Sweden and
Denmark. As participants play against
other people, the gaming companies
only receive a small part of the stake
played for.
John Arne Riise is a
Norwegian footballer and
Betsson ambassador.
19
2
20
NORWEGIAN GAMING POLICY
2.1 The Norwegian gaming monopoly
Norwegian gaming policy is a constant
topic of debate, and gaming policy in
Norway's neighbouring countries is also
currently in a state of major flux. This
section examines the current status
of the Norwegian gaming monopoly,
the marketing ban and the financing of
good causes from gaming proceeds.
While socio-political considerations are
guiding for Norwegian gaming policy,
high priority is also attached to control
and prevention of gambling addiction.
The current legislation also secures
income for sporting, cultural and other
socially beneficial causes.33
Gambling is essentially prohibited in
Norway, although some individual
exceptions are permitted under current
legislation. The Act on Tote Business
(betting on horses), the Norwegian
Gaming Act and the Norwegian Lottery
Act regulate the legal exceptions for
gaming.34
The Lottery Act is the general act
covering different forms of gambling
including games of chance, gaming
3 3
3 4
3 5
3 6
machines and lotteries. The Act is
intended to ensure that lotteries remain
in regulated forms and under public
control35. However, in practice the most
important laws are the Gaming Act and
the Tote Act.
The Gaming Act confers Norsk Tipping
with the sole right to offer gambling in
Norway. Norsk Tipping offers gambling
within responsible frameworks through
the state gaming monopoly, and also
distributes as much of the surplus as
possible to good causes36.
The third legal exception concerning
gambling in Norway relates to horse
racing. The Tote Act gives the
Norwegian National Tote a monopoly
on operating legal betting on horses.
Proposition to the Storting 1 S 2013-2014, Regjeringen: http://www.statsbudsjettet.no/Statsbudsjettet-2014/Dokumenter1/Fagdepartementenes-proposisjoner/
Kulturdepartementet-KD/Prop-1-S/Del-1-Innledning/5-Fordeling-av-spilleoverskuddet/
Regulatory frameworks, the Norwegian Gaming and Foundation Authority: https://lottstift.no/lotteritilsynet/nb/om-lotteritilsynet/lov-og-regelverk-2/
The Norwegian Act on Lotteries etc., Lovdata: http://lovdata.no/dokument/NL/lov/1995-02-24-11
The Norwegian Act on Gaming etc. Lovdata: http://lovdata.no/dokument/NL/lov/1992-08-28-103
21
CURRENT PLAYERS IN TODAY'S GAMING MONOPOLY37
THE NORWEGIAN GAMING AND
FOUNDATION AUTHORITY:
State supervisory body for
administration and control of private
lotteries and state-controlled games
Ongoing control and supervisory
work
Responsible for the VAT
compensation scheme and for control
and monitoring of the grassroots
funding scheme.
37
22
NORSK TIPPING:
Monopoly on operation of gambling
within responsible frameworks
Owner of Norsk Tipping
Decides which games are offered
Shall secure sound and efficient
operations in order to ensure that
surpluses are ploughed back into
good causes to the greatest extent
possible.
Runs the Extra game on behalf of
the Extra Foundation for Health and
Rehabilitation, which is also
responsible for allocation of funds
About Norsk Tipping, Norsk Tipping: https://www.norsk-tipping.no/selskapet/om-norsk-tipping/vaar-rolle-i-samfunnet
MINISTRY OF CULTURE:
Establishes game rules
Manages distribution of the
company's surplus
Norsk Tipping's commercial
featuring the fictitious Tufte IL
team spawned a spin-off reality
series on the football team that
was broadcast on TV Norge in
2005.
THE NORWEGIAN ACT ON LOTTERIES ETC. (THE LOTTERY ACT) § 11:
With the exception of lotteries mentioned in § 7, marketing or promotion of
lotteries not permitted under § 6 second para is prohibited. Promotion of
unlicensed lotteries includes processing payments of stakes and winnings in such
lotteries. The King (the government) can establish further terms concerning the
scope and implementation of the prohibition on payment systems.
2.2 Marketing prohibition
Marketing of any form of lottery or
gaming is not currently permitted in
Norway. The legislative framework
therefore allows the monopolist
Norsk Tipping to market its games,
and the company has been one of
Norway's largest advertisers in terms
of advertisement placements for many
years. The company has won a number
of advertising awards and earned the
right to be regarded as a major player
within Norwegian marketing.
In addition to traditional advertising,
Norsk Tipping and the National
Norwegian Tote are marketed via
dedicated programmes on prime time
national TV, including the Lotto draw,
and in stores through agents. The
company has previously been criticised
for its major marketing initiatives,
3 8
39
including for (a) using marketing of
a nature that could lead to gambling
addiction38 and (b) inadequately
communicating the actual chances of
winning39.
Despite the fact the marketing ban is
actually intended to cover all gambling
not permitted by the Norwegian
authorities, Norwegian consumers are
nonetheless exposed to advertising
from international gaming companies
– on both commercial Norwegian TV
stations that broadcast from abroad,
and on foreign websites. TV stations
such as TV3, Viasat4, MTV, FEM, MAX,
VOX, Discovery Channel and National
Geographic Channel are subject to the
regulatory framework in the country
they broadcast from and are therefore
not covered by Norwegian legislation.
The same regulatory framework
applies to foreign websites. However,
this does not change the fact that the
marketing is in the Norwegian language
and is evidently aimed at Norwegian
consumers.
In reality the emergence of satellite TV
and the Internet makes it impossible
for Norwegian authorities to impose
the ban. As a result, consumers
are being increasingly exposed to
advertising from both Norsk Tipping/the
Norwegian National Tote and unlicensed
companies. Thus we see yet another
example of a regulatory framework
that is easy to circumvent in the current
globalised world, making it easy for
unlicensed companies to advertise –
including in Norway.
Norsk Tipping creating major gambling problems, 2012, Hansen, HegnarOnline: http://www.hegnar.no/okonomi/politikk/article693969.ece
Norsk Tipping's advertising verges on misleading, 2012, Hansen, HegnarOnline: http://www.hegnar.no/okonomi/article674486.ece
23
THE GRASS ROOTS FUNDING SCHEME
The grassroots funding scheme, which
is part of the total gaming funds, allows
Norsk Tipping players to have a say in
determining the recipients of Norsk
Tipping's surplus. 46 The Ministry of Culture
ultimately determines who can receive
grassroots funding, where all teams and
associations registered in the Register of
Non-Profit Organizations are approved as
potential recipients of these funds. In 2013,
NOK 339 million was generated from the
grass roots scheme, distributed to more
than 20,000 associations. 47 An extremely
wide range of teams and organisations
have received grants under the scheme.
One of the recipients in 2013 was Vennesla
Minibyggere, which received NOK 3,600.
This is a group that meets to construct
models of older buildings of historical
interest. Other recipients include the
Romany National Association of Norway,
the Norwegian German Shepherd Club,
Skjeberg Beer Appreciation Society,
Friends of Traditional Dance and Vestfold
Elk hound Club. Vålerenga Football Club
received the largest amount in 2013. 48
2.3 Financing of good causes from gaming funds
Gaming funds
The "Act on Betting in connection with
Sporting Events" was passed in 1946.
This decreed that Norsk Tipping's surplus should be distributed directly to
Norwegian sport and scientific research.40 Today gaming funds continue
to be distributed to sport, culture and
socially beneficial and humanitarian
organisations. Recent years have seen
an increase in the share of the surplus
earmarked for sport, with 56 per cent
being allocated in 2014. In 2014, a total
of NOK 1,859,704,000 of the gaming
funds will be distributed to sport. This
amount will be split between six items,
including operation of the Elite Sports
Centre in Oslo and other central sports
organisations, and construction of facilities. 41
The gaming funds have aided the construction of thousands of sports facilities across Norway, and have made a
vital contribution to the development
of Norway as a sporting nation. More
and better sports facilities are allowing
more people to participate in sport, but
also presenting many clubs with difficulties in financing the maintenance
of these facilities. This maintenance
backlog highlights the need for greater
funding for sport, and this report will
look at further alternative financing
methods that could help to strengthen
sport's finances.
Maintenance backlog for
buildings and sports facilities
While the gaming funds have financed
many sports facilities, the funds have
not always been sufficient to cover operation of these facilities. A significant
maintenance backlog has arisen for
buildings and sports facilities, which
is preventing more people from taking
part in sport. Between 2005 and 2012
gaming funds increased by NOK 191
million. In the same period the backlog
for buildings and facilities rose by NOK
866 million, from NOK 1.358 billion to
NOK 2.224 billion.42 The increase in
the backlog for buildings and facilities
is thus rising 4.5 times as quickly as
the allocated gaming funds. From 2012
to 2013 alone, the backlog in Norway
increased by as much as NOK 98 million.
Several key sporting organisations have
pointed out that they are facing major
challenges with regard to this backlog,
and have requested higher funding from
the public authorities. In Akershus the
backlog amounts to NOK 189.6 million,
which equates to three years' grants
for buildings and sports facilities.43
The Norwegian Sporting Associations
Umbrella Organisation has also expressed its concern at the inadequate
financing of sports facilities, which has
meant that some towns and cities have
been unable to offer sporting opportunities to all interested children and
young people due to lack of places44
In its annual report for 2012, the
Norwegian Olympic and Paralympic
Committee and Confederation of Sports
discusses its finances based on its
annual financial statements for 2011.45
Here it is quite clear that – at just 10.5
per cent – gaming funds account for a
0 Report to the Storting (2011–2012). "The Norwegian Sports Model. Regjeringen.no.
4
22 April 2014 from www.regjeringen.no/nb/dep/kud/dok/regpubl/stmeld/2011-2012/meld-st-26-20112012/5.html?id=684389
41
www.regjeringen.no/upload/KUD/Idrett/Spillemidler/PRM-34-14_Fordeling_av_spillemidler-Hovedfordelingen_2014.pdf
4 2
Norwegian Olympic and Paralympic Committee and Confederation of Sports (NIF) (3 May 2013). "Gaming funds applications – development of backlog of facility financing". Memorandum:
Norwegian Olympic and Paralympic Committee and Confederation of Sports 03.05.2013: http://www.idrett.no/krets/akershus/tilskudd/
Documents/notat%20til%20blogg.pdf
43
Oda Marie Often. "Backlog". Akershus Sports Association: http://www.idrett.no/krets/akershus/nyhetsbrev/Sider/Etterslep.aspx
4 4
Nettavisen (2014). "Donates NOK 3 billion to sport and NOK 12 billion to culture":
4 5
Norwegian Olympic and Paralympic Committee and Confederation of Sports (2013). Annual report 2012: http://www.idrett.no/omnif/Documents/aarsrapport%20NIF%202012.pdf
46
Norsk Tipping. "About the grass roots funding scheme". 22 April 2014 https://www.norsk-tipping.no/grasrotandelen/om-grasrotandelen
47www.norsk-tipping.no/grasrotandelen/hvem-fikk-fra-grasrotandelen
4 8
Norsk Tipping (2013). "Who received grassroots funding". 22 April 2014 https://www.norsk-tipping.no/grasrotandelen/hvem-fikk-fra-grasrotandelen
24
Norsk Tipping's surplus will be allocated in the following way in 2014:
Socially beneficial and
humanitarian causes
18
%
56
Sporting
causes
26
Cultural
causes
relatively small share of the confederation's total income.
The general manager of Frederikstad
Sports Council, Svein Femtehjell, is
one of those to have questioned the
way in which the sport is financed. In
an article in the newspaper Aftenposten
he explains how the increase in funding
formula would not result in any real
improvements.49 He describes sport
as an increasingly divided institution,
where top-heavy central organisations
support a funding formula that acts
more as a straitjacket for amateur sport
than anything else. He also points out
that in 2012 a total of NOK 900 million was distributed to local sport
from gaming funds. This was used to
fund facilities and activities, while the
remaining funds were applied centrally.
Models for increased financing
of sport
Various models have been proposed to
clear the backlog and increase general
funding for Norwegian sport. A number
of different solutions have been discussed in recent years, which can be split
into three main models.
49
5 0
51
Increase in the funding formula:
One way to boost funds for sport would
be to increase the percentage of the
funding formula allocated to sport.
However, even though this funding formula has been increased to 64 per cent
for 2015, as previously discussed, this
will still not be sufficient to clear the
maintenance backlog for sports buildings and facilities.
Incorporating sport in the national
budget:
Many sports organisations have proposed that sports financing should be the
state's concern, i.e. that sport should
be financed through the national budget. Culture is guaranteed 1 per cent of
the national budget, which in real terms
amounts to around NOK 10 billion. A
similar solution could also be adopted
for sport. The Football Association of
Norway has resolved to target 0.5 per
cent for the sport from the national
budget, a change that would see its
funds double.50 On the other hand, this
would oblige the state to find around
NOK 5 billion in the national budget,
funds that would have to be sourced
ahead of other political priorities.
Licensing system:
The Norwegian Gaming Authority's
annual report for 2013 states that
160,000 of 480,000 online players use
foreign gaming companies.51 The authority estimates that these players
spend around NOK 11 billion – NOK 15
billion with these companies. Under the
current gaming monopoly these funds
thus go directly to gaming companies
that are not subject to Norwegian tax
regulations. Under a licensing system
these companies would be subject to
Norwegian tax and National Insurance
regulations, and a significant amount
of this turnover could be channelled to
sport and the Norwegian government
through these levies. A licensing system would also facilitate sponsorship
agreements between gaming companies
and sports associations. These would
help to boost income levels, and could
increase allocations by involving more
gaming companies in the public-private
partnership.
Svein Femtehjell (2012). "Sport's straight jacket". Aftenposten Meninger:http://www.aftenposten.no/meninger/Idrettens-tvangstroye-7034708.html#.U0ZbS444WUk
Report on Annual General Meeting 2014, Waagard, Football Association of Norway (NFF): https://www.fotball.no/nff/NFF-nyheter/2014/Vedtak-fattet-av-forbundstinget/
The Norwegian Gaming Authority (2013). "Annual Report 2013»:https://lottstift.no/lotteritilsynet/files/2014/03/Aarsrmelding-2013-høg-oppl.pdf
25
"The Norwegian Players' Association (NISO) welcomes an
independent survey of different gaming models, along with
concerted initiatives to prevent gambling addiction. We believe it
could be beneficial to review and compare the strengths and
weaknesses of the existing model, with, for example, the Danish
gaming model, which allows foreign gaming companies to operate
under licence from the authorities. Advocating that the gaming
monopoly is the only alternative – without any real basis of
comparison – is naive.
Joachim Walltin, Chairman of the Norwegian Players' Association (NISO)
2.4 A gaming market in flux
The authorities, through Norsk Tipping,
have expressed a desire to regulate
and develop the gaming market in a
sound socio-political direction.52 There
is a broad political consensus that the
market needs to be regulated, a role
that has been performed by Norsk
Tipping for 60 years.
Norsk Tipping has served its purpose
for many years, and has ensured
proper allocation of its surpluses to
various socially beneficial causes such
as culture and sport. However, recent
years' technological developments
have demonstrated that foreign gaming
5 2
5 3
5 4
5 5
5 6
57
5 8
26
companies are acquiring increasingly
larger market shares, and that
globalisation of the lottery and gaming
market have reduced the authorities'
ability to manage and control the
national gambling market.53
The Gaming Authority has confirmed
that in 2013 Norwegians spent between
NOK 11 billion and NOK 15 billion on
foreign websites. 54 A steadily increasing
number of Norwegian players are being
attracted to foreign websites offering
games with better terms and wider
selections.55 Against this background, in
winter 2014 Norsk Tipping introduced
a range of casino games in order to
compete with international gaming
companies.
In autumn 2013 the Solberg government
announced that it wished to review
Norwegian gaming policy.56 In addition
to the review that the government has
notified in its political platform, EFTA's
supervisory body (ESA) has recently
questioned the criteria Norway can
adopt for private lotteries, as well as
whether lotteries can be offered under
the monopoly model. These are issues
that the Solberg government has stated
it wishes to clarify before a review of a
new gaming policy57
About Norsk Tipping, Norsk Tipping: https://www.norsk-tipping.no/selskapet/om-norsk-tipping/vaar-rolle-i-samfunnet
Regulation of Online Gambling, Norwegian Board of Technology's newsletter for Norwegian Parliament no. 14 April 2007. The Danish Board of Technology.
Political platform for a government coalition between the Norwegian Conservative Party and Norwegian Progress Party: http://www.hoyre.no/filestore/Filer/Politikkdokumenter/
plattform.pdf
Government cleans up lottery policy, 2014, Ministry of Culture: http://www.regjeringen.no/nb/dep/kud/pressesenter/pressemeldinger/2014/
regjeringen-rydder-opp-i-lotteripolitikk.html?id=751839
Political platform for a government coalition between the Norwegian Progress Party and Norwegian Progress Party: http://www.hoyre.no/filestore/Filer/Politikkdokumenter/
plattform.pdf
The decision on new gaming concepts will be taken by the
Norwegian Gaming Authority. The government wishes to
differentiate between addictive gambling and non-addictive lottery
concepts. It also wishes to support the establishment of more
non-addictive lottery concepts that could strengthen the voluntary
sector, provided that these do not challenge the EU exception
Norway has been granted its gaming monopoly. Priority will be
given to major humanitarian organisations.
The government will review the issue of a licensing system for
foreign gaming companies in order to establish whether it is
possible to combine socio-political considerations with increased
total revenues for the voluntary sector within the framework of the
EEA.
From the Solberg government's political platform58
27
3
28
GAMING REGULATIONS IN EUROPE
Many European countries have now replaced their gaming
monopolies with schemes allowing private gaming companies to
operate under licence, while other Nordic countries have retained
their gaming monopolies.
3.1 Developments in Europe
The last decade has seen major changes
in the way that gambling is regulated
in Europe.
Many European countries have now
replaced their gaming monopolies
with schemes allowing private gaming
companies to operate under licence,
while other Nordic countries have retained their gaming monopolies. In Eastern
Europe, Russia officially imposes a total
ban on gaming with the exception of
a few dedicated gaming zones, while
Serbia, Croatia and Moldova currently
do not impose any form of regulation
in this area.59
5 9
60
61
62
There are many reasons for the major
changes in the European gaming market
over the last year. One constant topic of
debate is the extent to which national
gaming monopolies are compatible with
applicable EU legislation. 60 In order to
address this matter, the EU Commission
has proposed overarching gaming policy
principles intended to bring national
regulations into line with EU legislation. The EU is also prioritising initiatives to combat gambling addiction and
match-fixing, along with administrative
routines for the industry and different
member countries.61 The EU regards
the gaming industry as one of the
fastest-growing industries in Europe,
and is therefore devoting increasingly
greater political attention to the industry. 62 Another contributory factor is the
technological developments that have
taken place over the last decade. These
have led to players increasingly migrating from agents towards online gaming
solutions, which has made it more
difficult to protect national gaming
monopolies. Norway, where international online gaming providers have been
available to Norwegian consumers for
some time, has naturally not been left
untouched by these developments.
Online gaming in Europe, 2013. The Norwegian Gaming and Foundation Authority: https://lottstift.no/lotteritilsynet/poker-og-nettspel/nettspel-i-europa/
Towards a comprehensive European framework for online gambling, Communication from the commission to the European Parliament,
the Council, the Economic and Social Committee and the Committee of the Regions. http:
//eur-lex.europa.eu/legal-content/EN/ALL/;jsessionid=zNCkTzTFhmh1xJLznWT7VkhjTvdXDSw9G32Z533fj0Dmgnj4YJJJ!-870161892?uri=CELEX:52012DC0596
Gambling, European Commission: http://ec.europa.eu/internal_market/gambling/index_en.htm
Gambling, European Commission: http://ec.europa.eu/internal_market/gambling/index_en.htm
29
3.2 What is a licensing system?
Under a licensing system all public and
private gaming companies can apply
to the authorities to offer gaming
activities in the country. Licences are
currently used as a regulating tool in
other industries, for example, the
telecommunications sector, where the
authorities issue a fixed number of
licences for 3G and 4G websites.
The licensing requirements for gaming
can be structured to suit the authorities'
wishes, including to limit the scope
of games, identify suspicious gaming
patterns, verify players' identities
and age, and to impose requirements
to disclose the risks of gambling
addiction. The licensing requirements
can also impose a fee to be distributed
to cultural and sporting causes. Often
the licensing requirements are aimed
at both the gaming companies and
their key personnel. Breaches can be
sanctioned with, for example, the
imposition of fines, more stringent
requirements or revocation of licences.63
Gambling Revenue (CGR). In games
where the operator bears a risk (for
example in roulette, where the gaming
company can lose money) the GGR is
defined as stakes minus winnings and
marketing and bonus costs.64 In games
where the operator does not bear any
risk (for example live poker, where
the players bet against each other),
the GGR is defined as income due to
the game operator (commission or
similar). See diagram on next page for
an illustration65
GGR is the most common tax regime,
since it is easier to establish a fixed
percentage rate to be taxed, regardless
of the type of game. This method is
used in the United Kingdom, Spain and
Denmark, and has also been proposed
in the Netherlands.
3.3 Tax schemes
It is often difficult to compare different
countries' tax regimes for gaming, as
these are structured in several different
ways. Here we will briefly present the
two most common tax regimes.
The first method of raising taxation
is to tax players' stakes, i.e. the total
amount that is wagered. If a player,
for example, bets NOK 100, a certain
percentage of this amount will be
taxed.
The other method is to tax the Gross
3
6
64
65
30
While there are many tax regimes, the
two above are the most common.
Regulation of online gambling, Norwegian Board of Technology's newsletter for Norwegian Parliament no. 14 April 2007. The Danish Board of Technology.
Regulation of online gambling in Sweden, 2012. PwC’s Gaming Centre of Excellence.
Regulation of online gambling in Sweden, 2012. PwC’s Gaming Centre of Excellence.
TWO MAIN WAYS IN WHICH GAMES ARE TAXED
Customer stakes
“Recycling”
Return-to-player %
Pay-out
(to customer)
GGR %
(= 1-return-to-player %)
GGR
(operator revenue)
Tax on stakes
2 main forms of
gambling taxation
Tax on GGR
31
3.4 How do different countries operate their licensing systems?
There are major differences in the way different countries structure their licensing systems and the demands that are made
of the operators. Below we will focus on five countries comparable with Norway: the United Kingdom, France, Spain, the
Netherlands and Denmark, where we focus in most detail on our Scandinavian neighbour.
UK
The United Kingdom introduced a new
type of licensing system for online betting, bingo, casinos, gaming machines
and lotteries in 2007.66 This licensing
system taxes gaming companies physically located in the United Kingdom at
15 per cent of their profits.
The major difficulty with the above
was that gaming companies licensed
in another EU country had the
same marketing rights in the United
Kingdom, without being subject to tax.
Therefore only 15 per cent of gaming
revenues in the United Kingdom came
from companies with a British licence.
Consequently, for several years efforts
have been made to change the regulatory framework in order to boost
the percentage of companies with a
British licence. This work is currently
being concluded and will mean that all
gaming providers that market and offer
online gaming in the United Kingdom
must have a British licence from the
Gambling Commission, which means
that all companies will be taxed at
15 per cent of their profits. The new
regulatory framework is expected to
apply from 1 October 2014.67
6 6
The Remote Gambling Report 2012, 2012. Report from the Norwegian Gaming and Foundation Authority
67
Gambling (Licensing and Advertising Bill), 2013. Gambling Commission: http://www.gamblingcommission.gov.uk/gambling_sectors/remote_eg_online_gambling/about_the_remote_
gambling_indu/about_remote_gambling/gambling_licensing_and_advert.aspx
32
FRANCE
Betting on horses
Tax
Social Security
Contribution
Tax on companies
that organise the races
Total
5.3% tax on stakes
1.8% tax on stakes
5.9% tax on stakes
13% tax on stakes
Tax
Social Security
Contribution
Tax for sport
Total
(National Centre for Sports)
5.7% tax on stakes
1.8% tax on stakes
1.8% tax on stakes (up to EUR 9.6% tax on stakes
31 million per annum) + 0.3 per
cent (limited to a maximum
of EUR 24 million per annum)
until 2015
Online sports betting
Online poker
There is a difference between poker played online or in casinos or similar (land-based).
Here the players' stakes are taxed.
Tax
Social Security Contribution Total
1.8% tax on stakes
0.2% tax on stakes
France
On 12 May 2010 France allowed private
companies to offer online games such
as poker, betting and totes (betting on
horses). All other types of lotteries and
casino games cannot be offered online,
which makes the regulatory framework
one of the most stringent in Europe.
ARJEL (The Authority for Regulation of
Online Gaming) regulates gaming and its
enforcement.68 Breaches of the law can
result IP blocks, prison sentences and
fines for non-licensed operators. The
above measures were introduced in
order to deal with more than 550 websites that had been marketing games
without a licence.69
In France gaming companies have to
acquire a licence for each individual
type of game; poker, sports betting or
betting on horses. Licences are granted
for five years, after which they have to
be renewed. The gaming companies pay
a fixed sum per licence (EUR 3,300–EUR
5,000), plus an annual fee (EUR 13,300–
EUR 20,000).70 The tax rate depends on
the type of game involved. In France
tax is raised on the player's stake, and
distributed to social causes and sport.
The licensing system has encountered
major problems in France. The greatest
of these has been that participants have
continued to play on unlicensed websites that are not subject to French regulations. The industry attributes this to
extremely stringent regulations on the
games that can be offered, in addition
to high taxation rates. The relatively
uncompetitive terms of the French
licensing system have meant that the
2% tax on stakes
scheme has failed to achieve its objectives, since the leakage to illegal and
unlicensed gaming companies continues
unabated – a leakage that the licensing
system was intended to counter.
Even though ARJEL has purposely striven to close down unlicensed websites, a survey from 2014, carried out by
France's "Observatory of Games" (ODJ)
and "Monitoring Centre for Drugs and
Drug Addiction (OFDT)", reveals that as
many as 47 per cent of participants play
poker on unlicensed websites.71 23.5 per
cent of these people play poker exclusively on unlicensed websites. For the
Tote, 26.2 per cent of people play on
unlicensed sites, while for sports betting this figure is 34.7 per cent.72
6 8
Gaming Law, jurisdictional comparisons, 2012. Mullenex et al, European Lawyer Reference Series
69
70
Gaming Law, jurisdictional comparisons, 2012. Mullenex et al, European Lawyer Reference Series
71
Les joueurs de poker, une population présentant un profil particulier? 2014. Eroukmanoff, Costes, Tovar. Observatoire des jeux
72http://www.pokernews.com/news/2014/02/french-players-choose-illegal-poker-operators-17501.htm
33
In Spain it is common for
gaming companies to enter into
major sponsorship agreements
with the country's leading
football clubs and also have
rights to show games on their
websites. Bwin was Real
Madrid's main sponsor with a
sponsorship deal worth EUR 20
million per year in the period
2010–2013.
34
SPAIN
Gaming
Pool sports betting
22% of gross game turnover
Sports betting at fixed odds
Sports betting exchange
Pool betting horse racing
Horse race betting fixed odds
Other types of pool betting
Other types of fixed odds betting
Other types of betting exchanges
Lotteries
20% of gross gaming turnover/ 7% of gross gaming
turnover (not for profit organisations)
Competitions
Other types of games (poker, casino, bingo etc.)
Random combination games
10% of market value for prizes
Spain
Spain faced the same challenges as
Norway in embarking on the process of
changing its regulatory framework. The
country lacked a regulatory framework
that effectively regulated foreign
gaming companies. Therefore in 2007 a
process was initiated that on 1 January
2012 crystallised with the introduction of a licensing system. Today, only
companies with a licence are permitted
to offer and market gaming in Spain.
The Lotto is still a monopoly organised
by LAE (Spanish State Lottery) and the
charitable organisation ONCE (Spanish
Organisation for Visually Impaired).73 74
The gaming companies must have two
types of licence – a general licence for
the gaming category they wish to offer,
along with a separate licence for each
individual game. The general licence is
7 3
74
75
76
77
Taxation
offered for ten years, while individual
games licences are offered for a period
of between one and five years.
Various statutory taxes are raised on
online gaming based either on turnover
or gross profit. In individual cases players can also be taxed at up to 20 per
cent of winnings.
The Research Report "Social Perception
on Gaming in Spain 2014",75 prepared
by the Charles III University in Madrid
and the CODERE Foundation, revealed
that as many as 43 per cent of online
poker players play on unlicensed gaming
companies' websites. 13 per cent of
these people played poker exclusively on unlicensed gaming websites.
These figures could be interpreted as
indicating that the licensing system
has not been designed in a sufficiently
attractive way to persuade customers
to switch to licensed online gaming.
A report compiled by Deloitte for
Jdigital (the Spanish Gambling
Authority) reveals that the gaming
companies that were a part of the
licensing system posted an aggregate
loss of EUR 72.5 million in the period
between June 2012 (the year the licensing system was introduced) and June
2013. 76 The report emphasises that high
government taxes are the main reason
why more gaming companies are turning
their backs on the Spanish market. This
in turn led to lost tax revenues for the
Spanish state.77 In light of the negative
trend, the report recommended reducing the tax on gaming from 25 per cent
to 10 per cent, and to base taxation on
net profit rather than on gross profit. Gaming Law, jurisdictional comparisons, 2012. Asensi & Serebrianskaia, European Lawyer Reference Series
Percepción social sobre el juego de azar en España 2014 V, 2014. José Gómez Yáñez, José Ignacio Cases, Germán Gusano, Carlos Lalanda and Ana Cases Comyn. IPOLGOB –UC3M.
Informe sobre la fiscalidad del juego «online», 2013. Report prepared by Deloitte Spania on behallf of Jdigital Assocacion Espanolo de Juego digital.
Informe sobre la fiscalidad del juego "online", 2013. Report prepared by Deloitte Spania on behallf of Jdigital Assocacion Espanolo de Juego digital.
35
NETHERLANDS
The Netherlands
The Netherlands is the most recent
European country to declare a wish to
deregulate its gaming market through
a new licensing system. The five-year
process concluded with a proposed
new Gaming Act that was sent to the
relevant stakeholders for review in May
2013.
include monitoring and registration
of players, reporting of problematic
gaming, and a requirement for the
company to be registered in the EU/
EEA. The licence cost is expected to be
between EUR 35,000 and EUR 50,000,
and a licence will be valid for five years.
Many of the proposal's details still
need to be clarified, and amendments
can also be expected once the proposal has been sent to the "House of
Representatives" at the end of July
2014.78 A final Act is expected to be
adopted in early 2015, and the system
to be introduced at the end of 2015/
start of 2016.79
In accordance with the proposal, the
companies will be taxed on 20 per
cent of their Gross Gambling Revenue
(GGR),80 in addition to incurring other
smaller taxes and fees at a total of 2
per cent of Gross Gambling Revenue. It
has also been proposed that payments
be made to voluntary organisations, 81
and taxation of 1.5 per cent of Gross
Gambling Revenue be paid to schemes
to combat gambling addiction.82
As in many other countries, all operators who satisfy the requirements will
receive a licence. These requirements
At the same time many tools will be
launched to stop non-licensed operators, including taxing participants at
29 per cent of profits on winnings from
unlicensed companies and options to
close down websites, stop payments
and similar.
78http://www.kansspelautoriteit.nl/nieuws/alle-nieuwsberichten/2014/juli/wetsvoorstel/
79http://calvinayre.com/2014/07/24/business/dutch-online-gambling-bill-critics-abound/
80 Amendment to the Betting and Gaming Act, the Betting and Gaming Tax Act and several other acts in connection with organising remote games of change, English translation, 2014
81
The Netherlands: Text of the Dutch online gambling bill published earlier than expected, 2014. Averill, Dla Piper: http://blogs.dlapiper.com/all-in/2014/03/07/
netherlands-text-of-the-dutch-online-gambling-bill-published-earlier-than-expected/
8 2
The Netherlands publishes draft online gambling legislation ahead of 1 January 2015 market launch, 2013. Stradbrooke, Calvinayre.com: http://calvinayre.com/2013/05/22/business/
netherlands-publishes-draft-online-gambling-legislation/
36
DENMARK
3.5 Deregulation of Danish gaming policy
Like Norway, Denmark operated a
state gaming monopoly until 2012.
However, on 1 January 2012 Denmark
introduced "the Gaming Act", a law that
partially deregulates and modernises
the Danish gaming market.83 The Danish
market was deregulated following
long-standing pressure on the Danish
authorities from the EU and the nation's sporting organisations, and because
technological developments meant that
a very high proportion of Danes were
using foreign websites. This in turn led
to lost turnover for Danske Spil A/S.84
The Folketing unanimously adopted the
new gaming legislation in Denmark,
and during the political review, the
Danish Social Democrats and the Danish
People's Party justified their support
for the Act on the following grounds:
3
8
8 4
8 5
8 6
87
8 8
8 9
"It has been clear for a long time that
the current status of the gaming industry is untenable. The existing regulation
have been holed, resulting in a type
of anarchy, where it is impossible to
prevent illegal behaviour and enforce
regulations. Foreign gaming providers
escape paying tax and national insurance, to the detriment of the state's
coffers and betting funds. This has
rendered it critical that the collective
gaming market be ring-fenced and subject to clear regulation.»85
The deregulated gaming market
in Denmark today
The overarching principles for the current Danish licensing legislation are
aimed at keeping spending on gambling
at a moderate level, protecting exposed groups from gambling addiction
and operating a sound and transparent market under public control.86
"The Gaming Act" regulates the various
forms of gaming, and applies to both
land-based and online gaming activities.
The law permits the authorities to offer
products such as betting, casino games
and gaming machines. Both companies
and individuals can apply for a licence
to offer these type of services. Licences
are valid for five years. A licence will
be granted as long as the legal requirements are satisfied, and there is no
upper limit for the number of licences
that can be issued.87 On 1 January 2014,
44 licences were issued for betting and
online casinos, distributed to 31 different gaming providers.88
Lotteries, including online bingo, lotto
and scratch cards, and dog and horse
racing, are still operated under the
Danish monopoly and offered exclusively by Danske Spil A/S.89
The Danish Gaming Act, Retsinformation: https://www.retsinformation.dk/Forms/r0710.aspx?id=132755#Kap1
Report on Proposed Gaming Act, 2010, Danish Parliament: https://www.retsinformation.dk/Forms/R0710.aspx?id=132216
The Danish Gaming Act, Retsinfomation: https://www.retsinformation.dk/Forms/r0710.aspx?id=132755
The Danish Gaming Act, Retsinfomation: https://www.retsinformation.dk/Forms/r0710.aspx?id=132755
The Danish Gambling Authority's Annual Report for 2013, Danish Gambling Authority
The Danish Gaming Act, Retsinfomation :https://www.retsinformation.dk/Forms/r0710.aspx?id=132755
37
DANISH SPORT BENEFITS
FROM THE LICENSING SYSTEM
Interview with Niels Nygaard, Chairman of the National Olympic Committee
and Sports Confederation of Denmark (DIF)
According to Niels Nygaard, Chairman of theNational Olympic
Committee and Sports Confederation of Denmark, the Danish
gaming monopoly has ceased. He speaks about higher income
for sport, and active measures to combat gambling addiction:
"A few years ago we saw a decline in our income. Following the
abolition of monopoly, things have stabilised and our income
levels are now rising again," he explains. Since the end of the
monopoly in Denmark, income distributed to sport has risen by
DKK 100 million–DKK 200 million.
In a situation with clear parallels with Norway, the Danish authorities abolished the monopoly due to the significant increase
in number of foreign gaming companies offering online games.
The authorities subsequently introduced a new licensing system.
Nygaard welcomes the fact that Danish sport is now receiving
more money as a result of more gaming companies participating
in the public-private partnership whilst still being subject to the
authorities' control and requirements:
"Opening up the market to commercial gaming companies has
made competition healthier, and enabled the state to ensure that
the companies pay tax and national insurance to the government,"
he explains.
Nygaard further believes that the Danish licensing system could in
many respects serve as a template for gaming legislation in other
countries, at the same time as addressing those who claim that
more aggressive marketing could result in more gambling addicts:
"We have not noticed any signs of more aggressive marketing in
Denmark following the abolition of the monopoly." The marketing
regulations are extremely stringent, and focus in particular on
gambling addiction," explains the DIF Chairman.
38
Football game in the
Danish first division, also
known as the NordicBet
league.
The Danish Gambling Authority reports
to the Danish Ministry of Taxation, and
is responsible for monitoring and controlling the Danish gaming market. The
Danish Gambling Authority also administers the licensing system by distributing
and where necessary revoking licences
for the various games. 90
The Danish authorities impose different
requirements on companies applying for
a gaming licence, and the law imposes
a series of overarching conditions that
need to be fulfilled in the application.91
The Gambling Authority is responsible
for handling applications, a process that
makes further demands with regard
9 0
91
9 2
93
94
95
to responsible gaming, ownership and
customer support.92
Depending on the turnover and the type
of licence, the gaming operator pays an
annual fee ranging from DKK 50,000 to
DKK 1,500,000. In addition, the gaming
companies also pay a flat rate of tax
of 20 per cent of turnover after deduction of payouts and marketing and
bonus costs, i.e. what we have previously referred to as GGR (Gross Gaming
Revenue).
Foreign gaming companies that offer
betting in online casinos must in addition to national insurance pay a flat tax
rate of 20 per cent of turnover, after
the deduction of payouts. Land-based
casino activities are taxed at the same
rate up to 45 per cent, with additional
thresholds for higher taxation.
If licensing terms are breached, the
authorities will be able to impose
sanctions, and as a last resort revoke
the provider's licence.94
The Gambling Authority can also
obstruct illegal gambling providers.
The authorities have various tools
available to ensure effective control
and to protect legal operators. Nonlicensed gaming operators are subject
to a marketing ban in all media, and
About us, the Danish Gambling Authority: https://spillemyndigheden.dk/om-os
European lawyer reference series, page 79
European lawyer reference series, page 85
39
The Danish Parliament,
Christiansborg in Copenhagen
can also be prohibited from processing
payments.95
A deregulated, yet regulated
market
The Danish licensing system has largely
been developed on players' terms and
in consultation with the gaming companies. The authorities believed that
the players would gravitate towards
the unlicensed market if the licensed
gaming market offered less favourable
terms for players. This could lead to a
risk of the licensing system being undermined by foreign gaming companies.96
However, recent experiences show that
the illegal market has been dramatically
reduced following the introduction of
the licensing system. Conversely, recent
figures from 2014 indicate that this
trend may be about to turn.
9 6
7
9
9 8
9 9
1 00
1 01
40
The number of licences is on a par with
the volume at the time the licensing
system was introduced, which suggests than no new gaming companies
have applied for a licence in recent
years. It is therefore assumed that the
Danish tax level is too high to benefit
all gaming companies, which in turn
is helping to sustain the "grey market"
that the licensing system was intended
to kill off.
Initiatives to combat gambling
addiction
The Danish gambling authorities are
attaching a higher priority to preventing
and treating gambling addiction. There
is no evidence to suggest that the number of gambling addicts has increased
in Denmark since deregulation of the
gaming market.97
The licensing system also obliges the
country's gaming industry to take
responsibility for preventing and treating gambling addiction in Denmark.98
In 2013, DKK 33 million was donated to
research, prevention and other measures to combat gambling addiction. 99 In
total this is DKK 21 million more than
Norsk Tipping spent on similar measures
in 2013.100
The authorities have also established a
Register of Voluntarily Excluded Players
(ROFUS). This is a register of all players in Denmark who have requested
to be excluded from online gaming in
Denmark. The register is operated by
the Gambling Authority, in accordance
with the Danish Personal Data Act. 101
President of the Danish Sports Federation happy to wave goodbye to monopoly, 2013, Christiansen and Askeland, VG: http://www.vg.no/sport/artikkel.php?artid=10135866
Gambling Addiction, the Danish Gambling Authority: https://spillemyndigheden.dk/spilafh%C3%A6ngighed-0
The Danish Gambling Authority's Annual Report for 2013, 2013. The Gambling Authorities
NOK 12 million for measures to counter gambling addiction, 2013, Ministry of Culture: http://www.regjeringen.no/nb/dokumentarkiv/stoltenberg-ii/kud/Nyheter-og-pressemeldinger/
Pressemeldinger/2013/12-millioner-til-tiltak-mot-spillproblem.html?id=717843
ROFUS – exclusion from gaming, the Danish Gambling Authority: https://spillemyndigheden.dk/rofus-udelukkelse-fra-spil-0
TIME FOR NEW GAMING REGIME
Joakim Marstrander is a lawyer and partner in Deloitte Advokatfirma.
He has advised a number of gaming operators and is a member of the
International Lawyer Network for Gaming Law (IMGL).
The Norwegian regulatory framework for gaming faces
imminent collapse. We should adopt an international
perspective when looking for new solutions.
Games and competitions fascinate and enchant people. Games
mean energy and entertainment, and in many contexts also contain a social element. Gaming activities are also a main source of
income for Norwegian sport and cultural life. However, there is
another side to gaming. Gaming can be addictive and in some
cases can adversely impact finances and other life events. We
say that you can "gamble the shirt of your back", and for some
people this is a very real threat. At the same time, we are seeing
income flows for Norwegian sport and culture coming under great
pressure due to an obsolete regulatory framework ill-suited to
modern-day gamers in Norway.
Norway has a long-standing tradition of regulating and controlling
gaming activities. We wish to protect individuals, and safeguard
the state's income flow that is distributed to cultural and charitable
causes. The structure of the system has been a constant topic of
debate where opinions are often divided, but at an overarching
level the control regime worked well until 10–15 years ago.
Despite an initial slow pace of change, the gaming regime is now
being seriously challenged. The scope of "gaming" is no longer
easy to define. We are now seeing the growth of various online
gaming solutions through various media channels that transcend national boundaries, offering everything from pure-play
casino games to hybrid entertainment with opportunities to win.
At the same time Norway has had to accede to the European
view of gaming administration in several areas, including by permitting games and winnings offered through the marketing of
products – which was recently enforced by the European
Supervisory Authority ESA.
A growing number of market players are arranging competitions
as part of their general marketing initiatives, and users are downloading apps and playing directly on their mobile phones. We are
witnessing a trend towards "gamification" of society.
The realities of the current situation are making it more difficult to
employ stringent and specifically Norwegian legislation as a basis
for regulation. Online distribution is obstructing the enforcement
of stringent regulations, and from a legal perspective Norway will
encounter difficulties in prohibiting activities that are legal in the
EEA area. This has already been seen in several different areas.
It is a misconception that there is a blanket ban on facilitating
gaming in Norway. However, in Norway it is illegal to arrange
"lotteries" offering the chance to win a prize by making a stake or
using scratch cards. Furthermore, there are several exceptions
to this ban, one of the most striking being that the authorities
have introduced regulations to permit aggressive bingo products.
The definition of an illegal "lottery" is therefore constantly being
challenged, by organisations, foreign companies and sometimes
even by Norsk Tipping. Disputes have to be settled through individual resolutions, regulations (for example for bridge, "pantelotteriet" (bottle deposit lottery) and soon poker tournaments),
through statements from the Gaming Authority (for example for
SMS lotteries), through case law ("texas hold'em”/poker) or EEA
practice ("postcode lotteries”). While the lottery authorities deem
poker to be a pure "lottery", the tax authorities view poker as a
taxable business capable of generating profits. Norsk Tipping's
online gaming is tax-exempt, which, in accordance with EEA law,
ought increasingly to apply to gaming products offered by other
providers, including foreign gaming operators.
The Norwegian ban on "lotteries" only applies in Norway. However,
significant sections of the Norwegian gaming market have relocated online. Consequently, it is proving demanding – bordering
on impossible – to enforce the ban in any practical way today. The
Norwegian Broadcasting Directive prescribes that TV marketing
shall comply with regulations in the broadcasting country, meaning that gaming advertising can be specifically aimed at Norway
through these channels. The authorities' ban on making gaming
transactions fails because the operators nonetheless use thirdparty payment solutions. Consequently, the only effect is that,
Norwegians abroad cannot use their credit cards in cafés and
hotels that have a casino table.
In my opinion the current gaming regime is riddled with contradictions and in reality has already collapsed. We have not managed to establish a regime that protects gambling addicts. We risk
dwindling income flows for sport and culture. The current gaming
regime could result in both Norwegian sport and Norwegian
gamers losing out.
The trend in Europe is much clearer – towards licensing systems.
Norway can learn a lot from countries with licence-based regimes
like Denmark and the United Kingdom, where licences regulate
who can offer games, and about how these can be structured
and marketed and which taxes are payable among other features.
A balanced and collaboration-based licensing system would permit the authorities to regain control of the gaming market. I believe there is no doubt that the Norwegian regime has to change,
and that a licensing system could prove a productive solution for
Norwegian society.
41
4
42
HOW CAN WE PREVENT GAMBLING
ADDICTION?
4.1 What is gambling addiction?
An important part of a future licensing system will involve ensuring that gambling addiction remains at a low level. In light
of the above we wish to outline the extent of gambling addiction and research into this issue. We will also examine a few
research and experience-based proposals to combat gambling addiction.
Gambling addiction is defined as
an affliction in which an individual
is no longer able to control his/her
gambling behaviour. Gambling addicts
cannot resist gambling, and find that
they succumb to external/"unknown"
forces.102The Norwegian Directorate
of Health lists the following points
as potential indicators of gambling
addiction:103
Players cannot control their desire to
gamble, and spend extreme amounts of
time and money gambling
They get irritated if they are
disturbed
1 02
1 03
1 04
1 05
1 06
1 07
They are strongly convinced that
they will win
They have experienced getting into
a trance-like state when gambling and
lose perception of time and place
This is the current situation, with the
gaming market in a state of flux, there
is an ongoing need for more knowledge
concerning gambling addiction and the
expertise required to prevent problem
gambling.104
Who is/gets addicted to
gambling?
Most problem gamblers are young men.
Research has shown that the following
demographic groups are over-represented among risk and problem gamblers:
men, people in the age group 15-24,
individuals in the lowest income groups
or with low levels of education, single
people and pupils/students/apprentices.105 Other characteristics of problem gamblers also emerge when this
group is compared to people without
gambling problems. For example, it is
quite common for problem gamblers to
start gambling earlier than others.106 107
Problem gamblers also demonstrate a
different gambling pattern to the population as a whole. Gambling addicts
participate in a wide range of different
games, where online games and on
fixed odds betting from Norsk Tipping
appear to the most important games.
Hansen, Marianne and Skjerve, Randi (2006). "Game over! A self-help manual for gambling addicts". Gyldendal Akademisk Forlag.
The Norwegian Directorate of Health. "Gambling addiction".https://helsenorge.no/Helseogsunnhet/Sider/Spillavhengighet1.aspx
The Norwegian Government (2012). "Action plan for gambling problems". http://www.regjeringen.no/upload/KUD/Spill_og_lotteri/Handlingsplan_mot_spillproblemer_des2012.pdf
"Gambling survey. Gambling habits and gambling problems among the population." Kavli, Håkon and Berntsen, Wenche (2005). http://www.rus-ost.no/file=5257
Gambling addiction in Norway. "Facts on gaming and gaming problems" http://spillavhengighet.no/om-oss/fakta-om-spill-og-spilleproblemer
SINTEF Department of Health Research (2008). "Gambling and gambling problems in Norway 2008". http://www.hjelpelinjen.no/filer/tekstbilder/SINTEF%202008.pdf
43
On the other hand, lottery games are
most frequently cited as games for people without gambling problems. In a
survey from 2008 SINTEF revealed that
problem gambling was most common
among young men who had previously
played on gaming machines, and who
were now turning their attention to
online gaming.108
Scope
It is difficult to determine the exact
number of gambling addicts in Norway
due to the fact that different parties
use different figures. This is to a large
extent attributable to the different
definitions and methods of counting
applied. A 2013 survey carried out by
the University Bergen on behalf of the
Norwegian Gaming and Foundation
Authority revealed that 22,000
Norwegians are gambling addicts, or
problem gamblers as researchers prefer to call them. This is slightly lower
than figures for the last 10 years. 10,000
Norwegians took part in the survey, the
largest of its kind on gambling problems
in Norway.109The Norwegian Directorate
of Health had previously estimated that
50,000 people in Norway had gambling
problems.110
The self-help group for gambling
addicts, Gamblers Anonymous Norway
states that 25,000 people currently have
gambling problems. SINTEF Department
of Health Research made a comparative study of gambling addiction in the
period 2002–2007. It found that 0.7 per
cent of the adult population, or 25,000
people, had a gambling problem at the
time the survey was carried out. In
1 08 1 09
1 10
1 11
112
1 13 1 14
1 15
44
total 1.7 per cent of the adult population, or 62,000 people, were experiencing or had experienced problems with
gambling in 2007.
The comparative study revealed that
the number of gambling addicts had
remained stable during the period
2002–2007, despite rising turnover in the
gambling market during this period.112
SINTEF also found in a study from 2008
the same prevalence of gambling problems as in 2007.113 We can therefore
assume that there are around 20,000–
50,000 gambling addicts in Norway, a
number that appears to be remaining
stable even though people are gambling
more.
Some young people are also addicted
to gambling in Norway. A study carried
out in 2010 revealed that 64.3 per cent
of 13–17 year-olds had gambled over
the last year114 One per cent of young
Norwegians satisfied the criteria to
be defined as gambling addicts, and
a further 3.5 per cent were at risk of
developing gambling problems. From
2002–2010 the number of young people
with potentially problematic gambling
habits fell by two-thirds. Problematic
gambling habits also tend to be linked to
a number of negative aspects of young
peoples' lives, including poor guidance
from their families, little parental control and understanding and significant
tension between children and parents.
Truancy and difficulties concentrating
at school were more widespread among
young people with gambling habits.
Gambling habits are also often linked
to behaviour indicating a risk of drug
abuse or other behavioural disorders.
Consequences
Gambling addiction often has significant consequences for those affected. Gambling takes priority over
work, education, family, relationships
and friends. Mental health can also be
adversely impacted, with anxiety and/
or depression not unusual in connection
with gambling addiction. 115 Gambling
addiction not only has major negative
consequences for actual problem gamblers, but also leaves its mark on relatives. SINTEF's survey was the first in
Norway to map the extent and way in
which relatives are affected by gambling addiction. The survey revealed
that around 84,000 people in the total
population had a problem gambler in
their immediate family. 23,000 adults
stated that gambling problems in their
family had adversely affected their physical or mental health. 39,000 people
found that their family's finances had
suffered as a result of their family member's gambling problems, and 55,000
people had experienced family conflicts
as a result of the problem. 7,500 people also stated that they were less able
than previously to contact other family
members or friends.
Gambling addiction is the greatest
problem facing the gaming industry. A
licensing system would make it possible to make even greater demands of
companies with regard to managing this
problem.
"Scope of gambling and computer-gaming problems in Norway 2013." Ståle Pallesen, Daniel Hanss, Rune Aune Mentzoni, Helge Molde and Arne Magnus Morken.
University of Bergen, Faculty of Psychology (May 2014)
The Norwegian Directorate of Health. "Gambling addiction". http://helsenorge.no/Helseogsunnhet/Sider/Spillavhengighet1.aspx
Gambling addiction in Norway. "Facts about gambling and gambling problems". http://spillavhengighet.no/om-oss/fakta-om-spill-og-spilleproblemer
SINTEF Department of Health Research (2007). "Norwegians have not become more addicted to gambling". http://www.SINTEF.no/Presserom/Pressemeldinger/
Nordmenn-er-ikke-blitt-mer-spilleavhengige-/
Frøyland, Lars R., Hansen, Marianne, Sletten, Mira A., Torgersen, Leiliga and von Soest, Tilmann (2010). "Harmless fun? Gambling and computer gaming among young Norwegians."
NOVA (Norwegian Social Research) Report 18/2010. http://www.sirus.no/Uskyldig+moro%3F.E2x322-8_Bp77BFv3TR9D6CJ1K0CT27VPL28nMhPLZB9MtlY05hRvSXN.ips
The Norwegian Directorate of Health. "Gambling Addiction". https://helsenorge.no/Helseogsunnhet/Sider/Spillavhengighet1.aspx
45
RESEARCH REPORT:
NO DIFFERENCE IN THE REGULATED AND DEREGULATED MARKET IN SWEDEN
In 2013 two researchers at the Department of Neuroscience at
Karolinska Institutet in Stockholm carried out a study on behalf
of the Industry Association for Online Gaming (BOS).119 The aim
of the study was to compare measures to promote responsible
gaming among organisations in the regulated gaming market in
Sweden with five members of the Industry for Online Gaming
without a Swedish licence (BOS), including Betsson.120 The CEN
standard was used as a basis for the comparison. The CEN standard is a European standardisation body comprising members
from more than 30 countries. The standard used in the study
is based on an agreement between 27 different stakeholders
on issues relating to gaming, including industry organisations, supervisory authorities, experts on gambling behaviour
(Harvard Medical School) and gambling problems (G4), gambler
organisations, software suppliers and gaming companies. The
study found no differences in terms of the various companies'
compliance with the demands of the CEN standard, and that
most requirements were essentially satisfied by both regulated
companies and BOS companies.
Another survey was carried out in 2013 by eCogra on behalf of
the Industry Association for Online Gaming (BOS). eCOGRA
is an international testing institute focusing on responsible
gaming. The Institute has been approved as a testing laboratory
for online gaming in countries including the United Kingdom,
Italy, Spain and Denmark.121 In the study carried out on behalf
of BOS, eCOGRA compared the Swedish requirements of
gaming companies with the CEN standard.122 It was concluded
that the Swedish requirements partially or wholly only satisfied
56 per cent of recommendations, and that a transition to the
CEN standard would this raise the degree of customer protection in gaming. Many countries, including Denmark and the
Netherlands, have already incorporated the CEN standard into
draft legislation in the field.
4.2 Experiences from other countries with licensing systems
One of the most widely cited
arguments against licensing systems
is that initiatives to counter gambling
addiction will not be catered for in
the same way as they currently are
under the current gaming monopoly
by Norsk Tipping. However, there is
little empirical support for this based
on other countries' experiences of
licensing systems.
Denmark
Norway's neighbour Denmark has also
had positive experiences of introducing
1 16
117
1 18
1 19
1 20
1 21
1 22
46
a licensing system. Thomas Rørsig, Head
of Information at Danske Spil, Denmark's
state-controlled gaming company,
has declared 116 that there have not
been any signs of increased gambling
addiction as a result of deregulation.
The Gambling Authority believes that
competition from foreign companies,
outmoded legislation and general
changes in the gaming market necessitated the introduction of new legislation, and hence a licensing system.
One of the most important aspects of
the licensing system was that it should
offer a responsible gaming offering to
help counter gambling addiction via
regulations.117
UK
In the United Kingdom a major study
carried out by organisations including
Gambling Compliance in 2013 revealed
that the number of gambling addicts in
the country had fallen compared with
2010, and was now on a par with in 1999
and 2007.118
http://www.vg.no/sport/dansk-idrettspresident-glad-han-er-kvitt-monopolet/a/10135866/
The Danish Gambling Authority (2013). «The Danish Gambling Authority's Annual Report for 2012». https://spillemyndigheden.dk/sites/default/files/filer-til-download/
Spillemyndighedens%20%C3%A5rsberetning%202012.pdf
Macadam, Daniel (2013) "No Rise In English Problem Gambling, Finds Health Study". Gambling Compliance. http://www.gamblingcompliance.com/node/52989
Companies covered by the study included Svenska Spel AB, ATG and Postkodlotteriet, which are part of the regulated gaming market in Sweden.
Players from the deregulated market covered by the study included PAF, Betfair, Betsson, Unibet and Bonnier Gaming. Source: Tengström, Anders and Dr. Rybeck, Anna-Karin (2013).
"Mapping of measures to promote responsible gambling". Karolinska Institutet. Sweden .
Companies covered by the study included Svenska Spel AB, ATG and Postkodlotteriet, which are part of the regulated gaming market in Sweden.
Players from the deregulated market covered by the study included PAF, Betfair, Betsson, Unibet and Bonnier Gaming. Source: Tengström, Anders and Dr. Rybeck, Anna-Karin (2013).
"Mapping of measures to promote responsible gambling". Karolinska Institutet. Sweden.
eCOGRA (2013). "Comparative Study. London. http://www.mynewsdesk.com/se/branschfoereningen-foer-onlinespel-bos/documents/benchmarking-study-31210
The European Committee for Standardisation (CEN) is a standardisation body, and one of three such bodies officially recognised by the EU (www.cen.eu). The CEN standard for
responsible online gaming, published in February 2011, comprises 134 recommendations designed to protect customers and ensure that online gaming operators in the EU operate
responsibly. Source: eCOGRA (2013). "Comparative Study. London.
4.3 Managing gambling addiction under a licensing system
Limiting gambling addiction
The authorities in a number of countries
have used the introduction of licensing systems as a means of exercising
greater control over gaming companies'
efforts to prevent gambling addiction.
The objective should be zero problem
gamblers, and the authorities should
instruct licence holders to help limit
the scope of gambling addiction. One
of the benefits of well-funded licensing
systems is that they allow the authorities to impose a greater degree of regulation for the benefit of users.
Gaming companies have an interest in
preventing gambling addiction from
both an ethical and commercial perspective. A few individuals staking
large amounts over a short period of
time and then disappearing does not
provide a sustainable business model.
A sustainable business model is built on
a steady income flow from a large and
loyal customer base that stakes responsible amounts.
requirements for such courses across
the entire industry.
There is much evidence to suggest that
partnerships between gaming companies and the authorities is the best way
to prevent gambling addiction. How can
we do this?
Training/certification should be valid for
a specific period only, with employees
obliged to undergo refresher courses
at regular intervals. This would enable
key personnel to identify signs/symptoms of gambling problems and provide
guidance on how to manage suspected
problematic gambling. Gaming providers' staff should also be trained in how
to assist problem gamblers or people
at risk of developing gaming-related
problems.
Mandatory training of personnel
Employees who have daily contact with
players can play a key role in preventative work, as they are in a position to
identify gamblers displaying problematic behaviour and signs that individual
gamblers may be losing control. One
group currently offering certification
comprises international experts on
responsible gaming from the G4 (Global
Gambling Guidance Group) certification
and accreditation group. Many industry
players, for example Betsson, already
use such courses to train their staff;
however, the introduction of a licensing
system would result in formalisation of
A daily report should be produced detailing all correspondence with users and
any subsequent follow-up measures.
This will guarantee an ongoing focus on
problem gambling and help providers
and authorities to control and limit the
scope of the problem.
47
Hillevi Sturhenberg, who is
employed as Responsible
Gaming Officer in the
Betsson Group, has worked
full-time on preventing
gambling addiction among
the company's gamers since
2008.
Other requirements relating to
regulation
In order to restrict the scope of problematic gambling behaviour, licensed
gaming providers, both land-based and
online, should be obliged to:
Carry out an obligatory age check to
exclude users under 18 years old
Provide users with general information about the potential risks relating
to gaming and information on how to
retain a healthy attitude to gaming
Allow participants to establish their
own spending ceilings in order to avoid
a steep suggestion-driven escalation
of gambling stakes and effects-driven
gambling
Offer gamers the opportunity to
exclude themselves from gaming, either
permanently or temporarily
Allow gamers to opt out of receiving
promotional and marketing information,
and oblige gaming providers to exclude
problem gamblers from their own mailing lists
1 23
48
https://spillemyndigheden.dk/rofus-udelukkelse-fra-spil-0
Offer gamers an interactive selfassessment test in order to identify
potential risk signals
Block access to online gaming in
upper secondary schools
Donate some of their profits to
organisations that research gambling
addiction and/or support organisations
that cater for individuals with a gambling addiction
Proper control and monitoring of
problem behaviour will in addition to
identifying abuse situations ensure that
online gaming is not used for money
laundering or other illegal financial
transactions between gamers. These
are measures that major listed gaming
companies already implement, but
under a licensing system could be made
mandatory for the entire industry.
Register of gaming addicts
A licensing system would also give the
authorities the opportunity to solve
one of the greatest challenges currently facing the industry – the lack of
a common industry register for problem
gamblers. Such a register, which should
apply to both land-based and online
gaming providers, would make it easier
to ensure that players who are excluded from one gaming company due to
signs of problematic gambling behaviour
could not simply move to another
company.
In Denmark this problem has been
addressed by the establishment by
the Danish Gambling Authority (the
Danish equivalent of the Norwegian
Gaming and Foundation Authority) of
a register of voluntarily excluded players (ROFUS) . This is a register of all
players in Denmark who have requested
to be excluded from online gaming in
Denmark. The register is operated by
the Gambling Authority in accordance
with the Danish Personal Data Act. 123
Betsson was awarded the prize
for the most responsible gaming
company during eGaming Review's
awards in 2009.
SOCIALLY RESPONSIBLE
OPERATOR OF
THE YEAR AWARD
The industry magazine eGaming Review awards an annual prize to the
industry's most responsible gaming company. The prize is awarded at
the eGaming Awards, an annual event held in London and attended by
all major gaming providers and monopolists. Previous winners include
Svenska Spel and Betsson.
49
5
50
NORWAY'S LAST MONOPOLY?
5.1 Globalisation changing society
In an increasingly globalised world,
Norway too has undergone dramatic
changes over the last 30 years. National
boundaries no longer represent a barrier for people, goods, services or
companies, but in many ways simply
outline new opportunities and new
markets.
Norway was subject to a significant
degree of deregulation during the "drift
to the right" in the 1980s. Restrictions
on shops' opening hours and the housing market were relaxed and a number of monopolies were abolished. The
idea was to free Norwegians from state
regulations and give them the opportunity to make choices based on their
own preferences. The political changes
seen in the 1980s provided the platform
for further modernisation and development of Norwegian society.
In 1981 the Storting issued the first
licences for local television, local
radio and satellite broadcasting. Thus
technological developments had thus
enveloped the Norwegian Broadcasting
Corporation (NRK) and Norwegian politicians. With the advent of satellite
TV, NRK's monopoly was practically
over, even though the Storting did not
formally abolish the scheme until 1984.
Today few people criticise TV2 and
other channels competing with NRK,
and no one wants to return to the state
broadcasting monopoly when NRK was
the only option.
The Storting unanimously highlighted
financial and technological changes
as the reason for the decision to abolish NRK's monopoly.124 Together with
a desire for greater freedom of choice
and consideration of consumer needs,
current societal changes are in particular being driven by technological
change.
The Solberg government's political
platform notified a desire to facilitate
societal changes in line with the above
values. Several alternatives to monopolies are currently being assessed within
different areas of Norwegian society.
Abolition of the state gaming monopoly is one of the measures being considered, and various future Norwegian
1 24 Proposition to the Storting S. 129. (1985-86) Recommendation from the Church and Education Committee's on a New Media Policy. (White Paper No. 84 for 1984-85), Stortinget :
https://www.stortinget.no/no/Saker-og-publikasjoner/Stortingsforhandlinger/Lesevisning/?p=1985-86&paid=6&wid=aI&psid=DIVL1230&pgid=aI_0476
51
gaming policies are currently being
considered.
The rise of Internet
The emergence and growth of the
Internet has resulted in a technological
revolution without parallel in modern
times. An increasing percentage of
trade, communication and public services now take place via the Internet,
and activity levels are constantly rising.
More and more industries are being
transformed by the Internet.
Norwegians are particularly keen
Internet users, with 85 per cent of the
population going online every day.125
The pace of change is illustrated by the
fact that in 2000 this figure was only 27
per cent. This is presenting new opportunities for consumers, and obliging the
authorities to participate in the rapidly
unfolding technological developments.
1 25
1 26
1 27
1 28
52
An increasing share of public service
offerings are now delivered via the
Internet, and in many cases electronic
services are the only channel available to the public. This demonstrates
a desire on the part of the authorities
to look to the future and leverage the
opportunities offered by technology.
The massive increase in the use of the
Internet is also driving changes in other
industries. On an average day, 70 per
cent of people who listened to a sound
recording in 2013 did so using online
audio files. Conversely, the number of
people using CD players is declining.
While 93 per cent of people used CD
players in 2003, this figure was just 34
per cent in 2013. The music industry is
just one example of a sector that has
been dramatically and rapidly transformed by the Internet.126 A similar trend is
now being observed in the film, TV and
Norwegian media barometer 2013, Statistics Norway: https://www.ssb.no/kultur-og-fritid/statistikker/medie
Norwegian media barometer 2013, Statistics Norway: https://www.ssb.no/kultur-og-fritid/statistikker/medie
The E-commerce Report, Posten: http://www.bring.no/_attachment/205041
The E-commerce Report, Posten: http://www.bring.no/_attachment/205041
computer games industries.
Burgeoning e-commerce
Many companies now offer clothes,
holidays, cosmetics and a whole range
of other products via the Internet.
Ten years ago only a few Norwegians
shopped online. Today, around 90 per
cent of the country's population make
online purchases, and this percentage
is growing each year.127
Online shopping is easy and tailored to consumers' needs. As well as
saving time and facilitating quick price
comparisons, consumers also cite lower
prices as a reason for choosing online
shopping.128
The Internet provides users with a plethora of opportunities and is a key driver of ongoing globalisation. It is also
constantly ramping up competition in
a number of sectors as more and more
purchases are being made online over
national boundaries.
Changing gaming policy
The gaming industry has also been constantly affected by these international
trends, technological developments and
the growth of e-commerce over the last
ten years.
However, there have not been any
major political changes in gaming policy
between the introduction of the first
Norwegian Lottery in 1913 and the
recent launch of Norsk Tipping's extensive online offering. The state monopolist Norsk Tipping has been used as
a tool to restrict undesired gaming
habits, while the surplus has raised
money for good causes. The model has
proved successful for a long period of
time, but is ill-suited to the current
1 29
globalised world and ongoing technological developments that are attracting
more and more people towards online
gaming.
Norsk Tipping has therefore embarked
on much more market-oriented course
in recent years in order to be better placed to meet competition from
foreign companies – primarily online.
This change of direction has clearly placed the gaming monopoly under pressure, while technological changes have
effectively "rewritten all the old rules".
Satellite TV signalled the end of the
broadcasting monopoly. The Internet
is doing the same for the Norwegian
gaming monopoly. The Norwegian
Gaming Authority estimates that
Norwegians spent NOK 11 billion–NOK
15 billion on gaming on foreign websites in 2013. 129 This is money that is not
going to Norwegian sport and involves
activities that cannot be regulated by
the Norwegian authorities. Technology
is rendering the current gaming monopoly obsolete.
An increasing number of European
countries are introducing licensing systems to regulate gaming market operators. Denmark introduced a licensing
system in 2012, where to date feedback has been exclusively positive.
Other countries including Germany,
Italy, France and the Netherlands operate various forms of licensing systems,
which secure control of activities and
income for sport and culture.
There is a lot of evidence to suggest
that one of the last monopolies in
Norway – the gaming monopoly – is nearing the end of the road.
Annual Report Norwegian Gaming Authority 2013
53
BETSSON'S RECOMMENDATIONS TO THE
NORWEGIAN AUTHORITIES
Kim Rud Petersen, spokesperson for the Betsson Group in Norway
In this report we have taken a closer look at ongoing developments
in the Norwegian and international gaming markets, and experiences from other countries with licensing systems. The gaming
market has undergone a technological revolution in recent years,
and Norwegian gaming policy has no choice but to accommodate
current and future developments – with regard to both technology
and increasing globalisation.
A future-proof licensing system could reinforce initiatives to counter gambling addiction, boost state income in the form of taxes
and National Insurance, contribute more to worthy causes at the
same time as regulating the current unregulated market.
Betsson does not have a fixed idea of the exact form of a future
licensing system for the Norwegian market; however, future
legislation should in any case be based on certain gaming policy
principles.
A responsible gaming policy that protects young and vulnerable
groups would have to be the starting point for regulation of the
Norwegian gaming market. In the same way as in the current
legislatory framework, social-political considerations should be
prominent, and gaming providers must be required to participate
in the public-private partnership for Norwegian sport and culture.
To ensure that the legislatory framework remains robust in
the future, all market players must be treated on equal terms,
provided that they satisfy the public requirements of studies on
approval. The licensing system also has to be attractive enough
for the industry to participate in. France and Spain illustrate how
legislatory frameworks that do not provide competitive terms for
gaming companies can allow the unregulated market to live on. A
licensing system will only be able to function if it is prepared in
collaboration with the industry.
Experiences from efficient markets suggests that regulations have
to be technology-neutral, non-discriminatory and tailored to suit
users' needs. The above also ought to be fundamental principles
of a new Norwegian policy for lotteries and gambling.
Betsson has offered games to its users for more than 50 years, and
is attracting a steadily increasing number of players in Norway.
We look forward to being able to apply for a Norwegian licence.
54
55
BETSSON AB (publ),
Regeringsgatan 28, SE-111 53 Stockholm
http://www.betssonab.com/
[email protected]
Tel.: +46 (0) 8 506 403 00
Fax: +46 (0) 8 735 57 44
56

end of the road for the gaming monopoly?

Transcription

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