Gambling Addiction – How Do Regulations Differ Between Countries?


Over the last decade, we have seen a huge growth in people gambling online, due to faster internet speeds and improved computing technology. However, that growth and an easier access to betting has created a similar rise in problem gambling. Some countries have taken a heavier approach to regulation in recent years, while others have decided to apply a light-touch regulatory approach.

In this article, we will discuss the approaches taken by the UK and Non-GamStop casinos.

Heavily Regulated Nations – The UK and Sweden

The United Kingdom has seen a big rise in regulations over the last years due to pressure from social groups and the government. The UK Gambling Commission has applied some tough measures to protect problem gamblers, which also affect the vast majority. Credit card deposits saw an outright ban at UK casinos, while the group also moved to cut the bet size on Fixed Odds Betting Terminals. In-play rules have also been added to the UK online firms with spin timers and there has also been a tough approach to marketing in the country.

Another key feature of the UKGC approach has been a collaboration with GamStop- a non-profit group that applies a blanket self-exclusion for UK gamblers. The person will be blocked from all UK sites for a non-reversible term of up to five years. These rules have helped to put the brakes on problem gambling, but they drove many to use casinos, not on GamStop. The gaming commission can then ignore that they have driven some gamblers abroad and exclude them from the figures.

In Sweden, the government has always taken a heavier approach to the gambling industry before the rise of internet gambling.

Sweden currently has three government-run casinos, and those have also started online services in a bid to capitalize on demand.

Recent changes to the gambling laws in Sweden have had an impact on the overall industry and the authority ensures that all gaming companies in Sweden are licensed and comply with the set rules and regulations. Despite some tough rules, the country’s gambling industry has grown as they take a lighter approach to marketing than the UK.


Medium Regulatory Nations – Germany and Holland

Germany is a unique country for gambling laws because each state makes its own rules, so the regulations have been different in each. However, that has made the situation more complicated after the online gaming emergence. The country is in the process of implementing new legislation which they hope can clear up any issues.

The German Interstate Treaty on Gambling was passed in March 2020, with it taking effect in the summer of 2021. The new laws are expected to standardize issues around online gambling, criminal efforts, and the processing of payments. These issues have led to confusion since the first Interstate Treaty was passed in 2012. The country moved quickly on that but a lot in the industry since then with a wider range of payment options.

The European Supreme Court blocked that initial treaty because it violated fair competition rules, so it never came into effect, and online operators never got licenses. German gambling operators must provide a security deposit between 5 million and 50 million euros and this measure would help to weed out any rogue operators.

Also in Germany, players have had to set a monthly deposit limit for themselves, which cannot be more than 1,000 euros. Each user sets up one account for all gambling companies and they cannot spend the same at another online casino in the month.

The Netherlands has also been moving to pass a new set of laws with the passage of the Draft Bill on Remote Gambling in February 2019. This piece of legislation provided for the issue of licenses to online operators. One feature of the country’s Betting and Gaming Act is that it differentiates between skill and gaming machines.

Poker is licensed and available in the country but only for Holland Casino. That could change with the new gambling bill in 2021. Sports betting licenses are available, but only one license is possible. Most of the revenue that betting operators generate goes toward sports, public health, and culture.

Holland also applies some strict bet limit rules and spin timers. Gambling halls operated by Holland Casino can offer bets from €5 to €10,000. However, there should be at least one game with bets under €5 plus another with wagers that should not exceed €2.

Separate bet restrictions are in place for slot machines with the maximum permitted slot stake that players can make is €50. Slots are the fastest-paced game on the floor and Dutch regulators set a minimum of three seconds between each spin. Slot players are also restricted to wagering up to €150 during any single gaming session.


Light-Touch Regulatory Nations – Malta and Curacao

Malta is a country that applies a lighter regulatory approach and that has led to a buzzing industry for the tiny Mediterranean island. However, the country is making some changes after concerns about financial crime and money laundering.

The country has brought in key functional roles to ensure companies have adequately experienced people in roles such as CEO, legal, and gaming operations. According to, the regulator adequately protects players within its jurisdiction and promotes one of the safer environments that attracts UK gamblers seeking casinos not on GamStop.

South American sites have been a popular destination for gamblers in recent years and Curacao is a country with one of the oldest online regulatory setups. The tax and costs for setting up in the country are attractive for companies and that has also attracted a vibrant market. Only one license is needed for any type of gambling operation and the country does not restrict gameplay.

Unregulated Gambling Markets

There are still some markets that are unregulated when it comes to online gambling with Canada and New Zealand being two examples, and smaller countries in Asia and South America. The USA is similar to the German environment with states having different rules and many are still trying to get to grips with the online industry.

The problem with an unregulated environment is that they offer very little support for consumers and no third-party dispute resolution. Regulated markets also have more concise and regular audits of the payout ratios for slots and other games.


Which Approach is Better for Punters

The UK approach has been a bit extreme because the UKGC says that problem gambling is 0.4% of the market. It is right to tackle the issue but allowing more freedom and asking gambling companies to flag any users would possibly be better. Stake size are a fair tool, but they fail to account for the different earnings levels of punters. The ban on credit cards reduces funding options and limited marketing means that bonuses and rewards and less attractive at UK sites.

The German approach is unique with a universal account for all gaming companies and a monthly deposit limit. That should be set by gamblers based on their wealth and then there would be a block for problem gamblers in the country.

In the end, problem gambling is only a small part of the industry, but it is damaging to the people and the families involved. The regulators should give more responsibility to the companies but leave the gameplay alone. There is technology available to spot problem gambling trends, but monthly limits would also remove that problem. The tough approach merely punishes every user and that has led to many UK gamblers moving to find less regulations at a non-GamStop casino.

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