Affordability: the international picture

In case you hadn’t noticed, affordability checks - and the broader question of player protection when it comes to gambling - are something of a hot topic in the UK at the moment. 

I’ve probably contributed more than enough to that particular debate, so perhaps now is a good time to take a step back and view things in context. A recurring, if sometimes unspoken, belief is that the UK Government is leading the world when it comes to nannying the punter, and that the Gambling Commission specifically are acting in a way that clearly oversteps the mark when it comes to protecting players from gambling harm.

But is that true? What happens in the rest of the world? What are we comparing both the current reality and future proposals with, and what alternatives are out there for protecting players? Let’s take a brief look.

The big picture

Let’s start by making a point so blindingly obvious that it is often forgotten: there are many places in the world where gambling is entirely illegal, and many more where online gambling specifically is illegal. 

True, these jurisdictions lost their global champion when the US Department of Justice re-interpreted the Federal Wire Act in 2011, but there are plenty still out there. Online gambling is illegal in both China and India, for example. And there are of course still many US states, home to millions of Americans, where placing a bet on sports on wagering in an online casino are still illegal.

All told it is probably true to say that over half the world’s population live in states where online gambling is illegal.

I make this point because there is often an unspoken assumption at the heart of affordability and player protection arguments: that free, unrestricted gambling on anything that moves is the ‘natural’ state of affairs, and any attempt to prevent or limit this activity is by default an outrageous imposition on human freedoms.

From a historical perspective, and even a contemporary global perspective, the reverse is true. Some countries have legalised gambling, and a very few have no limits and restrictions in place around what form that gambling takes. 

So with all that said, what is actually happening where gambling IS legal? Let’s take a look.


Of course, there is no single story when it comes to gambling regulations in Europe (it isn’t something the EU tends to get involved in), and we don’t have space to cover them all individually. Some countries (Spain, Italy) are relatively laissez-faire. Others like Ireland have expressly rejected affordability checks, for the time being at least. But many are not so relaxed. Pretty much universal by now are the usual responsible gambling narratives, but plenty of countries take things further.

To start with Germany: legalisation was accompanied by a requirement to enforce a €1,000 a month loss limit per player, across the board. There are also restrictions on the types of games allowed to be offered (no live casino, for example), and stringent ID checks. 

Similarly, Belgium previously enforced a weekly loss of €500, theoretically across all operators. However, as this has proved challenging to implement to date, at present a lower limit of €200 applies to each individual operator. 

Meanwhile in Scandinavia a different approach is used: state-controlled gambling. In Finland and Sweden there is a state monopoly around most forms of gambling. In Norway, spending limits as discussed in the context of Belgium and Germany also apply.

Perhaps more interesting again, Norway has taken steps to ensure that Norwegian bank accounts cannot be used to fund black-market gambling sites. Although there’s no question this solution doesn’t work perfectly, it nevertheless suggests that governments who want to get really serious about limiting opportunities to gamble have more than one tool in their arsenal.

Australia and beyond

Moving across the world to what could fairly be categorized as the ‘other’ truly mature online gambling market, things do appear to be more liberal in Australia. And so they are. But nevertheless, there are clear signs that change is coming.

Take, for example, the introduction in Tasmania of a ‘player card’ for all state-owned gambling terminals, which will restrict spending to AUS$500 in a month and AUS$5,000 in a year. In what has historically been something of a free-for-all, this is almost certainly the first shot across the bows of many. Certainly, the operators we speak to in Australia are all well aware that the mood music is changing.

And that story is repeated elsewhere. Even in the US, where legalisation itself is still a project some way from completion, questions are already being asked about exactly how players should be protected from financial harm. In Canada (Ontario specifically), legislation outlining the anti-money laundering responsibilities of gambling operators was also a timely reminder that the need to look into customer finances is not only restricted to affordability use cases - in most markets source of funds checks will require the same type of information to be shared anyway.

I could go on - but as there are something in the region of 250 countries in the world, doing so would begin to strain both your patience and my knowledge. Nevertheless, I think the conclusion is clear: UK operators should perhaps consider themselves lucky that they are not already under some of the far more stringent measures already in place elsewhere. To be clear, I don’t necessarily advocate for this. Cheltenham is around the corner, and I am glad that next week I won’t be living in Belgium.

But whilst operators may not particularly like the Gambling Commission, perhaps they should be advised to take a leaf from Hilaire Belloc’s book, and…

“always keep a hold of nurse, for fear of finding something worse”