According to the target schedule for reforming Finnish gambling legislation, we live in exciting times. The working group responsible for the preparation should finish its work within a couple of weeks. After this, Ministry of the Interior officials should be able to write the law, which should be ready and translated during May so that the public hearing can begin in June. So, at the latest, we should have information about what kind of new gambling legislation is being planned for Finland by the beginning of June.
So far, no official information has been received about the working group's work, so unfortunately, I don't know what they have planned. However, there is quite a lot of unofficial information (rumors). Unfortunately, the message of all these rumors is the same: the working group is badly behind schedule and has not agreed on the most critical issues. If this is the case, it is unfortunate but not so surprising. The differences of opinion between those who emphasize responsibility and those who emphasize business are reasonably significant. However, the result should be a compromise in which a balance is found between these two crucial issues. Without a balanced solution, the new system becomes unusable.
As I already stated, the working group's schedule problems are just rumors, about which we will get more information in early March, when the working group must be given more work time if the rumors are true. If the rumors are false, the working group will complete its work, and the process will proceed according to schedule. A steering group has also been set up for the working group's work, which should provide political guidance for the planning. The political goal set by the Finnish government is to create a gambling system, thanks to which the degree of channelization of the system increases significantly, but in such a way that gambling problems do not increase but decrease. The steering group must ensure that the proposed legislation fulfills this goal. Ultimately, however, the Finnish government must decide whether the legislation is such that it can be submitted to a public hearing process. After that, it will be sent to the EU notification process and finally given to the parliament for a decision.
If the rumors about the working group's major scheduling problems are true, then there is a high risk that the practical implementation of the new gambling system will be moved to the beginning of 2027. At the moment, however, the official goal is to get the system into effect by January 1, 2026, at the latest.
Since no preliminary information has been received about the working group's work, we still do not know the details of the legislation. Based on the official schedule, the assumption is that the details will be precise by the beginning of June. Here, I present my guesses and opinions on the most significant issues. When the legislation is published, I promise to go through my guesses and find out how wrong I was once again.
License-based products: online casino and sports and horse betting in both sales channels. The government program states that at least online casino games and digital betting will be transferred to the license system. I believe that all sports and horse games will be moved to the license side. In terms of the system's functionality, the license must entitle the games to be operated in both the digital and retail channels.
License: Separate licenses for casino games and betting (includes both fixed odds and pool-based sports and horse betting), license price around 50 000 euros. I support a system where one license could be used to operate all games belonging to the license-based system.
Tax rate: 20 – 25% of GGR. I would make a system where the tax rate would vary depending on how dangerous games are from a gambling problem point of view the games are. With this logic, online casino games would have the highest tax rate, fixed-odds betting would have a slightly lower tax rate, and pool-based sports and horse games would have the lowest tax rate.
Marketing: Only brand marketing (company & products) is allowed; on radio, TV, and other live-streaming channels, it will be possible to advertise casino games for a limited time; there will be strict restrictions on bonuses; affiliate activities are restricted; sports sponsorship is allowed, but visibility aimed at children and young people should be minimized.
Betting limits: A company-specific deposit limit initially applies to casino games if Finland has separate casino and betting licenses. The deposit limit will also apply to betting products if Finland has one license that covers all license-based gambling. If this happens, customers can apply for a higher deposit limit based on their income or other assets. In the coming years, the company-specific deposit limit may be replaced by a customer-specific limit when the regulatory system will be able to monitor this. I think that a deposit limit is better than a betting or loss limit.
Self-exclusion system: Finland will have a system where customers can prevent all gambling activities for themselves. The system will be similar to the Swedish Spelpaus.
B2B license: The B2B license will not be implemented from the beginning of the system change. Instead, technology and game suppliers are set certificate requirements that they must meet. The B2B license can be introduced sometime later if, for example, Sweden's experiences show that it is a good solution.
Cooling-off: There is a risk of having a cooling-off period in Finland. Since the entry into force of the practical level of the gambling system seems to be moved to the beginning of 2027, the risk of using the cooling-off period has increased somewhat. The state-owned monopoly operator Veikkaus appears to support the cooling-off, and politicians are used to listening to Veikkaus' opinion. Cooling-off would require a new regulation, which might be why not to have a cooling-off.
Supervision & regulation: A new supervisory authority will be established in Finland. It is not sure if the new regulator would continue under the Ministry of Interior control or if it would move, for example, to the Ministry of Finance. A new technological system and plenty of new officials are needed for regulation. The new regulator must be able to intervene more strictly than the current one in gambling activities without a Finnish license.
Jari Vähänen
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