FINLAND MARKET REPORT
Use of bonuses and benefits– accepted methods Although the use of bonuses was initially proposed to be banned, they were included in the final draft following significant feedback submitted during the consultation period. Under the proposed regime, bonuses and other benefits will be allowed under strict conditions. Moderate bonus credits can be provided equally to all customers during an established relationship but must not be tied to gambling time or spending. Bonuses cannot be converted into cash, may have a maximum fivefold wagering requirement, and must not compromise player protection obligations. Similarly, benefits, such as discounts and free goods, are allowed during the customer relationship to help maintain it, provided they align with good practice and are of moderate value. Allowing license holders to use bonuses as part of their offerings is a positive step in maintaining the attractiveness of licensed gambling services, as bonuses are widely used in the industry. We believe that including bonuses as an accepted method can help reduce interest in unregulated grey-market services. Restriction on sponsorship Similar to the current legislation, the proposed marketing restrictions prioritise the protection of minors and no gambling marketing of any kind may be directed at minors through any channel, or at events or in content intended to be viewed by them. These restrictions also extend to sponsorship: sponsorship agreements must exclude individuals under 18 and events or content aimed at this age group. License holders must ensure that their logos and product names do not appear on items or services for minors. Sponsorships also cannot involve content created for minors or target products designed for those under 18. Most European countries are tightening restrictions on sports sponsorship, and we believe this change will have minimum impact on most operators’ marketing strategies. However, the sporting community has widely debated these restrictions. Some argue they are too strict and, suggest that, at a minimum, companies should be allowed to feature their sponsorship endorsement – if not the games themselves – in marketing materials such as athletes’, clubs’ or federations’ websites. Restrictions on direct marketing The proposed regulation introduces restrictions on direct marketing for gambling services. Consent for direct marketing must be given explicitly and cannot be automatically included
in customer agreements. Direct marketing through phone calls, SMS, emails, or postal mail is prohibited without clear consent. We suspect that this restriction will not significantly challenge operators’ marketing strategies. Since the proposed restrictions align with the principles of the current gambling legislation, they may not effectively advance the objectives of the new legislation, such as improving channelling rates and preventing gambling-related harms. Notable changes in the upcoming regime The upcoming reform in Finland’s gambling regulation marks a significant shift in oversight and enforcement. Key changes include the establishment of a new regulatory authority, updated enforcement measures, and a new consumer protection system. One of the major changes is the transfer of gambling supervision from the National Police Board to a new regulator to-be established, the Licensing and Supervisory Authority, which will grant licenses starting in 2027. The new regulator will also continue the current responsibilities of the National Police Board, including enforcing compliance by prohibiting unlawful (unlicensed) gambling services, implementing measures to restrict such activities, and monitoring the gambling market. As with current laws, the new legislation continues to restrict the unauthorised provision and marketing of gambling services in Finland. Furthermore, a national self-exclusion system will be introduced, akin to those in Sweden and Denmark, allowing individuals to ban themselves voluntarily from all gambling activities or limit their exclusions to specific operators or games. What is the cost of operating in Finland? Operating in Finland entails several costs, including supervision (licensing) fees and tax. License holders must pay an annual supervision fee, scaled according to their game margins, which adjusts based on the profitability of their activities. The fee ranges from 4,000 to 434,000 euros annually. Based on feedback received during the consultation period, the second draft also introduces the possibility of fee reductions. The authority must lower the supervision fee for license holders if the surplus is expected to exceed five percent of the costs approved in the authority’s budget.
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IMGL MAGAZINE | DECEMBER 2024
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