Two Sides of the Same Coin
There are two sides to the multi-display equation: multi-window and omni-channel. An online bookmaker needs to consider both elements, as well as the interactions between the two, in order to offer an enhanced, seamless experience, boosting brand loyalty and company profits.
First of all, it’s vital to take account of the differing psychologies and behaviors that apply to desktop, mobile and in-shop betting. Mobile UI/UX currently needs to be simpler and more streamlined than on desktop, while session time, bet propensity and stake amount vary significantly between channels: a player will spend more time and money on desktop or in-shop, but will place more bets within a shorter time-frame on mobile. An omni-channel strategy, therefore, shouldn’t be focused on building an identical experience across all touch-points, but on creating complementary journeys in order to add overall value.
There can still be space to offer exclusive mobile offers, for example, although creating special promotions to promote the omni experience is also a powerful marketing tool, considering that the growth in mobile betting, which already represents over half of most operators’ turnover, is certain to continue.
Window on the Future
Players tend to spend much more time researching bet types and statistics on desktop, usually opening multiple windows to research team news and previous performances, whereas mobile players naturally tend to be more impulsive.
This allows for much higher margins from mobile betting, but it’s important to note that future generations of mobile devices, especially tablets, will make much greater use of multi-window, with far-reaching implications. In other words, players will be able to spend more time researching their mobile bets, reducing overall frequency and potentially lowering margins. Gestural interface, especially on smart TVs, will also take off in the coming years, allowing for far more multi-window approaches than are currently possible.
The sheer ubiquity of an omni-channel experience serves to encourage repeat betting. Operators therefore need to consider how mobile can support, rather than supplant desktop and in-shop betting. Cash Out is the perfect example of this: many players choose to make their selections on desktop or in-shop, but then to follow the progress of their bets on mobile, opting to cash them out on-the-go, whether to lock in profits or limit losses.
A Cash Out feature should therefore be as flexible as possible, enabling the player to set the precise amount they wish to take off the table, while leaving the rest of the stake active. This provides that all-important sense of control, which is at the core of building brand loyalty and promoting repeat betting.
‘Fast markets’ in-play betting on what will happen in the next one or five-minute period of a live football match, tennis fast markets on next point and next game, and live basketball betting represent a rapidly growing sector, where mobile can also be a powerful complementary channel.
Offering live betting suggestions for an event on which a player has placed a pre-match bet is a proven means of increasing turnover through the kind of appropriate, non-intrusive personalisation that bettors have come to expect.
In-shop bettors generally spend long periods of time on the premises, and it’s essential to make better use of down-time by providing a wider range of products and experiences. For some, the period between major horse racing events, for example, is an opportunity to research betting possibilities. For other, younger players, it’s the ideal moment to engage in mobile-based social betting.
By integrating both of these mobile device activities with in-shop display units – TV and SSBTs – an operator stands to reap significant rewards. QR codes displayed on large in-shop screens will become increasingly significant as a means of directing players towards specific sites, and it’s therefore vital for operators to invest in the very best hardware.
The Name of the Game
Fully gamified sports betting experiences, involving extensive lists of achievements and rewards, as well as peer-to-peer challenges and social leagues, are looking likely to become a major element of the sports betting ecosystem in the years ahead. A small number of operators have already rolled out products of this type, designed to appeal to new generations of players who have grown up with online gaming.
These approaches are tailor-made for mobile, since they can be readily integrated with social media accounts and will increasingly depend upon real-time interactions with other players. In fact, social media is expected to play a greater part in achieving ultra-personalisation across the board. By tracking trending hashtags within a sports betting game frame, for example, betting suggestions based on the latest team and transfer news, or mirror-betting based on the selections of successful players, can be created.
eSports is also emerging as a major force within the online betting world. It’s fair to say that the sector is still in its infancy, and that the most popular competitive games titles still lack significant mainstream appeal. Game developers are certainly aware of this, and we anticipate the imminent launch of a slew of new games which will be of interest to very broad spectator demographics. In the interim, however, we should also be seeing greater sophistication in terms of bet types. For games such as “League of Legends”, where the action is spread across multiple locations within the game universe, multi-window and very fast markets could well prove to be lucrative areas for operators which have the vision to develop the required technologies.
More prominent integrations with statistics feeds will be increasingly demanded by players. Rather than accessing them through a separate tab, the use of pop-ups and widgets to display the information relevant to specific bets will become the norm. Such features could even include video clips, showing the recent goals scored by a particular player, for example.
Although multi-event streaming in different windows might sounds like a very attractive feature, in practice it has a couple of major downsides. Firstly, the performance of even a powerful desktop or laptop computer can be severely impacted by multiple streaming feeds. This also applies to graphical visualisations, and one major online bookmaker has recently moved away from a feature that offered up to eight simultaneous visualisation windows. However, this is likely to have been for a different reason: what’s sometimes known as the paralysis of choice, or what you could simply call information overload.
This is an important factor to consider when strategising and developing multi-display betting experiences. Although it’s tempting to say ‘the more the merrier,’ there’s a fine line between increasing opportunities to encourage bet placement and swamping players with too many possibilities, causing them to tune out or lose faith with a brand.
There’s an additional issue to consider when it comes to streaming. Because live TV is broadcast with a delay of anywhere between 5 and 20 seconds, data feeds can often announce a goal before the player has seen it on screen. Clearly the operator cannot add a delay to their price updates to sync with TV pictures, as that can open up an operator to abuse by players who are watching the game inside the stadium and have fast feeds. The smart operator, therefore, needs to deploy sophisticated player profiling to determine not only the location, but the previous behaviour and trustworthiness of each and every bettor to provide genuine punters with the best possible experience.
Words of Encouragement
In-play accas are likely to become a key element of the multi-window and omni-channel experience, offering players time-sensitive opportunities to win big payouts, with prompts delivered via pop-ups, push notifications and/or SMSs.
Personalisation plays a big part here. If a player has been identified as a regular favorites-backer, then a timely suggestion notifying him that five favorites are all currently at level-pegging in home games could prove to be a very appealing acca bet opportunity.
Such opportunities are tailor-made for enhanced acca promotions offering extra winnings, ideally on a sliding scale according to the number of selections. The important thing to remember is that although such features are generally automatic, meaning that there’s no need for an opt-in, the promotion still needs to flagged up. There’s no point offering enhanced winnings if the player isn’t aware of it!
Half-time casino betting for sports players is a well-established phenomenon, as are gamified elements such as double or nothing on sports bets. Encouraging such behavior can be achieved by incorporating widgets such as casino mini-games within the sports game frame, or by encouraging casino betting on mobile devices at key moments. The latter approach can be particularly effective, since players who are watching a live game on desktop or on a smart TV are likely to move away from their main screen during the break, whether to put the kettle on or simply to stretch their legs.
Top of the Shops
For the operator, the ideal customer interaction with an SSBT is defined by speed. Operators don’t want punters hogging a terminal for 30 minutes to place 3 bets and lose out on the business of 10 others. Although SSBTs generally do offer match statistics and visualisations, it’s clearly preferable to direct players’ attention towards big screen or mobile live action. This not only ensures greater operational efficiency, but increases bet propensity. A mobile device naturally feels more personal than a public terminal, and is therefore a far more appropriate channel through which to offer bet suggestions and bet management features.
The single electronic bet ticket represents another dimension of the omni experience that serves to reduce in-shop SSBT clogging. Retail operators do stand to lose the percentage of their revenues that derives from lost tickets, but on the flipside, customers will be feel better protected, increasing brand loyalty and overall betting frequency.
In the Lap of the Odds
An operator’s odds strategy needs to be carefully considered when providing a true omni-channel experience. In-shop prices, of course, are traditionally less competitive than online, but the ubiquity of mobile devices means that players naturally expect to be offered the same odds across all touch-points.
Mirroring retail odds online makes it much harder to stay competitive, however, whereas basing in-shop prices on online odds damages profitability.
Most retail operators, therefore, have their SSBTs managed by outside providers, meaning that they do, in fact, offer different prices within the same location, which inevitably has a negative impact on the appeal of omni.
The answer to this conundrum is transparency – being up-front about slight variations in pricing, and in fact making a virtue of them. By offering better prices to encourage in-shop players to place a bet on their mobile or an SSBT rather than over the counter, an operator can increase efficiency and expose the player to a greater number of time-specific and personalised promotions, especially on mobile.
What’s the Takeaway?
In a uniquely dynamic industry, where innovation is at the heart of staying ahead of the competition, every operator needs to be aware of all the latest trends and developments across the world of tech. The most successful bookmakers need truly joined-up thinking in order to take advantage of changing bettor behaviour, the demands of fresh demographics and new ways to enhance the overall omni and multi-window experiences they offer.
SBTech is the industry-leading provider of fully managed and semi-managed sports betting solutions and services in regulated markets, including its complete omni-channel offering and uniquely configurable Chameleon360 iGaming Platform.
The company’s sportsbook offers world-class coverage, including 2,000+ proprietary bet markets and multi award-winning live betting, featuring over 20,000 in-play events every month. SBTech employs over 750 people in eight global offices, including over 200 in-play traders working 24/7.
SBTech’s wealth of betting features, ranging from integrated enhanced winnings accas to flexible Cash Out, its expertise in developing gamified betting systems and its mastery of big data analysis for creating personalised betting journeys make it the platform provider of choice for a rapidly growing portfolio of over 50 international iGaming operators.
More info: http://www.sbtech.com/
Event Reports: SiGMA raises the bar with mega successful show (EEGReport Magazine – Issue 5 – February – May 2017)
The third edition of SiGMA broke all records. The island has never witnessed an iGaming bonanza this spectacular, this successful: everyone walked out a winner. The organisers anticipated close to 3,000 attendees, with the final numbers edging 4,000, double last year’s numbers. This was clearly visible on the expo floor, which was extremely busy on both days.
The iGaming storm came to Malta on 16-19th November. The organisers behind SiGMA pulled off an impressive number of strategic partnerships, culminating in a much anticipated Malta Gaming Week, bringing the entire gaming community together; from affiliates and operators to regulators and vendors.
After receiving plenty of great feedback, this year’s summit saw some great upgrades, including the fact that over 300 affiliates flew to Malta for free, from the organisers’ own pockets. There are plans to reignite this idea with 300 fresh flights, but for new affiliates, thus injecting the show with “fresh attendee blood”.
Following last year’s overwhelming interest in conferences, the organisers switched to a bigger conference hall, with completely redesigned layout. Instead of standard theatre style setting, the room was set up cabaret style, with round tables, giving the attendees a better opportunity for discussion and networking.
Free standing lunch for all the delegates was also introduced on both days. It gave the attendees more time for business during those busy days.
The BiG Charity Dinner was brought to SiGMA for the first time as well, one day before the exhibition officially opened. It was a fantastic night of sports stories and brilliant entertainment, simultaneously raising money to enhance the quality of life of injured, sick or terminally ill individuals around the world, with a focus on the healing power of sport.
First edition of Malta Gaming Awards was held together with the BiG Foundation Dinner at the InterContinental Ball Room. 6 winners were chosen in the following categories:
Affiliate Of The Year – Winner: Game Lounge Limited
Careers Program – Winner: Tipico Careers
Corporate Responsibility – Winner: Maltco
Fastest Growing Operator – Winner: Evoke
Innovator – Winner: Join Games
Investor – Winner: Optimizer Invest
Among the other new events introduced during SiGMA16, the SiGMA Startup Pitch, brought together nine startups and seven investors under one roof. With so many investors wanting to join the gaming scene in Malta as well as worldwide startups, there’s never been a better time to launch this session. Real big names, including Morten Klein (Cherry Group), Ory Weihs (XLMEdia) and Carla Maree Vella from Optimizer Invest were among the investors grilling the start-ups.
Each startup had three minutes to present their project and then faced a seven minute session of Q&A from the investors and the audience in a Dragon’s Den-like environment. Despite initial fears, the format worked marvels, and not a single member from the audience was bored given fast paced session.
The winner of the first edition is Commologic, an innovative sports betting software provider based in Israel and licensed in UK, Malta and Denmark. Their first game, BetUP, the world’s first inplay betting cash tournament game, has recently gone live with Unibet and The Football Pools.
Preparations for SiGMA17 are already in full swing. The details on the next edition will be announced in early 2017, but booths are already selling fast. Stay tuned and check maltaigamingsummit.com for regular updates.
Event Reports: SBC bringing a global perspective to sports betting industry (EEGReport Magazine – Issue 5 – February – May 2017)
As the sports betting industry settles after a year of major consolidation, SBC – Sports Betting Community is planning to provide the sector with the tools it needs to thrive in 2017.
SBC has grown considerably in the past few years as the sports betting industry responded positively to its services. Alongside its SBCNews.co.uk news portal, the company also offers sports betting consultancy work through its SBC Media brand. But it’s the SBC Events division that has really taken off with two established conferences, Betting on Football and Betting on Sports, complemented by the SBC Awards ceremony held at the end of the year.
“We’re bringing an international perspective to the sports betting industry at SBC this year,” explains SBC Founder Rasmus Sojmark. “We’ve had such a global audience attending our events, reading our news site and being up for our awards that we thought we’d acknowledge the fact by embracing the international nature of the sports betting business. We’ll be doing a much bigger global push on our events this year and also introducing some interesting new projects to the industry in 2017.”
The first of these initiatives is the brand new H20 Data – Sports Betting Seminar that is being held on the Sunday before the ICE Totally Gaming Show. SBC has teamed up with sports betting supplier BetConstruct to put on an evening discussing the importance of data to the sports betting industry.
Liverpool and England football legend John Barnes has been confirmed as a headline speaker at H20 Data. The two-time First Division and FA Cup winner with Liverpool will take centre stage as part of the post-dinner entertainment on Sunday 5th February at Whitehall Place. Barnes, who was capped by England 79 times, will be part of a Q&A session along with another big name from the sport, who is yet to be revealed.
Along with the appearance of football royalty, the invite-only seminar will address key questions around the speed, range and depth of data. BetConstruct will also be conveying the importance of its data services to sports betting traders, C-Level Management staff, Sportsbook Directors and Sportsbook Managers across the industry.
Among the subjects covered will be the management of risk, what to look for in a data feed and data for eSports. There will also be an opportunity to find out more about the Megafeed Live Scouting Data that BetConstruct provides to its partners. A panel discussion will also discuss how operators and punters are using data in a day to day capacity.
Starting at 6pm, the sports data seminar will combine presentations about sports betting data with high quality food, networking opportunities and a series of celebrity speakers for the 150 delegates in attendance. The event will officially end at 11:30 pm, but will be quickly followed by drinks and networking at the Royal Horseguards Hotel.
SBC Managing Director Andrew McCarron commented: “We’re trying something new this year with an event focusing exclusively on sports data ahead of ICE. We’ve already attracted a good crowd of people interested in finding out more about data and discussing its uses. It’s going to be an entertaining and interesting evening.
“There are three key things to take into consideration when it comes to data; it needs to be quick, it needs to be accurate and it needs to be robust. All three are vital components to a healthy data feed, which is as important to the sports betting business as water is to life – hence the name of the session.
“Of course there are always issues around the handling of data and filtering what is useful. That is perhaps the biggest challenge of all. The Sports Data seminar is the first of a new range of one-day targeted events from SBC this year, so this is an interesting development for us.”
A key philosophy at SBC is the power of networking for business. SBC’s origins are in networking evenings across Europe and one of its most successful events has been held in conjunction with iGaming Business for the past seven years.
The London Baby networking party is a free event held on the first Tuesday of the ICE conference and this year will be returning to Cafe de Paris on Leicester Square in central London. The free party provides a perfect opportunity for a more relaxed networking experience around ICE, although the free bar into the early hours also helps conversation. Almost 1,000 people attend the London Baby networking party every year, making it one of the biggest events around the ICE show itself.
One of the biggest developments for SBC this year is the evolution of its flagship Betting on Football Conference. This year will see the fourth incarnation of the conference and SBC is introducing some big changes to the format this year with a six-fold investment in the event.
Last year Sojmark promised to turn this 2017’s Betting on Football into ‘a bigger and better two-day event’. The decision to extend the conference was made after hugely positive feedback from the 2016 conference at Stamford Bridge, as well as the experience from the successful two-day Betting on Sports Conference held by SBC Events last September.
Both operators and suppliers were effusive in their praise for the Betting on Football concept. Simon Trim, CEO at Sporting Index, commented: “If you’re an operator or supplier and football is important to you, then this is the place where you need to come.”
Vahe Baloulian, CEO at BetConstruct, added: “It’s an opportunity to meet people that are in the same industry and learn from them. We are good at utilizing the knowledge gained from these conferences, and turning them into profitable opportunities for our partners.”
Tony Kenny, Head of Sponsorship at William Hill, reflected: “It’s been a fantastic day. A great chance to talk about sponsorships for William Hill, and show a lot of people what we do in terms of activation and the kind of sponsorships we’re involved in.”
Lennart Gillberg, Founder at Spiffx, said: “In our business if you get one or two new contacts, that can make a big difference for your business. I met a couple of guys here who are really going to push our business forward.”
Mark Davies, Head of New Business at Leicester City, the reigning Premier League champions, said: “This conference is beneficial for everyone, and these opportunities don’t arrive very often.”
Such positive feedback has encouraged SBC Events to push the boat out this year. McCarron explained: “This year’s Betting on Football will be our fourth and we are taking on board some of the lessons that we learned from Betting on Sports last September, as that was our biggest event to date.
“We’re putting on world class hospitality for around 800 delegates and providing unlimited networking and business opportunities, exhibition and product display, as well as top class sessions from 100 leading industry speakers.
At its core is now a two day conference with two main streams and a breakout room, as well as an international audience. We have broken these down into four tracks – Leadership, Market Profile, Marketing & Media, and Trading and Operations.”
This year’s Betting on Football is also a more international affair, with countries represented from far and wide, meaning the cream of the global sports betting business will be heading to Stamford Bridge in May.
The exhibition area has been transformed and now takes up most of the Great Hall at Stamford Bridge, while the two major networking parties are at the sensational Kensington Roof Gardens and Under The Bridge nightclub. SBC has also introduced networking gatherings either side of the main conference so the event actually stretches across four days – 2-5 May.
McCarron added: “The level of people there will also be extremely high – we have a dedicated evening for C-Level executives as well as a specific dinner for invited affiliates. It also has a much larger international contingent. For instance, from Italy we have the regulator AAMS attending, as well as tier 1 operators like SNAI, and also major clubs like AS Roma and AC Milan. These are just examples of how Betting on Football has become a global conference, with operators, regulators and sports organisations attending from across the world.”
The C-level and affiliate dinners are an embodiment of the greater focus that SBC places on networking at its events. The evening of 3 May sees a major networking party at Kensington Roof Gardens, one of London’s most spectacular party venues, owned by Virgin entrepreneur Richard Branson.
The evening itself contains three different elements – the main Betting on Football networking party and the two invite-only dinners. This is followed up on the second evening with another high class networking party at the Under the Bridge, Roman Abramovich’s personal nightclub on the grounds of Stamford Bridge, giving delegates the very best opportunities to make connections with key members of the sports betting industry.
Betting on Sports will also be making a return in 2017 and again will be in central London in September. SBC is expecting around 800 people to attend, a modest increase on last year’s inaugural Betting on Sport event, which offered the most comprehensive look at the betting industry ever seen. From Brexit to Esports, marketing to integrity, money laundering to DFS, and US Sports to payments, the two-day conference featured 90 speakers across 28 separate discussions.
Marathonbet CEO Viktor Hoffmann was on a panel discussing the future of sports betting, along with SNAI CEO Fabio Schiavolin and 10Bet CEO David Bazak.
Hoffmann believes that the conference offered a perfect opportunity for the industry to discuss the latest issues. He commented: “One great characteristic about our industry is that it’s ever-changing, fast-paced and dynamic. New standards are always being set, while goals and targets are being smashed and re-set. Betting on Sports is a chance for us as a business to immerse ourselves in an industry we’re passionate about, and perhaps influence how we grow and achieve more great things in the future.”
Another speaker was LeoVegas CEO Johan Styren who featured on the New faces panel talking about the new sportsbook that the mobile-first operator launched last year. Styren believes that the industry should be looking beyond its own boundaries for innovation.
He said: “There are a few pain points for sports betting consumers, but in my opinion, the main one is the lack of personalisation. Online and mobile sportsbooks have looked the same for a number of years now, and the industry needs to step up its game by looking at what other industries are doing to address this.”
Paul Leyland of Regulus Partners kicked off the conference with a comprehensive overview of the betting industry in 2016, with special reference to the Brexit vote.
Leyland commented: “The key issue facing all stakeholders in the short-term is uncertainty. Lots of people are making lots of predictions, but the nature of this unprecedented circumstance is that nearly all of them will be wrong. Where there is uncertainty, there is an opportunity. This is a time for big change for all sector stakeholders, and while that is scary for most it will be the making of some.”
Away from the main conference room, Betting on Sports also featured a series of interactive ‘breakout’ sessions, which included an anti-money laundering (AML) and data protection workshop targeting chief executives, heads of marketing, compliance teams and money laundering officers.
McCarron commented: “We’ll be building on the success of Betting on Sports as well this year and we already have dates for people to enter into their diaries – 13-15 September 2017.
“We’ve also been excited at the impact of our new look Awards. We really ramped things up last year and tried to offer something different to the usual industry award ceremonies. I’m pretty sure we managed to provide an experience to everyone who attended.”
Bet365 came out on top of its industry peers to take the SBC Bookmaker of the Year Award for the third year running. The Stoke-based outfit beat Unibet, Sky Bet, Pinnacle and 10bet to take the award, sponsored by Oddslife, which was voted on by industry professionals. Bet365 also picked up the gong for best Live Betting Product in a very successful night for the bookmaker.
Yorkshire-based Sky Bet also had a successful evening, winning the Best Football Bookmaker Award, being highly commended in another two categories, and seeing sister brand Oddschecker retain the Affiliate of the Year Award.
400 industry professionals attended the awards at the exclusive Under The Bridge nightclub at Stamford Bridge and were given a Christmas welcome with snow, mulled wine and mince pies. Inside entertainment came in the form of a 138.com sponsored selfie competition and the Slots Million VR casino.
The evening, sponsored by OPTIMA, was hosted by Sky Sports News presenter Hayley McQueen, thanks to sponsorship from BetOnBrazil, who announced the winners and highly commended entries in seven innovation award categories and seven overall award categories.
The innovation awards winners were chosen by a panel of 30 judges, most of whom are leading CEOs in the business, while the overall awards were voted for by people who attended SBC’s two conferences, Betting on Football and Betting on Sports, or who receive the daily Betting Bulletin from SBC News. The night ended with a set from Kellie Acreman, voted one of the world’s sexiest DJs, sponsored by EnergyBet.
Among the other winners were EnergyBet in the Rising Star in Sports Betting category, Betbrain as Football Affiliate of the Year, Pinnacle as Esports Bookmaker of the Year, LeoVegas for Marketing Campaign of the Year, BetBright for Best Football Betting Product, BetConstruct for Best Sports Betting Product, Golden Race for Best New Virtual Sports Product, Oulala for Best Fantasy Sports Product, Better Collective for the Best New Affiliate Product and Optima for Best Retail Betting Product.
The evening also saw the launch of the SBC Sports Betting Hall of Fame, with Howard Chisholm of Chisholm Bookmakers, Carsten Koerl of Sportradar and FSB Technology chairman Mark Blandford inducted as inaugural members.
McCarron added: “We were particularly excited about the launch of the Hall of Fame as we believe it’s a great way to honour the people who have given so much to the industry. We now have three worthy inductees and they will be joined by more at this year’s awards in December.”
Market Update: Poland (EEGReport Magazine – Issue 5 – February – May 2017)
Piotr Dynowski is a partner at Bird & Bird Warsaw office and Head of IP/TMT practice. He advises on all aspects of gaming law, in particular online gambling, social gaming and e-sports. His expertise covers licensing regimes, regulatory issues as well as advertising and provision of B2B services for gambling industry such as payment services etc.
As an expert on Polish gambling law, Piotr frequently comments on case law developments for Gambling Compliance and speaks as events such as World Gambling Briefing and Annual European Gambling Congress and Expo.
In 2010, as the Polish expert he participated in the research conducted by Cambridge Health Alliance together with Harvard Medical School and Harvard Law School, investigating associations between European gambling regulations and the actual gambling behavior of players.
In 2011, he represented the two largest European online gambling industry organisations in complaint proceedings against Poland to the European Commission for violation of the EU law by Polish gambling regulations, which resulted in the European Commission launching proceedings concerning violation of the EU law by Poland at the end of 2013 which terminated only in January 2016 after a number changes to the Polish gambling regulations were introduced. He is a legal expert to the Polish Chamber of Commerce.
EEGReport Magazine: Poland’s Gambling Law is currently going through some rapid changes. What are the key changes and amendments that have been added or changed over the past few months?
Piotr: Yes, there are several major changes that will come into force in the near feature, resulting from the amendment to the Polish Gambling Law that was adopted by the Polish Parliament on 15 December 2016 and signed into law by the President on 28 December 2016. Most of provisions of the new law will enter into force on 1 April 2017, with exception of provisions introducing website and payment blocking measures against the unlicensed operators and sanctions for in-compliance with these measures that will enter into force on 1 July 2017.
The new law introduces new forms of legal online gambling such as online casino-style gambling. Until now, the only online form of gambling legally available in Poland was online betting. Also slot machine gaming will be greatly expanded as slot machine games will be now allowed not only in casinos (as it is today), but also in newly-established slot machine parlors.
Unfortunately, both these changes will not affect private operators and will not open the market to them, as both these new forms of gambling will be subject to exclusive state monopoly.
Several other, lesser changes will also come into force. Unfortunately, many of them seem to be intended to tighten the restrictions concerning gambling, which are already very strict in Poland. However, some of them, while not ground-breaking, will open the market to some extent.
For example, the new law will allow advertising of betting, including on TV, although only after 10:00 PM, or during transmission of events sponsored by betting operators, such as football matches. The provisions on advertising of betting still contain several restrictions, but it’s good they were introduced. Currently all forms of public advertising of any forms of gambling is prohibited and there was even a case where someone was convicted for publishing a “selfie” on Facebook which featured a roulette wheel in the background.
Once the new law enters into force, it will be also possible to organize minor sport poker tournaments outside casinos where they have to be organised now. Currently poker tournaments held outside casinos (if the participants play for money or prizes of any value, no matter how minor) are sometimes raided by uniformed services and the participants convicted. The new law will allow for minor poker tournaments to be held outside casinos, although they will still have to be notified to authorities. Although many consider poker to be a game of skill more than a game of chance, Polish law does not recognize this.
Thus, to some extent the new law is a step in the right direction, even though it’s a small one.
From July 2017, the gambling sector in Poland will face a revolutionary change. The Minister of Finance will be granted authority to restrict access to unlicensed gambling websites in Poland. Not only access to such websites will have to be blocked by Internet Service Providers, but also payment services providers will be required to stop providing payments to such blacklisted websites. The rationale behind this regulation is that whereas it is difficult to directly enforce Polish regulations against the unlicensed, often offshore, operators, the efforts should be focused on cutting them off from money which may be harmful for their business and force to comply or withdraw.
It is hard to say what will be the actual impact of the new laws. It is possible, however, that in a year from now we may be facing a completely different gambling market in Poland.
EEGReport Magazine: Is there a country that has been model for Poland in these tough times of searching for the right framework in the online gambling industry?
EEGReport Magazine: What are the key sectors in the Polish gambling market based on niches? Sports betting, casino, poker?
Piotr: When looking at the Polish gambling market, we need to keep in mind that the truth is that currently a major part of it is in fact controlled by illegal or grey-market operators. Because the Polish law is very restrictive, a large part of gambling and betting takes place through foreign websites which are unlicensed in Poland. This is prohibited by law, but according to some studies foreign (so-called “offshore”) online betting operators hold around 70% of the Polish market. Foreign companies can provide all kinds of games (while the only form of online gambling that private companies may legally offer in Poland is online betting) and are not bound by Polish steep gambling tax rates. Legal operators who made an effort to obtain a license are of course frustrated with this.
The situation with slot machine parlors is particularly interesting. While they continue to operate in several places outside the casinos, they are regularly closed down by the authorities who consider them illegal. The situation however is not entirely clear, because some operators argue that the law that banned slot machines outside casinos is unenforceable as the government failed to notify these regulations to the European Commission. With the new law coming into force soon, this dispute may further escalate.
Some forms of gambling, although legal, are not really present on the market, such as bingo saloons, for example. This is most likely a consequence of strict laws making such operations unprofitable.
If we only consider legal enterprises, gambling in Poland mainly consists of sports betting (land-based and online) and casino games (land-based only). Popular games such as slot machines and poker may only be played in casinos.
Another major area in Poland is lotteries – the three main types of these are the national lottery (Lotto) which is losing its popularity year in year, similar number games – reserved for state monopoly, lotteries conducted by phone or SMS (handled by private operators), and various types of promotional lotteries organised by private companies as means of promoting their products.
EEGReport Magazine: Who are the key operators at the moment and how is the taxing going to change?
Piotr: Only big enterprises are able to pay the fees for licenses in Poland and satisfy the requirements to hold casino or betting licences. Currently, only few companies, such as Casinos Poland, ZPR, Finkorp, operate casinos throughout Poland (which are limited in number by law).
Similarly, only eight companies hold betting licences and seven of them may also operate online. The most prominent betting operators are Fortuna, STS, Totolotek and Milenium.
EEGReport Magazine: How is the taxing going to change?
Piotr: No significant changes will be introduced with regard to taxation of gambling. Unfortunately, the gambling tax rates and bases on which they are calculated, which are no less important, tend to be one of the highest in Europe and this will continue. This makes licensed gambling less appealing for Polish customers – offshore entities who pay lower tax can simply offer better deals.
There is some hope, however. During the recent legislative process there was a proposal made to change the tax base and rate for betting from the current 12% of turnover to 20% of the so-called Gross Gaming Revenue, which would make Polish operators more competitive against offshore companies. Although it was finally dropped, there are rumors that the idea may resurface in the near future.
EEGReport Magazine: It has been recently brought to our attention that the government has tried to block certain aspects of “free-speech” like restraining the media. The new law was intended to block unlicensed gambling websites. What would be the outcome of that measure and how is this going to impact online gambling?
Piotr: Website blocking is a novelty in the Polish legal system. While it’s a controversial idea by itself, it is not fully clear how the system is intended to operate in practice. There are numerous problems with it and there can be doubts as to its fairness and transparency. It seems the lawmakers simply overlooked some important issues while drafting the bill.
The basic idea is that the Minister of Finance will maintain a register of unlicensed gambling websites which – in his opinion – address their services to players in Poland. When a website will be entered into such register, Internet Service Providers will be required to block access to them and reroute Internet users who try to access them to a governmental website. Moreover, payment services providers will have to cease providing their services to such blacklisted websites. If they don’t, they may face heavy fines or even lose their license for providing financial services in Poland.
The idea is quite simple, let’s cut off the stream of customers and money from illegal online gambling, but the proposed regulation has numerous shortcomings. For example an operator of a blacklisted website may file an objection against having his website blacklisted. However, the law does not provide any way of letting such operator know that his website is blacklisted in the first place. It is up to the operator to regularly check the register to see whether his website is there.
The new blocking mechanism will definitely have an impact on the market in Poland. Much will depend on how it will work in practice, however.
EEGReport Magazine: Do you think that anything will have changed regarding the way remote operators look towards the Poland online gambling market?
Piotr: Of course, the government’s view is that the new system will allow eliminating of illegal offshore competition and at the same time encourage the foreign operators to establish “official”, licensed businesses in Poland. Will the blocking system actually achieve such aims? Only time will tell.
What may affect the effectiveness of blacklisting measures is the blocking mechanism used. The government opted for a so-called “DNS blocking” technique. In practice, this means that from a technical perspective it will be quite easy to circumvent the blockade to gain access to the blacklisted websites (although it has to be noted that participation in unlicensed gambling is a fiscal crime in Poland and participants of illegal gambling may also face heavy sanctions).
On the other hand, the new payment blocking system may turn out far more effective, depending on how vigorously the authorities will enforce it.
EEGReport Magazine: If you could immediately change any law on gambling, as you would wish, what would that be, and why would you choose to change that?
Piotr: From a business perspective, it would be beneficial to allow the private sector to provide online gambling services to a wider extent – of course, in a secure, regulated manner. “Civilized” rules on online gambling would increase tax revenue while ensuring protection of players and would be more effective in combating the grey market than any other measures. Strict prohibition is rarely effective – we should learn this from the outcome of the Prohibition period in the United States. Very restrictive regulations usually lead only to growth of clandestine operations and only less legal certainty and security.
The Polish government doesn’t seem to understand this, even though there are studies available that in fact restrictive regulations are not necessarily helpful with tackling such issues as addition from gambling and other related threats. The Polish government presents gambling as a serious danger to the society, so it puts restrictions on the private sector. At the same time however, it plans to open thousands of state-owned slot machine parlors and run state-owned online casino and sees no contradiction in this.
EEGReport Magazine: In your expert opinion, what are the main challenges operators can face when entering the Polish market?
Piotr: Gambling regulations in Poland are very strict, probably one of the most restrictive worldwide. They ban a number of activities which are legal elsewhere, including other EU member states. Thus, the operators who wish to enter the Polish market should thoroughly and carefully review the legal landscape if they want to be compliant and avoid risk.
Unfortunately, there is also a barrier of entry to the Polish market in the form of high licence fees, complicated regulations and high taxes which makes it attractive only to large entities. Setting up a gambling business requires considerable resources.
There also is no specialized authority in Poland supervising the gambling sector, like the Gambling Commission in the UK. It is the Customs who are currently responsible for supervision of the gambling market. There are no official guidelines on interpreting the law available and the government’s stance also does not seem very friendly towards the gambling business.
On the other hand, Poland is a large market (approx. 40 million inhabitants) with considerable potential to grow. The latest changes to the law – although controversial to an extent – may expand the market at least for online betting.
EEGReport Magazine: What advice would you give to potential new entrants considering Poland (operators, affiliates, suppliers etc.)?
Piotr: Due to the upcoming changes to the law, caution is definitely advised for new entrants. It is definitely advisable to be up-to-date with the new laws especially in the near future, when they will begin being enforced in practice. “Interesting times” are definitely coming for the gambling business in Poland.
However, the new law does also create a lot of new opportunities, in particular for the suppliers of software solutions for gambling industry. Even though online gambling will be controlled by a state owned company, that company will still need third-party suppliers – such as software developers – to launch its services. There will soon be thousands of new slot machines on the market – the state company will definitely look for someone to produce, equip and service them.
There are more examples of such new opportunities. The new law introduces betting on so-called “virtual events”, a new form of betting already popular in many other countries like Italy or UK. This of course means that betting operators will need new software soon. It will now be legal to advertise betting – this makes it much easier to enter the market for new betting operators, but it will also generate income for advertising agencies.
EEGReport Magazine: Looking further afield, where are the major emerging opportunities in Eastern Europe for operators at this moment?
Piotr: I don’t think there is a single trend in Eastern Europe as concerns the approach to regulation of gambling. It seems that different countries are trying to regulate the gambling business in their own ways, choosing different models. Some countries seem to understand the benefits of controlled liberalization of gambling and try to monetize on this, whereas others, Poland included, still try to remain as prohibitive as possible. Time will tell which approach is better and more effective.
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