January 19, 2024
We recently wrote about how iGaming Ontario is looking to build a centralized self-exclusion solution so that people in that province can opt-out of the ability to play across all of its operator gambling platforms in order to minimize harms. Centralized self-exclusion platforms are growing in numbers across the world's regulated igaming and online sports betting markets. We want to highlight the best examples of these in the world and compare them to the current Canadian context.
However, centralized self-exclusion registers are a relatively new addition in many regulated markets, even in very mature ones. Australia for example, which has had regulated online sports betting for over 20 years, only instituted a national self-exclusion register in August of 2023. For some nations that have a centralized self-exclusion solution, the associated statistics may not be published in a frequent manner, if at all. Thus, it can be difficult to measure the success of a given jurisdiction's implementation.
Australia does publish their numbers frequently, but their solution is so young, it is too early to make any judgments about it. The markets with more mature solutions that have been in place long enough to warrant judgment and which publish data that we will examine, are Denmark, Sweden and the UK. We'll look at the latest numbers and the self-exclusion solutions themselves, then compare their results to those we can find for the self-exclusion platforms and numbers in the unregulated Canadian markets of British Columbia, Alberta and Quebec.
With a population of 5.9 million, Denmark is home to a regulated market for online gambling that is very similar to the iGaming Ontario market. There are over 40 Danish igaming license holders which combined, operate well over 100 brands. Denmark has a very good, if perhaps not the the best self-exclusion system, from our perspective. They have a central self-exclusion register, but it is not as frictionless as we would like to see, as it is not directly integrated into the interfaces of Danish igaming sites and apps.
At a given Danish gaming site, a person may self-exclude from that operator, but this action to self-exclude at the one site does not directly carry over to the centralized self-exclusion system. The operator simply notes as an aside how a player may go about doing that within the national self-exclusion register, known as "ROFUS", with links to that website. This is not ideal, as it adds friction to the self-exclusion process for players. Ideally one action toward self-exclusion on any Danish gaming site should take effect across all brands and sites in the market.
Despite this drawback, the Danish system does well in another area. Crucially, players may self-exclude at ROFUS with their "MitID", which is an ID number that all Danes have, in order to access national digital services including gaming sites. Thus, regardless of the contact information used to establish a given gambling account, in using this point of ID, it is very difficult for a player to circumvent the self-exclusion by simply trying to register a new account with a different email address or mobile number. This is very important, given that a person in crisis may certainly seek ways to gamble once they've self-excluded. Despite the friction in the system, in early 2023 the Danish gaming regulator reported that 40,000 Danes had self-excluded from gambling, which is about seven tenths of one percent of their population (0.7%).
Sweden has the best integration of self-exclusion and harm reduction tools that exist in any market today, which we have outlined already in some detail. To briefly summarize why we feel this way, there are three main reasons.
Firstly, like Denmark, Sweden uses a national form of ID for association to player accounts, which makes player circumvention of the self-exclusion extremely difficult. Secondly, very prominently, not buried in the footer of the site or app, across the top of every regulated Swedish igaming site page or app, players have access to three buttons to access their relevant problem gambling tools. One button allows players to access a self-test to help identify potential problem gambling behaviours. One button allows access their play time, loss and deposit limit settings. One button allows access their self-exclusion settings.
Thirdly, and crucially, the limit and self-exclusion tools are directly linked to a given player's universal profile, so they come into effect across the entire ecosystem of Swedish gaming sites, not just for the site they are on. So if they set a limit and reach a limit, or self-exclude while on one site, then go to another site, the limits or exclusions should already be in force at the next site. This is an incredibly powerful concept and implementation in order to prevent gambling harms in a robust manner.
In other words, at all times, players in Sweden have constant, direct access to these key tools to prevent harm. Different from Denmark, when a user in Sweden looks to use the self-exclusion functionality on any of these operator platforms, they are instantly added to the centralised self-exclusion registry. There is no separate register and there is no separate process. Sweden's central self-exclusion system is completely and directly integrated into each and every igaming platform itself. This prominently placed and essentially friction-free approach to player-set limits and self-exclusion is the key to the success of this program in Sweden. With a population of 10.6 million people, the Swedish gaming regulator reports that over 104,000 people had self-excluded, or nearly one per cent of the population (1%).
The UK is likely the most saturated igaming market in the world, with over 120 operators, and even more brands. The UK does have a central exclusion system, but to our mind, it is well behind both Sweden and Denmark in the two most important ways. First, the "GAMSTOP" program is not directly integrated into the given gambling site, nor is its logo with web link prominently placed to be noticed by players. Notices and access to GAMSTOP are generally found at the bottom of the given gaming app or site, among several other payment method, compliance or jurisdiction logos, where it can be easily overlooked by players. In other words, a player in the UK really has to go looking for this resource.
Second, if a player has found the GAMSTOP site to move toward self-exclusion, the player must submit a list of all the points of contact, that might have been used in the past to register with gaming operators, like email addresses, postal addresses and telephone numbers. Unlike Sweden or Denmark, the UK does not use a national identification number within its igaming ecosystem. This can allow for players in crisis to more easily circumvent their self-exclusion. What if a player creates a new email address, or gets a new mobile number, or lives at a new address? If they do, there is a high risk that the player will be able to circumvent their self-exclusion. This is the problem of a self-exclusion system that does not use a form of national ID in its player verification, which will allow for many at-risk players to fall through the cracks and easily defeat the system that is meant to protect them.
While we can't see just how many UK players are falling through the cracks, we can see the result of a program that is neither prominent in placement at its associated gaming sites, nor is it integrated directly in a friction-free manner to the self-exclusion registry. At the end of 2022, GAMSTOP reported that over 341,000 people had self-excluded. The 2022 UK population was about 67.5 million people. This means that about one half of one percent of the population had self-excluded (0.5%), which is well behind both Denmark and Sweden, that both have similar markets in terms of operator numbers, but have far more robust and prominent self-exclusion systems.
While we do not yet know which of these three centralized self-exclusion systems might most closely resemble the one to be built in Ontario, regardless, it will be an order of magnitude more effective than those that currently exist in other Canadian provinces. The great weakness of self-exclusion programs in Canadian provinces outside Ontario is that by definition, they are so narrow, since there is no regulated market. The current "grey market" is where most of residents of these provinces play online.
Current exclusion programs only apply to gaming operators under their direct jurisdiction - the local bricks and mortar casino, slots and bingo locations, and their online lottery and igaming platforms as operated by the respective provincial gaming monopolies. This means two things: Firstly, since very few people use the respective provincial igaming platforms compared to the "grey market", very few people will actually look to make use of the current self-exclusion programs, hence the low figures to come below. Secondly, through the self-exclusion, only one website that is available for play, will be made unavailable, leaving the entire "grey market" open for those at risk.
What good is a self-exclusion program that protects at-risk players from playing at but one of two thousand available gaming sites? Let's see how Canada's largest three provinces outside Ontario are doing on self-exclusion, without a regulated market.
In British Columbia, at the end of the 2023 fiscal year, BCLC reported that just 2,764 people had self-excluded via PlayNow.com, their online gaming platform. In a province of 5.5 million people, this is an incredibly small proportion of self-exclusions. Even with the problems of the UK system in terms of ID verification, program prominence and lack of registry integration with gaming sites, if BC had a regulated market and could share the UK's "not-so-great" rate of exclusion of roughly one half of one per cent (0.5%), about 27,500 people could be self-excluded from most of the widely played BC betting sites, which are currently based offshore, but would be interested in local regulation, as they were for Ontario. This is essentially ten times the current BC self-exclusion rate, which would of course apply to against a market of dozens of operators. Thus, this would be almost immeasurably more effective than the current situation.
For a province that prides itself on being progressive, caring and inclusive, this is the shameful reality. If BC had a regulated market and a robust self-exclusion system like those in Denmark or Sweden, we could nearly fill BC Place (capacity 54,500) with the number of citizens that would be able to exclude themselves from online gambling related harms across the currently available offshore gambling brands that are interested in being part of a regulated market as per iGaming Ontario.
Alberta's most recent report at the time of writing, encompasses the results from the 2021/22 fiscal year, which included online self-exclusions on "PlayAlberta" of 5,700 players. With a 2023 population of 4.7 million people, if Alberta had a regulated online market and self-exclusion system, the number of excluded players would be much higher, and it would be in effect across most of the top currently "grey market" brands that serve the province now from their offshore jurisdictions.
With a regulated market of Alberta betting sites and online casinos in the mold of the UK, we could see a similar self-exclusion rate of one half of one percent of the population. This would mean nearer to 23,500 people could remove themselves from harm, across most of the "grey market" brands, where the majority of Albertans currently play online. Most of these operators have looked to become regulated in Canada, when given the chance to do so within Ontario.
If Alberta could implement a regulated market with a leading self-exclusion system, similar to Sweden, we could see a self-exclusion rate near one full per cent of the population. This could mean that we approach a figure of 47,000 Alberta residents that could significantly reduce gambling related harms. In other words, Alberta could be doing 4X to 9X better in terms of sheer self-exclusion registrations, and of course within a properly regulated market, more brands would be off-limits, not just PlayAlberta. Despite the clear and obvious benefits for the health of Albertans, leaving alone the incremental income regulation would bring to the province, there is no priority within the government to address this in Alberta.
Finding self-exclusion stats worth talking about for Quebec has been a difficult task. We find no resources quoting these figures on Loto-Quebec's own site or within their various reports. We have seen some figures associated to a Quebec online self-exclusion figure in the region of 7,000 people, listed on various igaming affiliate marketing sites, but these figures were not linked to a Loto-Quebec source document. We cannot speak to the veracity of this figure, however, given the low self-exclusion figures reported in similar gaming monopolies in BC and Alberta, it would not surprise us if this sort of figure for Quebec was genuine.
Given Quebec's 2023 population of 8.8 million, if it had a regulated online gambling market and central self-exclusion platform, the number of self-excluded players would again, be far, far higher. With a system like the UK, which is less prominently marketed, less robust and full of friction, at a 0.5% exclusion rate, we could see 44,000 Quebecers that might remove themselves from the harm associated with a large swath of online gaming brands that otherwise serve that province from the "grey market", yet have looked to be regulated in the Ontario market.
If Quebec were to implement a market and self-exclusion system that is as robust and frictionless as that found in Sweden, Quebec could see as many as 88,000 people exclude themselves from these gambling sites and the associated harms. In other words, a regulated market and associated centralized self-exclusion system of Quebec betting sites would allow anywhere from five times, to over ten times the number of people that may be made safer, relative to gambling harms, as compared to the current situation of a Loto-Quebec monopoly, mixed with an unregulated "grey market".
The numbers are pretty stark. A strategy for self-exclusion in an ecosystem that pits one official monopoly operator against an unlimited number of "grey market" operators, is no strategy at all. Not only are the self-exclusion numbers in British Columbia, Alberta and likely Quebec, exceedingly low, we know the entire premise is flawed, given that so many alternate online gambling options are available to players in these provinces. Through regulation in Ontario, most international operators that had previously served the province prior to regulation, were made to choose to get a license, or stop serving Ontarians.
The reality is that a huge number of brands that decided not to get a license, have indeed respected the laws of Ontario and have stopped serving their residents. In this way, Ontario's regulation will make a centralized self-exclusion system even more effective, since there are far fewer operators that might offer a self-excluded player a route to circumvention. While Ontario players can indeed find now "black market" online gaming options, it is far, far easier for players to be funneled or channeled into the regulated system of licensed operators, and the eventual centralised self-exclusion system which should actually "have teeth".
Given the exclusion rates we've quoted for the UK, Denmark and Sweden, with the 2023 Ontario population of 15.5 million, we could see anywhere from 77,500 to 155,000 at-risk Ontarians able to exclude themselves from the harm associated with the 70 or so legal Ontario gambling options. Plus, with regulation of the market, scores of formerly "grey market" brands that did not gain a license now refuse to serve anyone in Ontario.
Think of how many online gambling brands now thus will not serve a problem gambler in Ontario, simply because of where they live, regardless of their propensity to experience harm. It's a huge number, so this is of considerable importance in terms of harm reduction, yet it is something that is rarely highlighted. The general public and members of the general media would rather complain about too many sportsbook ads during Hockey Night in Canada, than understand what has actually developed behind-the-scenes, in a far more impactful regard, which is all due to the regulation of the Ontario market.
Forget about the benefit of incremental tax income that would accrue from regulated online gambling. Why are Canadian politicians in other provinces not taking the simple steps to follow Ontario and other successful national jurisdictions on this matter, to make tens of thousands their own citizens safer, and insulated from gambling harms, given the realities faced in competing with the "grey market? The game plan is so simple: regulate your provincial market. Nothing groundbreaking has to be done. Yet here we are, no further forward on igaming regulation outside Ontario.
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