Finland’s gambling reform sparks debate over AI safeguards and risk of players shifting to illegal operators

Finland’s sweeping plans to reform its gambling system are facing mounting criticism from legal experts and harm prevention organisations, as discussions intensify under the consultation process led by the Gambling Harm Risk and Harm Assessment Group within the Ministry of Social Affairs and Health.

Legal firm Nordic Law has strongly criticised the government’s position on artificial intelligence, arguing that the draft legislation fails to properly recognise the sophistication of modern machine learning systems designed to identify at-risk gambling behaviour. The current proposal claims that predictive models have not yet reached a level of reliability sufficient to play a major role in meeting statutory compliance requirements. However, Nordic Law maintains that this conclusion is not supported by independent evidence and instead appears to be based on internal policy assumptions rather than objective analysis.

The firm has called on regulators to take the opposite approach by actively encouraging gambling operators to invest in AI-based player protection tools. It has proposed that license holders should be required to develop AI-driven risk detection systems and submit detailed documentation and reporting to authorities, rather than regulators minimising the importance of such technologies in compliance.

In addition to concerns over artificial intelligence, Nordic Law has also raised alarm over the potential impact of strict regulatory measures on market channelisation, which refers to directing players toward licensed operators. The firm warned that the combined effect of multiple restrictions—including a ban on affiliate marketing, stricter controls on social media promotion, a prohibition on bonus play money for customer acquisition, and a total ban on cryptocurrency gambling—could unintentionally push consumers toward unlicensed and unregulated platforms. According to the firm, policymakers have not adequately evaluated the overall impact these combined measures could have on channelisation rates. Nordic Law has therefore recommended that some of the proposed restrictions be introduced gradually to allow for proper assessment and adjustment.

Another controversial aspect of the reform is a proposed loss limit of €25, which critics have described as unrealistically low. Opponents argue that frequent intervention messages and warnings tied to such low thresholds could reduce their effectiveness over time by desensitising players. Nordic Law has also questioned whether a planned ban on gambling marketing aimed at individuals aged 18 to 24 could raise constitutional concerns, particularly in relation to protections for freedom of expression.

At the same time, other organisations have voiced support for stricter consumer protection measures. Both the Finnish Competition and Consumer Authority and the national gambling harm support service Peluuri have endorsed stronger centralised loss limits. They argue that operator-specific monitoring systems are insufficient because they cannot effectively track gambling activity across multiple platforms, limiting their ability to identify patterns of harmful behaviour.

The ongoing consultation highlights a wider debate unfolding across Europe, as regulators attempt to balance precautionary harm prevention measures with the realities of an increasingly digital gambling landscape shaped by data analytics, artificial intelligence, and intense competition between licensed and unlicensed operators.

By fLEXI tEAM