Operators Warn Finland’s Proposed Gambling Safeguards Could Drive Players to Black Market

Several international gambling operators have voiced strong concerns over proposed player protection rules in Finland, warning that overly restrictive measures could undermine the country’s newly forming regulated market by pushing players toward illegal operators. SkillOnNet and Wildz Group both argue that the proposals risk weakening channelisation by making licensed gambling less attractive than unregulated alternatives.

The concerns were raised in response to a consultation launched on 30 January by Finland’s newly established Gambling Risk and Harm Assessment Group, which operates under the Ministry of Social Affairs and Health. The consultation invited stakeholders to comment on a package of proposed consumer protection measures, with submissions accepted until 24 February. The feedback will help shape the regulatory framework for Finland’s reformed gambling market.

Among the most controversial proposals is the creation of a single, cross-operator loss limit register. Under this model, players would be subject to a unified loss cap across all licensed operators, rather than being limited individually by each operator. Additional measures under consideration include mandatory player control tools such as deposit limits, loss limits, and restrictions on playing time. Operators would also be required to enforce cooling-off periods, impose play restrictions, and block certain gambling functions in specific circumstances.

In its consultation response, SkillOnNet, which operates brands including PlayOJO, warned that a low cross-operator loss limit could have unintended consequences by driving players away from licensed platforms. “A forcibly closed gaming account is always a negative customer experience,” SkillOnNet said. “Every time a customer is directed to look for a new gaming location, the risk of finding a site operating outside the system increases.”

The company argued that deposit and gaming limits cannot be viewed in isolation and tightened aggressively when the broader Gambling Act is already largely finalised. It cautioned that strict deposit limits, when combined with the new legislation, would increasingly push players beyond the regulated system and into the black market.

Wildz Group echoed those concerns, stressing that the impact on channelisation must be carefully evaluated before introducing rigid limits. The operator, which runs the Wildz Casino brand, pointed to research from Germany showing that in markets with particularly strict limits, only around 20% to 30% of gambling activity was channelled through licensed operators. “If the restrictions presented in the recommendations were applied in Finland without an assessment of the channelling effects, it is justified to assume a similar outcome,” Wildz said.

SkillOnNet went further in its criticism, warning that excessive protection requirements could backfire by discouraging consumers from using licensed services altogether. It argued that gambling on regulated platforms should be clearly preferable for players. According to the operator, gambling on a licensed site should be “more attractive, more sensible and smoother for Finnish consumers than gambling on an unlicensed site”.

The company also suggested that regulatory focus should shift away from further limiting licensed operators and toward tackling illegal gambling activity. “In licensed gaming, resources should be directed to ensuring that licensees adhere to their own duty of care and report on it actively, that the restrictions set by the players themselves are adhered to and that the national gambling ban register functions flawlessly,” it said.

SkillOnNet added that one of the reasons for opening the Finnish market was the limited reach of the current monopoly operator, Veikkaus, which it said accounts for only about 50% of the market, with the remainder dominated by offshore operators.

Beyond loss limits, the Gambling Risk and Harm Assessment Group has also proposed a tiered intervention model. This would require operators to continuously monitor player behaviour, define specific risk indicators, document intervention measures, and keep detailed records of customer contacts and outcomes. The group also recommended classifying young adults aged 18 to 24 as a “high-risk” demographic, which would trigger lower thresholds and stricter protective measures for that age group.

The proposals also include a cautious stance on the use of artificial intelligence in safer gambling systems. The group warned against relying too heavily on AI and machine-learning models for harm prediction, stating that such technologies remain “still immature” and should not be the primary mechanism for protecting players from gambling-related harm.

At the time of writing, SkillOnNet and Wildz Group were the only operators to have submitted formal opinions as part of the consultation. Any new player protection measures will be incorporated into Finland’s wider gambling legislation, which was approved in December. The rules will apply to all operators that obtain a licence under Finland’s restructured gambling system, which will open to a broader range of licensed iGaming operators for the first time.

Applications for licences are set to open in March this year, although the government has yet to finalise all safer gambling requirements. The launch of Finland’s new regulated gambling market is currently scheduled for July 2027.

By fLEXI tEAM