Border control: The SGA’s Camilla Rosenberg talks safer gambling and quelling the black market

Consumer protection is a top priority in Sweden, and when it comes to online gambling the situation is no different. The Gambling Act, introduced on 1 January 2019, was brought in by the government to address that exact issue: to bring order to what was a long-established grey gambling market and strengthen protection for consumers.

While the Scandinavian country is renowned for its stringent regulations, especially during Covid-19 lockdowns, Sweden’s gross gambling revenue (GGR) for the total regulated market in Q1 2022 was up 4.8% year on year (YoY) to SEK6.5bn, but remained at the same level as before re-regulation in 2019. However, Spelinspektionen’s director-general, Camilla Rosenberg, is quick to point out to EGR Intel that growing GGR was never an objective of the re-regulation, nor was it to increase the number of gamblers in the Swedish population.

Here, Rosenberg shares insights on how the gambling market has evolved since she joined the Swedish Gambling Authority (SGA) in 2017 and the importance of a dialogue-focused approach with the industry’s trade bodies as well as operators.

EGR Intel: How has the Swedish online gambling market changed since its re-regulation in 2019?

Camilla Rosenberg (CR): The year of 2018 was really an all-time high when it comes to advertisements in traditional media. And that was the year before the re-regulation. Now, gambling advertisements in traditional media have decreased. So, we assume that more and more ads take place on social media and through sponsorships if we compare it to 2018.

The main objective of the re-regulation was for unregulated online gambling operators targeting Sweden before 2019 to apply for a licence. By 1 January 2019, most of the known operators had actually applied and we had the licences in place by the start of the year. So, the goal to create better opportunities to control the market and establish a high level of consumer protection has been achieved through the re-regulation, even though there is more to be done, especially when it comes to excluding operators without a licence from the market.

Also, we have been working hard to ban a lot of operators from targeting Sweden without the necessary licence. We had gathered a lot of information over the years but now, three-and-a-half years into the new regulation, we don’t get that much information anymore on many new operators targeting Sweden without the necessary licence.

In spring this year, we had dialogue meetings with a number of operators from all verticals and all of them are very pleased with the regulation in general. For us, that’s another sign that the regulation has been working, even though there is more to be done.

EGR Intel: What kind of changes have you overseen since you became director-general in October 2017?

CR: We’ve been working through constant changes and towards a moving target for the past five years. It has been difficult to plan for supervision activities since we didn’t know what to expect from the operators when it comes to compliance. One should not underestimate the pressure when it comes to implementing comprehensive and rapid changes in the market. You can accomplish a lot in an extremely short amount of time but it cannot be perfect from day one.

We have increased the number of employees by about 50% at the authority, launched a self-exclusion register, Spelpaus, and developed cooperation with other authorities, both nationally and internationally, when it comes to supervision. We have also been evaluated by the Swedish Agency for Public Management since the re-regulation started.

When we look at court proceedings, almost all decisions regarding sanctions have been appealed by the operators without exception. We have had about 45 ongoing court proceedings at the same time. And of course, the legislation is new and the industry claims that the regulation is unclear and guidance is lacking. But we have seen several judgments and decisions from the Supreme Administrative Court lately and we will shortly be in a position to summarise the legal situation and issue further guidance. But the courts have shared the authority’s assessment that violations of the regulation have been committed.

EGR Intel: Sweden is considered one of the stricter European online gambling markets due to bonus and deposit limits introduced during the Covid-19 lockdowns as well as hefty fines handed out to those who break the rules. Is that a fair description?

CR: I think compared to other European gambling markets, the regulation in Sweden has a very strong emphasis on consumer protection, responsible gambling (including duty of care) and fighting to stop match-fixing. To understand that fully, you need to know that consumer protection has always been of great importance in Sweden in several areas, both for the politicians and for the public in general. Parliament has agreed on these matters and it’s also reflected in the new regulations.

EGR Intel: How did the Covid-19 restrictions on online gambling impact the sector?

CR: We, as the authority, were given an assignment by the government to evaluate these temporary regulations. Our report was out in March this year and we summarised that it was very difficult to assess which parts of the developments were due to the temporary regulation, the pandemic or the re-regulation of the gambling market in 2019 since all factors interacted. So, we concluded that it’s not possible to determine what the development of gambling would have been if the temporary regulations had not been introduced. Another conclusion from our report is that it may be preferable to tighten the measures within the area of ‘duty of care’ to increase consumer protection if a similar crisis was to occur.

EGR Intel: The goal for channelisation was 90% but casino operators and the online trade body BOS say casino is around 70%-75%. Are they right and, if so, how can this be improved?

CR: We are using a definition used by the government and the Swedish Agency for Public Management. They have been evaluating the re-regulation of the market during the past three years. We acknowledge and are fully aware this is not an exact science and also that the channelling rate is likely to vary for different verticals. The government’s goal for the channelisation rate refers to all gambling that is subject to competition under the new legislation. So, it’s probable the channelisation rate varies for individual verticals but the actual rates are difficult to estimate. We also think this can be improved. We are eager to know the exact channelling rate, hence why the casino operators are speaking about their verticals but the government’s goal is for the entire market.

EGR Intel: How will the B2B licensing plans help boost channelisation?

CR: By introducing the B2B licensing, the availability of gaming software for unlicensed operators is expected to decrease and thus the channelisation is expected to increase. A B2B company with a licence is prohibited from providing gaming software to an unlicensed operator. Also, that B2B company risks losing its licence with the Swedish Gambling Authority if it does so.

EGR Intel: Over 78,000 people are using Sweden’s self-exclusion system, Spelpaus. How effective has it been? The SGA’s 2021 annual report mentioned a new system for Spelpaus was due to be operational in summer 2022. What has the change in system involved?

CR: A new supplier of Spelpaus was procured last year. The demands on the system when it comes to robustness and availability are extremely high. The total number of requests to Spelpaus from licence holders is unbelievable – 41.5 billion since the start. The new Spelpaus was up and running as planned at the end of May and we are also planning to increase the dialogue with licensees. That is to achieve high operational reliability and improve the system further.

The major change in the system was the possibility for users to extend the time for self-exclusion during the ongoing exclusion period. We have added more information on what measures can be taken if players need help with gambling addictions and to prevent problem gambling. We are promoting Spelpaus on an ongoing basis on social media to increase awareness of the system in connection with major sporting events. But we do need, however, to look further into how to prevent players from going to unlicensed operators after they have signed up for Spelpaus. That is an issue that has been discussed in Sweden by the licence holders, the gambling addiction treatment organisations and the authorities.

EGR Intel: The 2021 annual report stated the SGA has prioritised increasing its knowledge of match-fixing. Can you elaborate on what this has involved?

CR: We are awaiting new legislation regarding match-fixing so we can exchange more information between the SGA, members of the Match Fixing Council and other stakeholders. So, that’s one missing piece in the regulation that we are still waiting for.

Last year was actually the first year of mandatory reporting of suspected match-fixing for Swedish licensees. And that was to inform us as the authority about suspected fixed matches, which has given us a good basis for further dialogue. We are working closely with the trade bodies BOS and SPER, the Swedish Sports Federation, the police and the prosecution service to discuss how we can be more effective and have operational cooperation. The dialogue has continued and is ongoing to clarify different needs as well as further explore the legal possibilities to exchange information, which we don’t have at present.

The SGA has seminars arranged by the Match Fixing Council. We have also shared experiences internationally and in the framework of the cooperation in the Group of Copenhagen. In addition, we have recently finalised the procurement of an information service from Sportradar. So, there is work underway which will be ongoing but more needs to be done in that area.

EGR Intel: How often do you engage with operators and trade bodies such as BOS and SPER to discuss current issues in the online gambling market?

CR: We have meetings on a regular basis, about once a month, with BOS and SPER to exchange information regarding the development of the gambling market and to discuss improvements. We have conducted several meetings with a number of licensed operators this spring, representing all licence forms. We have discussed issues and reflected on the first three years of the regulated market, the pandemic and how it has affected the industry, as well as future challenges. These have been really interesting and informative meetings from our point of view and we are very much looking forward to future meetings with more licensed operators this autumn. We have opted for a more dialogue-oriented approach, which is something the industry has expressed several times there is a need for.

EGR Intel: How can Sweden ensure a gambling market that is sustainable in the long term?

CR: I think both regulators and operators must keep customers within the regulated environment. Our common objectives should be a well-functioning gambling market within the licensing system with operators being compliant. I have divided it into a challenge for the industry. That is, in my opinion, for them to think long term. We have, for several years now, viewed the annual survey carried out by Svenskt Kvalitetsindex on customer satisfaction that reveals the gambling industry in Sweden has a very low reputation. So, it is important for the industry to improve its reputation, build trust and dare to change.

Responsible gambling measures will be more important in the future for the reputation of the industry. Our challenge is to make sure licensees within the system are compliant to ensure consumer protection and fair competition. At the same time, we need to focus on closing out operators targeting Sweden without the necessary licence. We must work with both areas and not look the other way if we find violations of the regulation within the licensing system. We also need to better understand the driving forces of the customers who choose unlicensed operators and take the right measures to keep them within the licensed system.

EGR Intel: What are your expectations for the Swedish online gambling market?

CR: Even though the new regulation has only been enforced for three-and-a-half years, we are awaiting new and additional regulation. A decision is due in the autumn from parliament regarding the Swedish gambling market and B2B licences, among other things. We’re also awaiting the next step when it comes to the inquiry regarding match-fixing and illegal gambling.

I’m personally very optimistic for the future development of this market. The licensees are very pleased with the re-regulation but we are waiting on these missing pieces. This additional legislation, I think, will be taken care of. In short, we are all ready for the next step towards a well-functioning gambling market in Sweden.