Belgium’s largest gaming operators say Europe needs stronger coordination on player safety but warn that a pan-EU licence would spark a “race to the bottom”.
A call for protection without deregulation
As Europe edges towards a common standard for monitoring gambling harm, Belgium’s BAGO association is urging Brussels to prioritise player protection over market liberalisation and to resist pressure for a so-called European “passport” for gambling licences.
Talking to SiGMA News, the association said its priority is not harmonising licences across Europe, but ensuring a consistent level of safety for players wherever they gamble. BAGO “advocates for a unified, outcome-driven approach to player protection across Europe, emphasising that all players should benefit from a consistently high level of security regardless of their location.”
The association argues that European coordination is needed, but only on the goals that matter most for consumers, not on market access.
“The principle of the free provision of services ensures that any European company can apply for a licence to operate in any Member State. It does not, however, grant unregulated access. The market is open but regulated, and the freedom to provide services comes with the responsibility to meet the specific legal and player protection standards set by each host country.”
This, BAGO insists, is a crucial distinction: harmonisation of standards, not harmonisation of licences.
Rejecting an EU ‘passport’, fear of ‘race to the bottom’
With cross-border legal disputes mounting, especially between Malta and Germany or Austria, some industry voices are calling for a “European licence” that would allow operators authorised in one Member State to operate everywhere in the EU by default. BAGO opposes that direction.
The group warns that a single licence would amount to deregulation by the back door. “Given the significant social and cultural differences across the EU, a single European passport for gambling is not a feasible or desirable solution. Such an approach would likely trigger a race to the bottom, undermining national safety standards, and causing a loss of national sovereignty and control over a vital public health and taxation level.”
Instead, BAGO wants the EU to focus on the outcome: players being safe, harm being prevented and the illegal market being squeezed out. One proposed tool is a measurable target for channelisation (the percentage of gambling done with licensed operators). The association explains that “a target like an 85% minimum channelling rate would serve as a quantifiable metric”, forcing Member States to demonstrate that legal offers are both safe and attractive enough to keep players out of unlicensed environments.
Suppliers and payment providers in the spotlight
BAGO also argues that the most effective enforcement lies not only at the licensing level, but in regulating the gaming supply chain itself, particularly technology and payments.
The association calls for EU policy to “shift towards regulating the supply chain by enforcing compliance on service providers. This means mandating B2B suppliers to serve only licensed markets and requiring banking and payment systems to actively block transactions for illegal gambling.” By targeting intermediaries, the industry says, illegal sites would simply be starved of services.
This approach is partly a response to the legal rifts playing out across the bloc. In recent years, German and Austrian courts have ordered Malta-licensed operators to refund some players’ losses, while Malta has responded with legislation shielding operators from foreign rulings. The Belgian position is that instead of trying to uproot licensing frameworks country by country, Europe should starve unlicensed gambling of infrastructure.
Turning markers of harm into practice
Beyond the legal structure of the market, the association is pushing for a European baseline on responsible gambling standards. BAGO strongly backs the adoption of the new “markers of harm” developed by the European Committee for Standardisation, data-driven behavioural indicators that help detect risky play earlier.
“These European markers of harm standards provide a unified objective science-based framework for national implementation,” BAGO says. The association adds that it already “implements these standards” through its Duty of Care charter and believes the EU should use them to build a “baseline of protection standards across all member states”.
BAGO now wants these same principles to underpin exclusion systems. It says it “supports the sharing of self-exclusion registers among European member states”, so that players who block themselves in Belgium cannot simply cross a border to bypass the system. Belgium’s small size makes this especially relevant: “Belgians are therefore more impacted than other Europeans.”
Cooperation
The Belgian operators reinforced this stance in a recent press release following the approval of the European harm indicators at CEN. “The strengthening of European cooperation is essential for establishing consistent and transparent criteria for online platforms,” it said, adding that the new standard “provides operators with concrete responsible gaming tools that turn commitment into measurable action.”
The group signalled its intention to help members integrate the new system: “BAGO commits to actively supporting its members in integrating these indicators into their Responsible Gaming policies.” It also stressed that responsible gambling is not an add-on, but its core purpose: “A safe, fair and responsible gaming policy is at the heart of our mission.”
For Belgium’s licensed operators, harmonisation should raise standards, not strip them away. In other words, Europe should be a level playing field, not a lowest common denominator.
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