Finland’s responsible gambling draft may fuel black market
Finland’s newly proposed draft for responsible gambling recommendations is likely to discourage operators from entering the regulated market and pushing players towards unlicenced platforms.
This is the forewarning issued by Antti Koivula, Chief Compliance Officer (CCO) of Hippos ATG. In an interview with SiGMA News, as Finland prepares to open its gambling market to competition in 2027, Koivula stressed that the country’s proposed strategy for player protection might be counterproductive if implemented in its current form.
“There is no doubt whatsoever that overly strict rules will drive players to the black market,” Koivula said. “Overly strict rules will hinder operators’ willingness to come within regulation and favour the black market, which will not follow these rules.”
Uncertainty over new suggestions
The comments follow the publication of draft national recommendations on responsible gambling by Finland’s Ministry of Social Affairs and Health on 27 January 2026. The proposals were developed by the Gambling Harm Risk and Harm Assessment Group as part of the implementation of the new Gambling Act. However, experts have already started to flag concerns in the draft.
“Forced break increases the risk of customers migrating to black-market platforms that offer uninterrupted play,”
– Antti Koivula, CCO, Hippos ATG
The recommendations are now open for public consultation until 24 February 2026, after which they will be finalised. Although not legally binding, the guidelines are widely expected to influence forthcoming decree-level regulations and shape how Finland’s future gambling supervisor interprets the law.
Finland plans to replace its long-standing monopoly system with a multi-licence gambling market in July 2027. In the lead-up to that transition, operators and analysts are closely examining whether the proposed framework will support a commercially viable regulated market.
A centralised player monitoring
At the core of the draft recommendations is a proposed centralised, cross-operator system that would track player losses and spending across all licensed gambling operators. The system would monitor daily, monthly, and annual losses for every customer in the legal market.
Under the guidelines, players would receive automated pop-up notifications after reaching spending thresholds of €25, €50, €75, €100, and €200. The interventions would become progressively more intrusive as losses increase. Once a player reaches €100 in losses, their gambling account will be temporarily frozen. At €200, the account would be fully frozen and could only be reopened after direct personal contact with the operator.
Koivula said such measures could lead to repeated and disruptive interruptions for players, even at relatively low levels of spending. “Operators would be required to freeze player accounts once cumulative deposits or losses reach €100 and €200, resulting in up to four forced account closures within the first €200 each month,” he said.
He further added, “Such repeated interruptions are exactly the type of friction most players will not tolerate. Each forced break increases the risk of customers migrating to black-market platforms that offer uninterrupted play.”
Proposing heavy loss caps
The draft recommendations also propose firm annual loss caps. Adult players would be limited to €5,000 per year, while additional restrictions would apply to younger customers. Players aged 18 to 19 would face an annual loss limit of €1,800, rising to €2,500 for those aged between 20 and 24. Analysts say the age-based limits reflect a strong focus on harm prevention but may further narrow the appeal of licensed platforms.
Koivula does not dispute the importance of player protection, but argues that regulation must be proportionate if it is to achieve its intended goals. “Player protection must be strong, but proportionate,” he said. He warned that if legal operators are unable to offer products that players find usable and attractive, channelisation efforts will fail.
“If regulation eliminates commercial viability, the regulated market fails its channeling and consumer-protection purpose,” Koivula said. Although the recommendations are formally non-binding, Koivula believes their influence will extend well beyond the consultation phase.
“Even without formal legal force, the recommendations will likely heavily influence decree drafting and supervisory expectations. With any rules, it should be kept in mind that we do not live in a vacuum where everyone obeys the rules,” he added.
Tackling illegal gambling: A necessity
He also stressed that tackling illegal gambling must be viewed as a core element of responsible gambling policy, rather than a secondary concern. “Effective black-market supervision is a de facto crucial part of player protection, which should always be kept in mind,” Koivula said.
Stakeholders have until 24 February 2026 to submit feedback on the draft proposals. With Finland set to open its gambling market in 2027, Koivula believes a key challenge for lawmakers is coming into focus: striking a balance between player protection and keeping the regulated market competitive enough to prevent players from drifting to unlicenced sites.
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