Finland’s Responsible Gambling Draft Raises Black Market Concerns

As Finland plans the switch to an open market in 2027, it is feared that the proposed framework may discourage licensed operators and push players toward unlicensed platforms.

Antti Koivula, Chief Compliance Officer at Hippos ATG, tackled these concerns in an interview with SiGMA News. According to Koivula, the current proposals risk doing the opposite of what they intend. 

“There is no doubt whatsoever that overly strict rules will drive players to the black market. Overly strict rules will hinder operators’ willingness to come within regulation and favour the black market, which will not follow these rules,” he said.

Draft recommendations open for consultation

The Ministry of Social Affairs and Health published the draft recommendations on 27 January 2026. They were developed by the Gambling Harm Risk and Harm Assessment Group in preparation for the new Gambling Act. However, there has been a kick back from industry experts. 

“Forced break increases the risk of customers migrating to black-market platforms that offer uninterrupted play,” Antti Koivula stated. 

Public consultation runs until 24 February 2026, then the proposal will be finalised. While the recommendations are not legally binding, they are expected to influence future decrees and shape how the new gambling authority enforces the law. 

With the multi-licence market set to begin in July 2027, the draft has become a focal point for debate over whether Finland’s new model will balance consumer protection with commercial viability.

Centralised monitoring and forced interventions questioned

At the centre of the proposal is a mandatory centralised monitoring system that would track player losses across all licensed operators. The system would track losses for each customer daily, monthly, and annually.

Under the draft, players would receive pop-up warnings at loss levels of €25, €50, €75, €100, and €200. Once losses reach €100, the player’s account would be temporarily frozen. At €200, the account would be fully frozen and only reactivated after direct contact with the operator.

Koivula argues that these measures introduce repeated friction at relatively low spending levels. 

“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. 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.”

Loss caps and black market risk

The recommendations also propose strict annual loss limits. Adult players would be capped at €5,000 per year, while players aged 18 to 19 would face a €1,800 limit. Those aged 20 to 24 would be restricted to €2,500 annually. While these age-based limits reflect a strong focus on harm prevention, critics say they further narrow the appeal of licensed platforms.

Koivula emphasised that effective player protection must include realistic channelisation goals.

“Player protection must be strong, but proportionate. If regulation eliminates commercial viability, the regulated market fails its channeling and consumer-protection purpose,” he said. 

“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.

Furthermore, Koivula stressed that combating illegal gambling should be treated as a core part of responsible gambling policy, not an afterthought. The Hippos ATG executive believes that the final framework decided by lawmakers must balance player protection with a competitive legal market to prevent drift toward unlicensed platforms.