SBC Summit preview: Miguel Luis of Lebull says Portugal must learn RG lessons from other markets
Responsible play is one of the most important elements of online gambling today that all industry stakeholders must play a role in upholding to the highest standards.
This was the topic of discussion with Miguel Luis, Head of Compliance at Lebull, who spoke to iGaming Expert ahead of the SBC Summit and the Affiliate Leaders Summit, which takes place this September in Lisbon.
iGaming Expert: What challenges do operators face in balancing responsible gambling efforts and optimising the player experience?
Miguel Luis: The biggest challenge is to maintain an engaging and frictionless experience while protecting the player from risky behaviour. The most common responsible gaming measures, such as wage, deposit or loss limits, are often seen by players as an “interference” in their leisure time.
The risk here is that if the tools are too intrusive or poorly communicated, they can lead to frustration, or even lead the player to seek out unlicensed sites that do not adopt these practices, or that can be easily removed, without waiting periods.
In addition, operators face regulatory and reputational pressure, often being held accountable for individual behaviours. This requires a preventive approach, supported by technology: AI-based / machine-learning behavioural monitoring systems that detect problematic patterns, alert the operator and trigger discreet but effective interventions, such as pop-ups with suggested breaks or personalised limits.
I believe the right balance involves investing in educational UX/UI, with elements that resonate with the players, creating experiences where RG tools are presented not as barriers, but as elements of value to the user, and especially where these can be communicated as something good and at the reach of the player, not just as something “there”, or unilaterally imposed on the player.
iGX: What role do game suppliers play in upholding responsible gambling principles, and how can they work with operators to improve their understanding of responsible gambling efforts?
ML: Suppliers should not only be creators of engaging content but also central players in promoting safe gambling.
This involves various aspects. A starting point can be developing games with responsible design, where volatility is transparent, wins and losses are clearly explained, and reward mechanisms (such as free spins or jackpots) do not encourage compulsive cycles. But it can also include visual elements such as session time messages, loss reminders, balance counters and real-time counters. Last, but not least, it can involve allowing the operator to set features such as “in-game limits” or mandatory breaks after a certain time.
Operator-supplier collaboration can be enhanced through joint efforts, namely workshops on player behaviour, integrating real-time data, so operators can make informed decisions about games or risk profiles, or even joint certifications (e.g. through iTech Labs, eCOGRA, GamCare) demonstrating compliance with RG practices.
Suppliers should also be open to adjusting games based on real behavioural data. For example, if a game shows potentially problematic usage patterns, it can be re-evaluated or adjusted in partnership with the operator.
But above all, suppliers should, together with the other stakeholders, help provide education on healthy gaming habits, thus improving the proactiveness, reducing the need for reactiveness of this type of measure.
iGX: What personal responsibility does the player hold to educate themselves on how to play responsibly and maintain their well-being while participating in gambling?
ML: Players have an active and crucial role to play: educating themselves about the risks, recognising warning signs, and using available risk management tools. However, it is important to understand that most players do not perceive themselves as “at risk”, especially those who are in an early stage of dysfunctional behaviour.
Still, I believe this is transversal to many other activities and aspects of life, e.g. it’s hard to conceive starting to invest in something without educating yourself properly on the matter/product, or when buying something, etc.
Therefore, personal responsibility should be encouraged but not imposed in a guilt-ridden way. Operators can aid by providing accessible and ongoing educational content, not only in the risk management section, but integrated throughout the player’s journey, or even create interactive and gamified tests for self-assessment. An interesting approach can be the highlight of real stories of recovery and psychological support.
At the end of the day, outside of some special cases, the player is responsible for their actions and should seek to get proper education and information on the activity that they’re doing. Nonetheless, operators should give easy access and ensure that relevant and easily understandable information is given to the players.
iGX: How can the different stakeholders involved in the debate work together more effectively to strengthen responsible gambling measures?
ML: The effectiveness of responsible gambling measures depends on true cross-sector collaboration, in which all stakeholders recognise that no one can solve the problem alone.
Examples of successful collaboration can include regulators that promote dynamic guidelines based on scientific evidence, rather than just legal enforcement. It can also be operators that share anonymised data with researchers and NGOs, helping to map risk patterns.
Technology providers that develop algorithms for the early detection of harmful behaviours, integrated with CRM and support, are another example. Public health entities that train customer support teams to recognise signs of addiction, how to handle them and guide players can be a good example. Lastly, industry associations that create common codes of conduct and voluntary certifications have been well accepted as well.
A good example to follow would be the creation of a national RG platform, with cross-data (anonymised) between operators, promoted by the regulator, and with the presence of academic and clinical partners.
iGX: What RG tools do you believe resonate with players, and what aspects of player data should operators focus on to deliver more effective RG tools on their platforms?
ML: The most effective tools are those that combine practicality and behavioural intervention, such as voluntary limits (time, loss, deposit) with the option of gradual adjustments, avoiding impulsive decisions.
Personalised alerts, such as messages tailored to individual behaviour (e.g. “you’ve played for three hours today, do you want to take a break?”) seem to be well accepted. Lastly, as a more strict measure, Self-exclusion with fixed or indefinite blocking, integrated with shared databases, thus affecting all the operators, seems to be effective, albeit harder to implement at scale.
In terms of data, operators should focus on Gaming rhythm and frequency (very long sessions or with short breaks), Aberrant bets( sudden spikes in volume or frequency), the number of failed deposit attempts and the behavior after a significant loss/win (e.g.: trying to recover quickly with higher bets).
With this data, risk scoring models can be applied that trigger automated interventions or manual reviews by RG teams.
iGX: Looking more closely at Portugal, 2025 marks ten years since online gambling was regulated. How has the country’s market developed in this time, and what is its future outlook?
ML: Since 2015, the Portuguese market has seen steady growth. Stable growth in the number of licensed operators and the diversity of products. Gradual growth and maturity of the market, both from the operators and the players. This maturity of the market was also visible with the “gentleman’s agreement” of the manual on good practices in terms of publicity that is now in force.
Investment in digitalisation and mobile-first, with estimates pointing to more than 80% of accesses coming from mobile devices, is another reflection on the shaping of this market through the years.
The future points to an increase in the diversity of products, albeit this could be greatly improved, as the process is still rather slow and bureaucratic. Greater use of emerging technologies, such as machine learning, for early risk detection and for some functions that were being done manually.
Also, the expectations of the players, in terms of ease of access to the products and especially to the speed (e.g. deposits and withdrawals), have to be met by the operators. Portugal has the potential to become a case study for sustainable regulation if it invests more in collaboration with international stakeholders and player-centric innovation.
iGX: What can Portugal learn from similar markets, both in terms of market growth and responsible gambling efforts?
ML: There are several lessons to be learned from other markets.
In terms of growth, a good starting point would be ending the different tax models (casino vs. sports betting), adopting a common revenue model (currently only applicable for casino games), and abandoning the current 8% on the amount of the bet in force now for sports bets.
The inclusion of new regulated products (as I pointed out before) has increased revenue without compromising control. Both of these can greatly increase the attractiveness of the legal market and reduce unlicensed supply.
In terms of responsible gambling, mandatory use of behaviour-based interventions (e.g. blocking deposits after risk signals), data integration and requirement of certified training for support teams.
Don’t simply ban casino/sportsbook advertising, like we’re seeing things pointing in Brazil, instead opt for restrictions in specific situations/scenarios (like it was already done in Portugal with the “manual on good practices in terms of publicity”). It’s not hard to make some parallels with other outright bans in history where only the illegal side benefited.
Public investment in educational campaigns and information platforms for citizens should be paramount and is a great example to take from other markets. Portugal can also invest in school prevention programs, media campaigns and mandatory training in responsible gambling for all industry employees — something that is currently lacking.