SBC News

The Dutch gambling regulator, Kansspelautoriteit (KSA), has cautioned operators to be mindful of the strategies they use to influence consumer behaviour, as this can swing both ways.

In a study commissioned by the authority, research firm Behavioural Insights provided an in-depth analysis of the behavioural influence tactics that Dutch iGaming platforms utilise.

The two main points considered were what kind of behavioural influence strategies operators have put in place, and in what way can these tactics positively or negatively affect the choices of players.

Methodology
Researchers tested a total of 21 online gaming platforms and 35 games shared between them, ensuring that their choices vary in game popularity, game variation, platform variation, as well as the “push factor” – meaning the prominence of incentives on offer to attract players.

The outcomes were segregated into two categories – ‘dark patterns’ and ‘bright patterns’. The former represents a conscious attempt to push a consumer’s behaviour against their own interest, “extracting as much data, money, and time as possible” from them.

Bright patterns on the other hand were described in the report as using the same influencing techniques to help consumers make well-informed choices, in addition to proactively safeguarding vulnerable groups.

To make the results easier for digestion, the research identified a total of six phases as part of the player lifecycle where such patterns can be identified.

These were the landing page, registration, homepage, the game setting itself, withdrawals, and account closing.

Dark patterns seen across the board
Dark patterns could be seen across each of the six stages. Unbalanced info, which fails to display important information about the product, was mostly observed in the game setting phase.

Friction, which the study says can unnecessarily obstruct the behaviour of players, was often present in the registration, game setting, withdrawal and account closing stages.

Although lesser in frequency, some operators also created a false sense of urgency across their landing and home pages, which the report says could lead to rushed customer decisions.

Most notable, however, was the ‘Habitual Behaviour’ dark pattern. According to the report, this is the category most likely to steer players towards problem gambling.

This pattern was frequently seen in the registration stage, home stage, and the game playing stage. It usually involves “conditioning” sound and visual effects to encourage gambling, as well as promotions incentivising large amounts of wagers.

Separately, bright patterns were also observed, with the most common types being self-exclusion options and safer gambling messaging. However, Behavioural Insights highlighted that the prominence and frequency of bright patterns were not correlated with those of the dark patterns.

Report to influence future policies
As a result of the study, the KSA will now launch its own proprietary investigation into the negative effects of the behavioural influence tactics described above. The regulator wants to establish any conflict with duty of care principles and potentially introduce tighter restrictions.

Michel Groothuizen, Chairman of the KSA, added: “At the KSA, we understand that online providers, like other commercial companies, look at what users do with their platforms and how they can steer that to their advantage.

“Thanks to this research, we know better how they do this, and we can also give more direction in the field of negative management and things we no longer want to see.”

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Glücksspiel (GGL), Germany’s Federal Gambling Authority, has warned the Bundesländer (federal states) to treat the threat of illegal online gambling as a serious public health risk.

The warning comes ahead of the GGL’s annual Gambling Addiction Action Day (24 September), with the regulator urging state agencies to scrutinise offers and advertising that promote unlicensed providers.

As Ronald Benter, CEO of the GGL, explained: “Illegal platforms do not offer effective player protection mechanisms. Anyone who plays there runs a significant risk of developing a gambling addiction.”

The Action Day is held under the patronage of Prof. Hendrik Streeck, the Federal Government’s Commissioner for Addiction and Drugs, and this year carries the motto “Gambling Harms – Recognise, Name, Avoid.”

The 2025 campaign includes a symposium for state authorities to exchange best practices in treating gambling harm, while also reminding consumers to consult the GGL’s whitelist of licensed operators under the Fourth Interstate Gambling Treaty (GlüNeuRStV).

Commissioner rings alarm on Gambling Addiction
As patron of the campaign, Prof Streeck used the Action Day to provide a stark update on gambling addiction. He noted that 1.3–1.4 million adults are already addicted, with a further 3.5 million at risk.

Around 600,000 minors live with at least one gambling-addicted parent, facing neglect, depression, anxiety, and financial insecurity. Streeck warned that gambling disorder remains one of Germany’s most common addictions, often hidden for years and devastating for families.

Yet headline figures mask a deeper challenge. Experts agree that Germany has significant liabilities in how it measures and interprets gambling harm. There is no academic consensus on how to separate play on licensed versus unlicensed sites, or how to quantify the true social cost.

GlüNeuRStV has no accountability
Nearly three years since the GlüStV 2021 came into force, the federal regime remains troubled by divisions on data and exposure to black market threats.

The GGL’s Third Annual Activity Report estimated that unlicensed operators accounted for 25% of the online gambling market in 2024. Official figures put total legal stakes at €8.2bn, up slightly from €7.9bn the year before.

For the German Sports Betting Association (DSWV), this represented long-overdue transparency but not accuracy. Chairman Mathias Dahms argued the black market share is far higher, “exceeding 50%” according to studies such as the influential Schnabl report.

One alarming statistic was that the number of illegal German-language sports betting websites jumped 36% from 281 to 382 in a year, against just 34 licensed sites on the GGL whitelist.

“The ratio of legal to illegal sites is around 1 to 11,” Dahms said. “Illegal providers benefit from offering wider markets, especially in live betting, which is immensely popular. This is precisely why many users switch.”

The dispute reflects a broader question over Germany’s restrictive model. Licensed operators are bound by stringent rules including €1 maximum stakes on online slots, strict deposit caps, narrow bet types and heavy ad restrictions.

Critics argue that these restrictions make the legal market less appealing. By contrast, illegal sites exploit demand for in-play betting and broader wagering options.

This gap undermines channelisation, the treaty’s core goal of steering players into the regulated market. Critics say that since GlüNeuRStV’s inception, true accountability has been paused, with conflicting statistics fuelling a stalemate between regulator and industry.

GGL hands tied
The GGL, for its part, has pressed ahead with enforcement. Since 2023 it has implemented geo-blocking under the EU Digital Services Act, expanded payment blocking, and lobbied Google to restrict ads to licensed operators. But enforcement is resource-intensive: by late 2024 the GGL was defending 189 lawsuits, many brought by operators challenging licence decisions and restrictions.

The regulator leans heavily on the GlüNeuRStV Atlas compiled by the University of Bremen, but these figures are refuted by the German Online Casino Association (DOCV), which argues they understate the black market and misrepresent consumer behaviour.

Anxieties on Interstate direction
Underlying these disputes is a constitutional reality: the GGL enforces, but cannot legislate. Any reform — whether on advertising, sponsorship, deposit limits or product scope — requires Bundestag approval, and political opinion remains divided.

Betting on amateur football has already triggered state-level disputes over integrity and oversight, while also prompting operators like Interwetten to pull wagering markets on amateur sports.

Looking ahead, 2026 is expected to bring a federal law on gambling advertising and sponsorship, likely the next battleground. Until then, both sides invoke player protection: the GGL through uniform restrictions, and the DSWV by demanding a legal market strong enough to outcompete the black market.

As Dahms put it: “With this figure, the GGL is creating more transparency for the market and the public. Fact-based debates are only possible if we have access to reliable official figures—we expressly welcome this step.”

Clarity has not yet delivered consensus. Germany’s online gambling market remains a divided house, with addiction concerns, black market leakage, and regulatory rigidity leaving the future of the Interstate model uncertain.

Swedish state-owned operator Svenska Spel is celebrating a major milestone for its contributions towards public health in the country.

The operator’s independent research council has passed the SEK 100 million (£8m) mark for funding research on problem gambling and harm prevention, while simultaneously observing its 15-year anniversary since its inception in 2010.

In addition, a total of six new projects have been approved to tap into a collective fund valued at SEK 5m for research purposes.

Sara Lindholm Larsson, Research Council Chair, said: “It is a favour and a privilege to be able to contribute to the development of knowledge and evidence in this important subject.

“Through research, we can better understand what drives unhealthy gaming and which interventions really have an effect.”

Anders Håkansson is the researcher who will get the most out of this year’s communal grant, a total of SEK 1m, to explore the future prospects of gambling harm-related care procedures, as well as the suicide prevention.

Another equally valued project is that of Olof Molander, which will analyse the implementation of internet-CBT for gambling disorder and comorbidity.

Elisabet Jerlhag Holm is another stand-out participant thanks to her project researching the correlation between gambling addiction and GLP-1 – a medication first developed against diabetes but which has also shown promise in fighting compulsive behaviours.

Emma Claesdotter-Knutsson will receive a grant of SEK 750,000 to evaluate the effects of family programmes within social services on youth gaming participation rates.

Sabina Kapetanovic will also utilise SEK 750,000 in funding to focus on underage demographics, particularly mid-adolescents and how gambling affects their mental health.

And last but not least, Johan Svensson has secured a SEK 700,000 grant to provide a wider and up-to-date public health perspective on gambling in Sweden.

Anna Johnson, President and CEO of Svenska Spel, concluded: “Passing SEK 100m in research support shows that we are serious about our long-term responsibility.

“The research has provided new knowledge about everything from young people’s gambling habits to how healthcare can be developed – insights that make society better equipped to prevent gambling problems and create safer gambling.”