Date: 16.10.2023

by Mateusz Mazur

Strengthening Consumer Protection in the Swedish Online Gambling Market

The Swedish Trade Association for Online Gambling (BOS) plays a significant role in shaping the future of online gambling in Sweden. Today, BOS is responding to the Ministry of Justice’s inquiry on “Strengthened consumer protection against risky lending and over-indebtedness.”

In this article, we will explore BOS’s views on the proposed regulatory changes and their potential implications for the gambling industry.

BOS’s Position on Key Proposals

BOS represents approximately twenty gambling companies actively participating in the Swedish gambling market. As Sweden’s largest trade association within the industry, all BOS members possess licenses/permits issued by Spelinspektionen, ensuring they adhere to the country’s gambling regulations.

BOS’s engagement in the inquiry primarily focuses on two critical aspects – a stricter regulation of offering games on credit and the introduction of a debt and credit register. Let’s delve into their stance on these proposals.

The inquiry suggests extending the credit prohibition in the Gambling Act to cover third parties. The proposal aims to prevent licensed gambling companies from promoting the offering of credit for gambling by third parties. BOS endorses this proposal, emphasizing that responsible gambling should not lead to financial stress or vulnerability.

Additionally, BOS agrees with the inquiry’s assertion that customary means of payment, like credit cards, should not be affected by this provision. Customers must be aware of the payment options available to them. However, it is crucial to distinguish between specific gambling credits and general credits, such as regular credit cards.

Should Credit Card Gambling Be Banned?

The inquiry considers whether gambling with credit cards should be banned. BOS acknowledges the inquiry’s understanding of the current payment market’s dynamics and supports the proposal to reject a credit card ban. They argue that such a ban would have severe consequences for the gambling market, particularly the online gambling sector.

In the online gambling market, cashless transactions are the norm, and illegal off-license gambling is only a few clicks away. Banning credit card payments would inadvertently benefit unlicensed and often illegal gambling operators. BOS emphasizes the importance of maintaining a competitive advantage within legal parameters.

Introducing a System for Skri Registers

The inquiry proposes the introduction of a system for debt and credit registers, referred to as Skri registers. BOS sees this as a vital step to ensure that customers only spend what they can afford on gambling. The entertainment industry, including gambling, should not undermine essential expenses such as food and housing costs.

BOS believes that a Skri register can enhance lenders’ understanding of borrowers’ financial situations, potentially reducing cases that end up in debt collection. The proposed limitations on reporting and data retrieval in the system strike a balance, considering privacy and GDPR concerns.

BOS recognizes the possibility of future expansion of the Skri register, allowing licensed gambling companies access to it. They emphasize the potential benefits for promoting their duty of care towards customers, as well as addressing money laundering and terrorism financing concerns. However, BOS also highlights the need for a thorough integrity review before expanding access to the register to protect individual privacy.

BOS’s response to the Ministry of Justice’s inquiry reflects their commitment to ensuring responsible and safe gambling practices in Sweden. The proposed regulatory changes aim to protect consumers from risky lending and over-indebtedness, and BOS’s engagement in this process plays a crucial role in shaping the future of the Swedish online gambling market.