Reply to committee report 18Li12693, adjusted proposals to regulations and general advice about limitations and prohibitions against certain betting to counteract manipulation of results (for instance match-fixing) within sports as well as reporting of suspected manipulation.
The Swedish Gambling Authority has, in extensive replies from the industry regarding this matter, received facts from BOS, IBIA and H2 Gambling Capital among others who state for example:
- That almost all of the suspected gambling occurs on the sort of betting that the Swedish Gambling Authority does not intend to forbid.
- That the main part of the betting that the Swedish Gambling Authority intends to forbid is occurring abroad and therefore not will be affected by the prohibition made by the Swedish Gambling Authority.
- That the introduction of restrictions against gambling objects in practice will mean that a manipulation of these restrictions will be decriminalised.
BOS has via Copenhagen Economics demonstrated that the channelisation of sports betting is 80-85 % and decreasing. The objective of Parliament and Government for a long-term sustainable regulation of gambling is a 90 % channelisation rate.
BOS, and others, have in referral replies showed that the cost measured in loss in channelisation – excluding the hastily expedited additional prohibitions – amounts to 5,9 percentages.
A high channelisation is a basic condition for a successful against match-fixing. The one who hurts the channelisation is siding with the match-fixers.
The Swedish Gambling Authority’s behaviour in this matter is upsetting and incomprehensible from every fact-based perspective. The SGA has not in any way presented facts which supports the intended effects of the proposed restrictions. The SGA has barely even presented any motive to the restrictions. Furthermore, the SGA has not presented any basis for their change in opinion, which has led to the inclusion of the now notified amendments.
BOS understands the fact that the SGA must effectuate decisions made by the Parliament and the Government regardless if these decisions are fact-based and regardless of the consequences of these decisions. What makes this issue unique is that the settlement and thereby the responsibility of this matter is not in the hands of the Parliament or Government but resides with the SGA itself.
BOS is convinced that the SGA realises that the new amendment about prohibitions against, among other things, betting in lower divisions in football, is hurting the channelisation and the protection of the reregulation. If the SGA still chooses to move forward with the proposal, the Authority will end up residing with those actors who have jeopardized and damaged the Swedish license system, and this during a time when the channelisation is already put under a lot of pressure.
BOS has appreciation for the fact that the SGA has been put under pressure by the government and tax-financed NGOs has been significant. It is however a kind of pressure in which the SGA must show capability to counter when there is cause for it. That is the purpose with independent authorities.
If the Swedish Gambling Authority, against its better judgement, decides to proceed with the restrictions, BOS assumes that these restrictions will be EU notified before going forward.
The Swedish Trade Association for Online Gambling
103 63 Stockholm