The Dutch Gambling Authority (De Kansspelautoriteit) published the draft version of the Policy for Responsible Gambling on October the 20th, 2020. So are you involved (or interested) in the Dutch Gambling market; especially regarding to responsible gambling and advertising? In that case, you can send your opinion/statement before the 9th of November, 2020 to email@example.com.
After the feedback is taken in consideration, the Policy for Responsible Gambling will be finalized as soon as possible. Also, the final version will be with reservation until the Dutch Remote Gambling Act is officially effective.
In collaboration with the Centrum voor Verantwoord Spelen, we will organize a webinar to address the new policy (as soon as it is definitive). But before all this, we will address some points about the Policy for Responsible Gambling draft version in this article. Of course, we care a lot about your opinion: feedback or questions can be directed to firstname.lastname@example.org.
The broad definition of ‘Vulnerable Groups of People’
Article 1 of the Policy draft states definitions that will be referred to. In general, a Dutch (online casino) license holder shouldn’t focus its marketing on these Vulnerable Groups of People. As the title already gives it away, this definition is rather broad:
- Persons who seem to display risky gambling behavior;
- Consumers with limited knowledge of the Dutch language;
- Consumers with a low socio-economic status;
- Low literate-people;
- Consumers with an intellectual disability;
- Consumers of old age.
Of course you can prevent social media campaigns targeting minors by narrowing target age. There’s also no question about the fact that you can’t advertise (with Google Ads) with search terms like ‘how do I quit gambling?’, or ‘how to get help for my gambling addiction?’. Especially the segmentation that’s marked bold raises some questions. For instance: how can you narrow your targeting in marketing/advertising when it comes to consumers with al low socio-economic status? Why should directing marketing to consumers of old age be restricted? How can you even know if you are targeting consumers with limited knowledge of the Dutch language?
You must not imply happiness with online casino marketing
Article 2.3 sub a of the Policy draft states the following: ‘by inciting to excessive participation in gambling is understood to include implying happiness.’ This seems to be a bit contradicting. Responsible gambling in general focusses on subjects like: gambling supposed to be fun, it should not be a way to earn money (or to cover your losses). This is also stated (partly) in Article 3.1.14 of the draft version. Would this mean you can’t post ads with smiling people, having fun at a Blackjack table?
High risk games of chance can’t be promoted
Article 2.6 sub a states marketing isn’t allowed when high risk games of chance are being promoted. Of course, the draft version (as well as lower legislation), provide information about a risk analysis (article 3.1.9). But what to expect of this? Most online casino video slots have a fixed Return to Player (RTP), which is around 90 to even 97 percent. Should a more volatile slot be considered high risk? And what about Roulette? If you only place your bets on red or black, risk is relatively low. But what if you place a (considerable) bet on only one number?
A webinar for online casino marketeers and online casino affiliates
You get the picture: there’s a lot to discuss concerning the Policy for Responsible Gambling. When a final version is published, we will organize a webinar in which we will clarify different clauses. In the meantime, we would highly appreciate your feedback and input. Are you involved in the online casino market and are you looking for a Dutch Permit? Or are you in any other way involved in online casino marketing? Please reach out to us via email@example.com, or by dialing +3130 – 227 03 86.