SkillOnNet and Wildz Group submitted detailed responses to a consultation launched by Finland’s Gambling Risk and Harm Assessment Group (GRHAG) on 30 January. The consultation, which runs until 24 February, seeks stakeholder input on player protection requirements that will apply to all licensed operators when Finland’s reformed market launches in July 2027.
Cross-Operator Loss Limits Draw Criticism
Among the most contentious proposals is a single, cross-operator loss limit register that would cap player losses across all licensed operators rather than on a per-operator basis. The GRHAG also recommended mandatory player control tools including deposit limits, loss limits, playing time restrictions, cooling-off periods, and operator-imposed interventions in certain cases.
SkillOnNet, the operator behind the PlayOJO brand, argued that excessively low limits could create negative customer experiences and increase black market activity.
“A forcibly closed gaming account is always a negative customer experience,” SkillOnNet stated in its response. “Every time a customer is directed to look for a new gaming location, the risk of finding a site operating outside the system increases.”
The operator cautioned that deposit and gaming limits cannot be implemented in isolation, particularly when Finland’s Gambling Act is already comprehensive in other areas. It warned that strict deposit limits combined with the new legislation would increasingly drive players to unregulated sites.
Channelisation Concerns Based on German Experience
Wildz Group, which operates the Wildz Casino brand, echoed similar concerns and pointed to empirical evidence from Germany’s regulated market. The operator cited studies showing that approximately 20% to 30% of gambling activity was channelled to regulated operators in markets where limits were deemed too restrictive.
“If the restrictions presented in the recommendations were applied in Finland without an assessment of the channelling effects, it is justified to assume a similar outcome,” Wildz stated.
The operator called for a thorough channelisation assessment before implementing strict player limits, warning that Finland could face similar regulatory challenges to those experienced in Germany’s market.
Licensed Gambling Must Remain Competitive
SkillOnNet went further in its critique, arguing that overly restrictive protection rules could make licensed gambling less appealing than unregulated alternatives that offer no player safeguards.
The operator stated that gambling on licensed sites should be “more attractive, more sensible and smoother for Finnish consumers than gambling on an unlicensed site.”
SkillOnNet called for a strategic shift in regulatory focus, urging authorities to prioritize enforcement against unlicensed operators rather than imposing excessive restrictions on compliant licensees.
“In licensed gaming, resources should be directed to ensuring that licensees adhere to their own duty of care and report on it actively, that the restrictions set by the players themselves are adhered to and that the national gambling ban register functions flawlessly,” the operator said.
SkillOnNet noted that Finland’s decision to liberalize its gambling market was partly driven by state monopoly Veikkaus holding only 50% market share, with the remaining activity occurring on offshore sites beyond regulatory oversight.
Additional Proposed Measures
The GRHAG consultation also includes proposals for a tiered intervention model requiring operators to continuously monitor customer behaviour, define risk indicators and responses, and maintain detailed records of player contacts and outcomes.
The assessment group recommended designating young adults aged 18-24 as a high-risk group subject to lower thresholds and stricter protections. Additionally, the GRHAG issued cautionary guidance on artificial intelligence, stating that AI and machine-learning harm prediction models remain “still immature” and should not serve as the primary basis for player protection measures.
Market Timeline and Regulatory Framework
The proposed player protection rules will form part of Finland’s broader gambling legislation approved in December 2025. The measures will apply to all operators securing licenses in the country’s reformed market, which will open to multiple licensed iGaming operators for the first time.
Operators can begin submitting license applications from March 2026, though the government has yet to finalize all safer gambling requirements for licensees. The regulated market is scheduled to launch in July 2027.
At the time of publication, SkillOnNet and Wildz Group were the only two operators to have publicly submitted responses to the GRHAG consultation. The Ministry of Social Affairs and Health will review all stakeholder feedback before finalizing the player protection framework.
Source: iGaming Business
