• SkillOnNet and Wildz Group argue that strict limits will drive players to illegal sites
• Proposed rules include a universal loss limit across all licensed operators
• Wildz cites German market data suggesting strict rules harm channelisation rates
• Regulators advise caution on using AI for harm detection and flag young adults as high risk
• Stakeholders have until late February to submit feedback before licensing begins

Finland’s Black Market Nightmare: Operators Warn New Loss Limits Will Spark Exodus to Offshore Sites

Major industry players have issued a stark warning to Finnish regulators regarding the nation’s upcoming gambling framework. Both SkillOnNet and Wildz Group have publicly criticised proposed player protection measures, arguing that draconian restrictions will inevitably push players away from the legal market and straight into the arms of unregulated black market operators.

The controversy centres on recommendations released on 30 January by the Gambling Risk and Harm Assessment Group, known as the GRHAG, which operates under the Ministry of Social Affairs and Health. The group has launched a consultation period that runs until 24 February, inviting stakeholders to voice their opinions on the draft regulations. However, the initial feedback suggests a significant divide between the authorities and the industry regarding how best to protect consumers.

At the heart of the dispute is the proposal for a single market-wide loss limit register. Under this system, players would face a cap on how much they can lose across all licensees combined, rather than having separate limits for individual operators. Further proposals include mandatory player control tools for deposits and playing time, enforced cooling-off periods, and strict intervention protocols.

SkillOnNet, the company behind the popular PlayOJO brand, was quick to highlight the potential fallout of such heavy-handed interventions. In their official response, they argued that a low universal limit would degrade the user experience to the point where players would simply leave the regulated system entirely. They stated that a forcibly closed gaming account is always a negative experience and that every time a customer is directed to look for a new location, the risk of them finding a site operating outside the system increases.

The operator emphasised that regulated gambling needs to be the more attractive and smoother option for Finnish consumers compared to offshore alternatives. They suggested that resources would be better spent ensuring licensees adhere to a robust duty of care and tackling illegal activity, rather than imposing radical restrictions that tighten the market too severely.

Wildz Group echoed these sentiments but brought alarming data to the table. The operator pointed to the German market as a cautionary tale, where strict regulatory limits have reportedly resulted in a channelisation rate of just 20 per cent to 30 per cent. Wildz argued that if Finland applies similar restrictions without assessing these effects, it is reasonable to expect a similarly disastrous outcome where the vast majority of gambling spend flows to offshore sites that offer no player protection whatsoever.

Beyond the financial limits, the GRHAG has proposed a tiered intervention model requiring continuous monitoring of customer behaviour. They also recommended classifying young adults aged 18 to 24 as a high-risk demographic requiring lower thresholds for intervention. Interestingly, the group also advised against relying primarily on artificial intelligence for harm prediction, deeming current machine learning models too immature for the task.

With the market set to open for licence applications in March and a full launch scheduled for July 2027, the clock is ticking. As it stands, the government must balance the desire for stringent safety measures against the very real risk of creating a regulatory framework so tight that it inadvertently fuels the illegal market it aims to replace.

The friction we are seeing in Finland is a classic case of the channelisation paradox that has plagued almost every newly regulating European jurisdiction in the last decade. The primary goal of ending the Veikkaus monopoly is to bring the reported 50 per cent of offshore gambling spend back under state control. However, if the GRHAG insists on a universal loss limit that is too restrictive, they will fail in this objective. Players who hit a global cap do not simply stop gambling; they open Google and find a Curacao or Costa Rica licensed site that ignores Finnish law. The warnings from SkillOnNet and Wildz are not merely corporate posturing but are grounded in the reality of consumer behaviour seen in markets like Germany and Sweden.

The reference to Germany is particularly poignant and should ring alarm bells in Helsinki. The German Glücksspielstaatsvertrag introduced deposit limits and stake caps that were so severe they made the legal product uncompetitive. If Wildz is correct that channelisation in such environments sits as low as 20 per cent, then Finland is risking a scenario where the new licence system becomes a ghost town populated only by casual punters, while the high-value players continue to play offshore. A successful regulatory framework must be commercially viable; otherwise, it offers protection only in theory, not in practice.

Finally, the regulator’s scepticism regarding AI is a fascinating deviation from the industry norm. While most tier one operators are investing millions into behavioural AI to detect problem gambling in real time, the Finnish working group seems unconvinced by the maturity of this tech. This suggests that the Finnish framework may rely more on hard caps and manual triggers than on the dynamic, algorithmic safety nets that have become standard in the UK. While this ensures a certain baseline of safety, it lacks the nuance required to differentiate between a wealthy VIP playing within their means and a vulnerable player spiralling out of control.