Not too hot, not too cold – just right. The future of responsible gambling reforms in Australia's wagering landscape is turning into a Goldilocks tale of its own. One bowl is filled with unchecked risk, another with overcorrection.

Author: Alexander Norrish, Senior Associate / Julian Hoskins, Principal

With competing interests, rapid technological change and shifting community sentiment all tugging at the edges, the challenge ahead is to craft reforms that are neither too heavy-handed nor too lenient. A ‘balance’ needs to be struck where consumers are protected effectively and a sustainable, well-regulated gambling industry is maintained.

Looking abroad can offer valuable insights, but they also highlight that there is no simple solution. What works in one jurisdiction may not work in another. This piece explores a range of measures and considers how they might inform the ongoing conversation in Australia.

Making losses impossible to ignore

Earlier this year, Rebekha Sharkie MP highlighted a gap in Australia’s responsible gambling measures. While monthly activity statements are intended to help customers track their losses, these statements may languish unread in inboxes or junk folders. Sharkie’s Interactive Gambling Amendment (Know Your Losses Activity Statement) Bill 2025 proposed a different approach: a real-time display on every gambling webpage or app screen, showing users exactly how much they have won or lost over different periods.

Although the Bill did not progress due to lack of support from the major political parties, it highlights the notion of immediate feedback for customers. If implemented, we would need to address questions about how best to present such information so that it genuinely influences behaviour, rather than becoming just another screen prompt that customers ignore.

Midnight lockouts: A pause for safer play

In Finland, Veikkaus Oy, the state-owned operator that holds a monopoly, blocks all customer deposits between midnight and 6 a.m. The rationale behind the blackout is to prevent impulsive decision making late at night.

Such a measure in Australia could help create natural intervention points and encourage breaks. However, whilst Finland has one unified time zone, Australia has multiple time zones and daylight savings in certain states to account for. Such a blackout may also prevent customers from betting on overseas events like Formula One or the Tour de France, which often occur overnight in Australia. It could also disproportionately impact night-shift workers and other people who do not follow the usual work-day cycle from having access to gambling services.

Pop-Ups and Pushbacks: Nudging players

Some jurisdictions use automated reminders to keep responsible gambling top of mind for customers. In Romania, customers receive hourly notifications about how long they have been gambling and the self-help tools available. Sweden goes further, displaying accumulated losses, personal limits and self-help tools available every time a customer logs in.

A similar approach in Australia might integrate messages about tools like BetStop or summaries of recent betting activity. Such reminders could help some customers pause and reflect. However, there is also the risk that the messages become background noise for frequent users, or drive some punters to change betting providers before a trigger occurs.

Set Your Clock before you bet

In Spain, customers must set a maximum session length before starting certain online casino games. The Czech Republic has adopted a similar approach, requiring customers to set limits on the number of logins per month and on the duration of daily sessions.

Applying such measures in Australia could support time-based harm minimisation by encouraging players to pre-commit to limits. However, uptake will ultimately depend on the individual customer’s behaviour and attitude towards setting limits. Some may set unrealistically high limits to avoid being interrupted, while others might switch providers once a limit is reached. In some cases, unusually high self-set limits serve as an indicator for closer monitoring of transactions or engagement with the customer.

Younger players, lower limits

Norway enforces a loss limit of NOK 2,000 (approximately AUD $304) per month for customers under 20 years of age. This is ten times lower than the limits for older adults. It reflects concerns around younger people are more vulnerable to gambling harm.

The Netherlands takes a different two-stage approach. Firstly, operators must engage directly with any customer who wishes to set monthly deposit limits above €350 (approximately AUD $630). This threshold is reduced to €150 (approximately AUD $270) for young adults under 24. Before approving a deposit limit above the threshold, operators must explain the risks of a higher limit and remind customers about available responsible gambling tools available to them. Secondly, where monthly deposits exceed €700 (approximately AUD $1258) operators are required to assess whether the customer can afford those loses. The limit is lowered to €300 (approximately AUD $539) for young adults. If personal engagement is not possible, the account is restricted.[1] The approach of the Dutch operators when undertaking these affordability checks has been criticised by the Dutch regulator, Kansspelautoriteit. The regulator has indicated a preference for official pay slips over questionnaires, or details of tax allowances, income of family members, inheritances, savings in bank accounts.[2]

By contrast, the pre-commitment obligation in Australia applies across all customers, regardless of age. Recent research published by the Australian Institute of Family Studies (AIFS) suggest that the 18 to 34 age group had the highest proportion of those gambling at moderate-to-high risk level compared to other age groups. This research, coupled with increased public concern over children being exposed to gambling advertising, would suggest an imperative for similar age specific limits being introduced in Australia.

An Australian age-specific limit would raise issues around age-based discrimination, failure to account for socio-economic differences between young people, and whether it would increase the prevalence of potential workarounds such as ‘bowler’ account activity, where younger individuals funnel money through older account holders. Wagering operators would also be likely to significantly increase resourcing to monitor customer preferences, interact with them, and store their data securely.

By way of contrast, the same research published by AIFS stated that a higher percentage of men fell into the moderate-to-high risk gambling classifications than women. However, we are not aware of any jurisdiction that places restrictions or limits on male bettors over female bettors.

This is a sensitive area of reform where industry insight and consumer research would both play a crucial role in identifying practical solutions.

A One-Click escape

In the Czech Republic, online gambling operators must offer a “panic button” that allows customers to freeze their account for 48-hours with a single click. Operators are required to provide information about self-exclusion options and to notify regulators when the panic button is used.

If Australian wagering operators had a similar feature, their customers would have a simple off-ramp that could be used if they were experiencing distress during a session. It could help their customers regain control whilst avoiding the stigma around gambling-related harm. However, it would not stop a customer from hitting a panic button with one operator and then gambling with another. Such a feature would also need to be designed so that people can easily access it but do not inadvertently activate it. Whilst this is not the silver bullet, it could sit comfortably in the responsible gambling toolbox.

Looking longer-term, a panic button that integrates with the BetStop system could potentially stop a customer from betting with all online wagering operators at the click of a button. However, logistical issues around automated transmission of data and how long it takes to transmit would need to be considered.

Connecting the Dots of Harm

Fully launched in September 2024, the United Kingdom’s GamProtect system allows wagering operators to securely share information when they close a customer’s account due to a customer disclosing that they have a gambling addiction, are seeking treatment, risking harm to themselves or others, or needing to stop gambling for health reasons. The customer’s details are then flagged within the system so other participating operators can identify and proactively protect the same individual.

Could such a system work in Australia? With BetStop already in place as the national self-exclusion register, an Australian GamProtect would need to overcome concerns that it would be redundant. The key distinction between the two systems lies in their timing and trigger for action. BetStop is an opt-in model, placing the onus on individuals to exclude themselves. In contrast, GamProtect requires operators to intervene at moments of acute risk. For such a system to be justified, there would need to be a demonstrable gap between those who require protection and those who proactively seek it. Implementation would likely increase compliance costs, as operators would need additional capabilities to identify and respond to signs of gambling harm. This may include additional staff training and investment in behavioural monitoring systems.

If Australia were to explore a similar model, it would require strict limitations on data use, clearly defined triggers for intervention, and a transparent appeal process for the customer.

Shaping the Future

For the industry, the path forward is about balance. Too little reform risks eroding public trust and inviting more aggressive, reactive regulation. Too much reform may push customers to unregulated offshore markets or place disproportionate burdens on smaller wagering operators with compliance costs.

This is what makes this discussion a true Goldilocks dilemma. Regulation that is too “hot” and heavy could destabilise the industry’s viability, while regulation that is too “cold” leaves significant potential harms unaddressed. The goal is to find an approach that is “just right” – one that protects consumers while preserving a sustainable, regulated market.

Australia’s reform agenda is already underway. The review of the National Consumer Protection Framework for Online Wagering, along with the Government’s pending response to the You Win Some, You Lose More report, will likely define the next wave of change.

For Australian operators, this is not a time to sit on the sidelines. There is a clear opportunity to contribute expertise, shape practical solutions and ensure reforms deliver real outcomes without unintended consequences. The question is no longer whether reform is coming, but whether we are ready to help shape it into the best possible future for both consumers and industry alike.

About Senet

Senet is a multidisciplinary Australian firm specialising in gambling and gaming law, regulatory compliance, and business advisory services. We are the largest specialist team in Australia and based in Victoria. Recognised globally as experts in our field, we understand Australia’s complex gaming, legal, and regulatory landscape, enabling us to guide clients through their compliance requirements across each state and territory. Our clients range from start-ups to publicly listed global operators, both nationally and internationally. Our team is deeply immersed in the industry, often sharing insights at public speaking events, and our principals have held executive roles in a global ASX-listed entity and a 'Big Four' advisory firm, giving us a unique perspective on the challenges our clients face.

If you have any questions or would like to discuss the topics covered in this article, please contact the team at Senet.

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