Research for the review of the Interactive Gambling Act 2001

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1 Research for the review of the Interactive Gambling Act 2001 Gambling and 'In-the-run' betting April Report to the Department of Broadband, Communications and the Digital Economy

2 Allen Consulting Group Pty Ltd ACN , ABN Melbourne Level 9, 60 Collins St Melbourne VIC 3000 Telephone: (61-3) Facsimile: (61-3) Sydney Level 1, 50 Pitt St Sydney NSW 2000 Telephone: (61-2) Facsimile: (61-2) Canberra Empire Chambers, Level 2, 1-13 University Ave Canberra ACT 2600 GPO Box 418, Canberra ACT 2601 Telephone: (61-2) Facsimile: (61-2) Website: Disclaimer: While the Allen Consulting Group endeavours to provide reliable analysis and believes the material it presents is accurate, it will not be liable for any claim by any party acting on such information. Allen Consulting Group 2012 The Allen Consulting Group ii

3 Contents Executive Summary Access to Gambling In-the-run Betting Findings v v vii ix Chapter 1 1 Introduction Purpose of report Report structure Terms of Reference and this Report Assessment on the evidence bases A note on terminology 8 Chapter 2 9 Policy context The Interactive Gambling Act Review of the Interactive Gambling Act Other concurrent gambling reviews 12 Chapter 3 14 The online gambling market Introduction Gambling as part of the growth of the Internet Forms of internet gambling Consumption of Internet gambling Prevalence of online gambling Payment methods 37 Chapter 4 40 Regulating online gambling Prevalence of online problem gambling Risks factors associated with problem online gambling Sports integrity associated with in-the-run and micro betting Australian regulation of online gambling Limiting unlawful provision of online gambling services International regulation of online gambling Consumer response to regulation on online sites 90 The Allen Consulting Group iii

4 Chapter 5 93 Minimising harms from Internet gambling Rationale for harm minimisation Current approach to harm minimisation Assessment of harm minimisation effectiveness measures Substitution effect if online in-the-run betting (including micro betting) are allowed 105 Appendix A 107 Research specification 107 A.1 Access to Gambling 107 A.2 In-the-run betting 108 Appendix B 109 Terms of Reference for 2011 Act Review 109 Appendix C 110 Roy Morgan Research Single Source Database Player Profile 110 C.1 How to read the tables 110 C.2 Demographic characteristics 111 C.3 Attitudes and Leisure & Entertainment Spend 111 C.4 Types of Gambling 111 C.5 Frequency of Bets Placed in the last 3 months 111 C.6 Average Spend on Bets in the last 3 months 111 References 166 The Allen Consulting Group iv

5 Executive Summary Access to Gambling Prevalence of online gambling There are no definitive studies that precisely quantify the prevalence of online gambling in Australia. Evidence from the Roy Morgan database suggests that online gamblers make up 9.4 per cent of all gamblers with around 3.9 per cent of the adult population gambling online and 0.9 per cent of the adult population participating in online gaming, which is prohibited under the Interactive Gambling Act 2001 (the IGA). Studies conducted in Tasmania, Queensland and the ACT suggest that the Australian interactive gambling market is small with prevalence rates ranging between 1.4 to 5.2 per cent. Findings from focus groups reveal that there has been a significant increase in the prevalence of online gambling over the past five years and that focus group participants engage in online gambling activities that are allowed and prohibited under the IGA. Prevalence of problem online gambling and risk factors There has been minimal Australian research on the prevalence of problem gambling among online gamblers. What evidence exists is mixed. Some of it suggests that the prevalence of problematic online gambling is at about the same proportion as prevalence of problem gambling in general; however, other evidence suggests that the nature of online gambling (e.g. small, high frequency wagers) makes it conducive to problematic behaviour. The 2006 Tasmanian and 2010 Australian Capital Territory gambling prevalence studies estimated that approximately 10 per cent of internet gamblers in both states are moderate-risk or problem gamblers. International studies suggest higher rates of problem gambling among online gamblers than gamblers in general. The 2010 British Prevalence Survey revealed that 5.3 per cent of interactive gamblers were classified as problem gamblers using the DSM-IV (scores of 3 or more). The United Kingdom has higher rates of internet gambling and median spend than Australia. Studies have identified that the risk factors associated with problem online gambling include high level of accessibility and convenience and opportunities for impulsive gambling; the use of credit cards; the increased social isolation of the interactive environment; the ease of drinking and drug taking while gambling; the immersive quality of the internet; and lower levels of consumer protection. The Allen Consulting Group v

6 Regulation Limiting unlawful provision of online gambling services Payment blocking, ISP blocking, advertising restrictions, direct enforcement measures, diplomatic pressure and international cooperation have all been suggested as potential measures to limit the unlawful provision of online gambling services. European regulators support implementing a suite of measures to limit unlawful online gambling service provision as no single measure is effective on its own. However, payments blocking and advertising restrictions appear to be the most prominent measures used. Gambling service providers believe that financial restrictions and attempted blocking of consumers from unlawful sites would prove to be ineffective as consumers are able to circumvent these measures. International trends International online gambling regulation models include: monopoly markets in Norway, Sweden and Finland where a broad range of products is offered; the free market approach to the regulation of online gambling in the United Kingdom; ringed fenced markets, where a more restrictive approach is adopted through regulating internet gambling at the point of consumption, taxes are imposed and players and operators are protected from black market offerings; offshore licensing where some of the world s largest online gambling companies hold licences in one or more of these jurisdictions and target customers and revenues from outside of these jurisdictions; and fully restricted internet gambling adopted in Germany and partially restricted gambling in the United States. 1 An emerging trend is ring fencing, which was first introduced by Italy and since adopted in France, Denmark, Spain, Romania, Poland, Belgium with the UK, Ireland and others indicating they will be moving towards a similar model. Harm Minimisation One prominent Australian study has noted the benefits of regulating harm minimisation measures, suggesting that it could include prominently displayed account information, tools to enable time and money limit pre-commitments, notifications about risky behaviour, self-exclusion protocols, age checks, credit betting restrictions and self-assessment tools. Other studies found that pop-up messages effectively captured gamblers attention during play, communicate information that is comprehended and influence gambling-related thoughts, but there is less evidence that they have any sustained impact on behaviour. The method of displaying signs may impact on awareness and recall of harm minimisation messages. The Allen Consulting Group 1 sports betting and poker are unlawful in the United States. According to a December 2011 memorandum opinion from the Department of Justice (DoJ), online lottery sales are not unlawful. The DoJ maintains that online horse race betting is a violation of federal laws. However the authors of this report are unaware of any prosecutions in this area. vi

7 Gambling service providers make available a range of harm minimisation measures on their sites but have indicated that usage is on a voluntary basis and have observed low participation by consumers. This observation is consistent with a focus group finding that most participants are aware of gambling management tools but do not use them as they are proud that they are in control of their gambling behaviour, and prefer that the adoption of protection measures not be mandatory. A range of harm minimisation measures is implemented in Europe as part of regulatory requirements. European regulators have indicated that it is too early to comment on effectiveness of these measures as they have been recently implemented and more research is required. However, initial feedback seems to be positive. Best practice Based on the trends of online gambling regulation models and harm minimisation measures implemented in Europe, it is too early to definitively evaluate or determine the effectiveness of these models and measures. Ring fencing however has been identified as an emerging online gambling regulation model in Europe, with payments blocking and advertising restrictions among prominent measures employed. Initial feedback on harm minimisation measures implemented has been positive though more research is required. In-the-run Betting Prevalence of in-the-run gambling There is no systematic Australian evidence known to the authors of this report on the prevalence of in-the-run and micro betting. Consultations with gambling service providers undertaken for this report suggest the prevalence is small, or at least the amounts that are gambled with these types of bets are small. According to discussions with European regulators, there is an increased prevalence of betting where micro betting is allowed. Additional risk factors Problem gambling While there may be an increased in prevalence of betting where micro betting is allowed, there is an absence of evidence in the research literature that it leads to a greater prevalence of problem gambling. However, problem gambling counsellors and other stakeholders believe that the intensity and anonymity of in-the-run betting online could lead to problem gambling. Integrity of events Sporting bodies have indicated concern regarding bets made to subsets of events and the potential links to integrity issues. Consistent with the National Policy on Match Fixing agreed to in June 2011 by Commonwealth, State and Territory Sports and Recreation Ministers, most sporting bodies have integrity agreements in place with gambling service providers which provide for the exchange of information, particularly around the placement of bets by people associated with the particular sports. The Allen Consulting Group vii

8 Europe s principal sports bodies have expressed their concerns over the proliferation of in-the-run (in-play) betting, including micro betting, and also outlined measures which are being taken to prevent match fixing. The sports bodies have implemented player education and entered into memoranda of understanding with the betting industry where betting organisations agree to provide information and suspicious betting activities or unusual betting volumes. Regulation International trends Three principal regulated betting markets (the United Kingdom, France, which does not allow micro bets, and Italy) have adopted positions on in-play betting while others (Spain, Belgium, Denmark, and Poland) are still assessing their positions on the activity. While they have not yet regulated online sports betting, Germany and Greece are also known to be considering the regulation of in-play betting. Currently, all the European regulators that have assessed in-play betting activities have determined that there are no significant differences between in-play and traditional ante-post betting and have decided to regulate it in the same way, and under the umbrella of existing betting regulation. Applying different rules Sporting bodies, while not supportive of in-the-run and micro bets, agree that betting regulation should be platform neutral. Views expressed to justify platform neutrality include: the belief that regulation should be indifferent to the technology used to place bets; there is no meaningful distinction to be made between bets that are made online or via a telephone; if such bets are allowed in the first place, they should be allowed on all mediums; and in-the-run and micro bets that are placed online pose no additional risks or integrity issues for sports, over and above in-the-run and micro bets that are placed by some other means. Gambling service providers agreed that platform neutrality should apply to in-therun bets including micro bets. The Allen Consulting Group viii

9 Findings Finding 1: Prevalence of online gambling by Australians (Access to online gambling TOR #1) [page 36] There are no definitive studies which precisely quantify the prevalence of online gambling in Australia, because it is a relatively recent form of gambling and to date has been a relatively small part of the gambling market. Evidence from the Roy Morgan database indicates that around 3.9 per cent of the adult population gambles online. The prevalence of online gaming (which is prohibited under the IGA) is around 0.9 per cent of the adult population. gamblers make up around 9.4 per cent of all gamblers. This evidence is consistent with the gambling research literature that finds that interactive gambling is a relatively small part of the overall gambling market. Recent prevalence studies by state include Tasmania (1.4 per cent), Queensland (2.0 per cent) and the ACT (5.2 per cent). The evidence from the literature suggests there is a higher prevalence of types of online gambling that is permitted under the IGA (e.g. horse and sports betting) than types that are prohibited (e.g. table games). Evidence from focus groups suggests that a significant increase in the prevalence of online gambling over the past five years. Focus group participants mostly gambled on betting types that are allowed under the IGA but also on those that are not, such as Texas Hold em poker and blackjack. Finding 2: Prevalence of in-the-run and micro betting ( In-the-run betting TOR #1) [page 37] There is no academic literature yet on the prevalence of in-the-run and micro betting in Australia. In Europe in-play (i.e. in-the-run) betting has grown very fast and accounts for over half of non-horse racing on-line betting. According to discussions with gambling service providers, in Australia, this kind of betting is a small, albeit growing, part of the gambling market. Because of the legal suppression of online in-the-run betting (including micro betting), this type of betting does not yet appear to be front-of-mind amongst Australian gamblers. It is possible that, should in-the-run online betting be legalised in Australia, this type of betting would become as popular as it is in Europe. However, as a practical matter, this kind of betting becomes feasible only with very fast and reliable internet speeds, especially for short-lived events, such as micro-events. Thus even if in-the-run and micro betting are legalised in Australia, their ability to grow to European levels could depend on the speed and quality of internet connections available to gamblers. The Allen Consulting Group ix

10 Finding 3: Relative frequency of payment methods (Access to online gambling TOR #3) [page 39] The way Australian gambling online customers pay for their bets is by establishing accounts with gambling service providers. When bets are made, money is debited from these accounts, and winnings are credited to them. The majority (70 to 80 per cent) of customers establish and top up these accounts with credit cards. Other payment methods such as PayPal and POLI are small but growing in importance. Finding 4: Relative prevalence of problem gambling amongst Australian online gamblers (Access to online gambling TOR #2) [page 44] There has been minimal Australian research on the prevalence of problem gambling among online gamblers. What evidence exists is mixed. Some of it suggests that the prevalence of problematic online gambling is at about the same proportion as the prevalence of problem gambling in general; however, other evidence suggests that the nature of online gambling (e.g. small, high frequency wagers) makes it conducive to problematic behaviour. International evidence shows higher rates of problem gambling among online gamblers. Finding 5: Extent to which [in-the-run and micro] betting raise additional risks from a problem gambling perspective ( In-the-run betting TOR #2) [page 47] Problem gambling counsellors, and other stakeholders, believe that the intensive and anonymous form of in-the-run betting online, such as micro betting, could lead to problem gambling risks that are over and above those associated with terrestrial gambling. The British Gambling Commission also noted that in-play betting could begin to look like a gaming environment. Finding 6: Problem online gambling risk factors (Access to online gambling TOR #4) [page 52] Studies have identified that the risk factors associated with problem online gambling include high level of accessibility and convenience and opportunities for impulsive gambling; the use of credit cards; the increased social isolation of the interactive environment; the ease of drinking and drug taking while gambling; the immersive quality of the internet; and lower levels of consumer protection. The Allen Consulting Group x

11 gambling offers convenience, comfort and easy access, but this is true for both problem and non-problem gamblers. More research is needed to distinguish between problem gambling that happens to be online and gambling where the problem occurs because it is online. Finding 7: Extent to which permitting [in-the-run and micro betting] online is likely to contribute to greater risk in terms of problem gambling, consumer protection and integrity of a sports event ( In-the-run betting TOR #5) [page 60] Problem gambling counsellors believe that the intensive and anonymous form of inthe-run betting online, such as micro betting, could lead to problem gambling. There is no evidence that in-the-run and micro betting, in general, pose additional risk in terms of consumer protection, except insofar as they might be associated with manipulated outcomes of events. It is clear that micro betting (and exotic betting) can pose an integrity problem for sports, as the outcomes of subsets of events (as opposed to the event itself) can be relatively easily manipulated. However, it is not clear that online micro betting, or online exotic betting, create any additional integrity problems. Indeed, according to gambling service providers, because online bets are more easily traced than terrestrial bets, which can be made anonymously, it is less likely that bets on subsets of events, where the integrity of the event has been compromised, will be placed online than off-line. Finding 8 : Issues that arise from having different rules regarding the same services delivered online and via the telephone ( In-the-run betting TOR #3) [page 70] Among gambling service providers, there exists a great deal of confusion around the definition of an event for the purposes of not breaching the prohibitions in the IGA against in-the-run betting. Some also believe that the current rules place Australian gambling service providers at a competitive disadvantage vis-a-vis their international competitors. Similarly, sporting bodies also believe that the IGA is unclear in this regard. With smartphones (or other mobile devices) enabling bets to be made online or by a voice call using the same device, the sense of having different rules regarding the same services delivered online or by telephone is diminished even further. All gambling service providers and sporting bodies consulted believe that regulations should be platform-neutral. The Allen Consulting Group xi

12 Finding 9: Additional measures that might be applied to in-the-run and micro betting to preserve integrity of sports events and consumer protection ( In-the-run betting TOR #6) [page 71] Based on discussions with sporting bodies, consideration could be given to allowing sporting bodies to define an event for the purposes of regulating in-the-run betting. Finding 10: Examples of best practice in other countries that have introduced regulated access to online gambling (Access to online gambling TOR #8) [page 89] It is too soon to tell what could be classified as best practice, but ring fencing (whereby online gambling service providers are brought inside the tent ) is an emerging trend in Europe. European regulators are confident that ring fencing regimes will provide an effective means of controlling online gambling though none claims that any regulatory solution is or can be infallible. The architecture of ring fencing includes permitted games, a taxation regime, licensing and regulations on server location. The variation in particulars of ring fencing across European countries reflects the lack of a Euro-consensus, e.g. UK regulators taking the view that in-play betting poses no significant difference to traditional betting in relation to harm minimisation and integrity issues; on the other hand both France and Italy have tight restrictions on micro betting. A taxation rate of about 20 per cent on gross gaming revenue appears to be consistent with creating a competitive regime that can channel consumers away from the black market. In contrast, the example of a high turnover tax in France indicates that this type of taxation model has the opposite effect. Finding 11: Examples of best practice in other countries of limiting access to unregistered online gambling services providers (Access to online gambling TOR #9) [page 89] Various methods are used overseas to limit access. These include payments blocking, ISP blocking, advertising restrictions, direct enforcement measures, diplomatic pressure and international co-operation. Payments and advertising restrictions are most prominent. The effectiveness of these measures has yet to be conclusively determined but payments blocking and advertising restrictions appear to be having the intended effect of restricting unlawful online gambling in some countries, such as the US. The Allen Consulting Group xii

13 Finding 12: Approaches taken overseas to [micro and in-the-run] betting ( In-the-run betting TOR #4) [page 90] Three principal betting markets have adopted positions on in-the-run (or in play) betting. The United Kingdom and Italy allow in-play including micro betting while France only allows in-play betting but not micro betting. Other European jurisdictions are still considering their positions. To date in-the-run betting has been assessed as being no different in principle to ante-post betting and is regulated the same way, under the umbrella of general betting regulation. It is too soon to judge the effectiveness of overseas approaches to in-the-run and micro betting on harm minimisation, consumer protection and sports integrity. Finding 13: For those people who play online, preferences to play on a regulated if one was available rather than on an unregulated (Access to online gambling TOR #5) [page 92] Australian gambling consumers aren t very well informed about what sites are regulated and if so how they are regulated. They do have a preference for what they perceive to be safe sites, based on size and reputation, and appear to be prepared to manage the risks themselves. More research is needed on whether, given sufficient information and opportunity, they would actually choose a safe, regulated site over an unregulated site (which is similar in other respects). Finding 14: Effectiveness of different harm minimisation measures (Access to online gambling TOR #7) [page 104] The research literature, while sparse, suggests a number of measures which could be effective in reducing harms from online gambling, including pop-up messages, spending pre-commitment and social responsibility response tools (e.g. personal budgets and self-exclusion options). Australian gambling service providers offer a variety of voluntary harm minimisation measures, such as pre-commitment and self-exclusion. The use of these is generally low, which could be interpreted in a number of ways: they might be ineffective, or they might not be needed. Overseas, harm minimisation measures have been introduced only quite recently and it is too soon to tell whether they are working. The Allen Consulting Group xiii

14 Chapter 1 Introduction 1.1 Purpose of report The Department of Broadband, Communications and the Digital Economy (the Department) is currently undertaking a review of the operation of the Interactive Gambling Act 2001 (the IGA). In particular, the review is to have reference to: the growth of online gambling services (both regulated and unregulated) in Australia and overseas, and the risk of this to the incidence of problem gambling; the development of new technologies, including smart-phones, and the convergence of existing technologies that may accelerate the current trend towards the take-up of online gambling services in Australia and overseas; the adequacy of the existing provisions of the IGA, including technical, operational and enforcement issues relating to the prohibition of interactive gambling services and the advertising of such services; consideration, where appropriate, of technology and platform neutrality including current distinctions relating to 'betting on the run' and micro betting; international regulatory approaches to online gambling services including consideration of their effectiveness and cost; examination of the social, tax, jurisdictional and enforcement aspects of regulated access to interactive gambling services currently prohibited under the IGA; and harm minimisation strategies for online gambling. To inform the review, the Department has engaged the Allen Consulting Group (ACG) to provide advice on access to online gambling, including its prevalence, risk factors, harm minimisation measures and overseas examples of best practice and issues relating to betting in-the-run including micro betting. While this examines most of the topics listed under the term of reference for the Review, it does not include how technology influences the uptake of online gambling services or the adequacy of current provisions in the IGA relating to prohibition of interactive gambling services and advertising. ACG has adopted a multi source approach to gather evidence needed to examine the issues at hand. Sources from which the information and data gathered for this report include: The Allen Consulting Group 1

15 an extensive literature survey on issues related to online gambling with a focus on in-the-run and micro betting including; prevalence of online gambling and online problem gambling; risk factors associated with online gambling; harm minimisation measures and their effectiveness; development of an online gambler profile using data from Roy Morgan Research Single Source database; extensive international research on: the architecture of regulation and taxation of the online gambling market that have been adopted by overseas jurisdictions; harm minimisation measures implemented and their effectiveness; in-the-run and micro betting and how it affects the integrity of sports; targeted consultation with 20 consumers of gambling services via two focus groups conducted in Melbourne and Sydney; and consultations with three main industry stakeholder groups; namely, gambling service providers, gambling counsellors and sporting bodies. gambling activities and its regulation impact each stakeholder group in different ways. Stakeholders provide insights across a wide range of issues that need to be considered when regulating interactive gambling. 1.2 Report structure The report is structured as follows: Chapter 2 briefly describes the Interactive Gambling Act 2001 and how it regulates internet gambling. The chapter sets the policy context by discussing past and current reviews; Chapter 3 sets the scene for the report by describing the internet gambling market internationally and in Australia, the characteristics of online gamblers that differentiate them from terrestrial gamblers including payment methods favoured and the prevalence of online gambling (including in-the-run and micro betting); Chapter 4 discusses online gambling market regulation, both in Australia and internationally. The chapter provides insights into the effectiveness of the IGA in minimising problem gambling from different stakeholder groups perspectives. It also discusses possible improvements to the current regulatory regime and approaches to preventing the unlawful provision of online gambling services. The chapter also provides a discussion on how international jurisdictions have regulated online gambling; and Chapter 5 discusses harm minimisation measures that are currently in place in Australia and internationally to protect online gamblers from fraudulent transactions and help manage their gambling activities. The Allen Consulting Group 2

16 1.3 Terms of Reference and this Report A detailed term of reference of the work that ACG is conducting is provided in Appendix A. In addition, the terms of reference for the Review that the Department is currently conducting is provided in Appendix B. Table 1.1 below shows where in the report the terms of reference have been addressed. The Allen Consulting Group 3

17 Table 1.1 WHERE THE TERMS OF REFERENCE ARE ADDRESSED IN THIS REPORT ACCESS TO ONLINE GAMBLING 1. current prevalence of online gambling by Australians on Australian based sites and overseas based sites. This should cover both online gambling that is allowed by the IGA as well as online gambling that is prohibited to be provided under the IGA (including online poker card playing) 2. the relative prevalence of problem gambling amongst Australian online gamblers on both allowed and prohibited services Section 3.4 (Consumption of Internet gambling) pp Section 3.5 (Prevalence of online gambling) pp Section 4.1 (Prevalence of online problem gambling) pp relative frequency of different payment methods used by Australian online gamblers using both allowed and prohibited services Section 3.6 (Payment methods) pp problem online gambling risk factors including demographic and other related risk factors and whether there are different risk factors associated with different types of online gambling such as online poker games (both tournament online poker and cash games) or sports wagering 5. for those people that already gamble online, preferences to play on a regulated site if one was available rather than on an unregulated site Section 4.2 (Risks factors associated with problem online gambling) pp Section 4.7 (Consumer response to regulation on online sites) pp for those that do not currently gamble online, likelihood of gambling on a regulated site if a regulated site was available Section 4.7 (Consumer response to regulation on online sites) pp effectiveness of different harm minimisation measures for online gambling including those adopted overseas as well as those suggested by the Productivity Commission: player identification to prevent underage play, duplicate accounts and betting by individuals involved in an event communication of account activity in an easily comprehendible and meaningful format pre-commitment strategies for time and money education about games, statistical probabilities of winning and responsible gambling including practical strategies dynamic warnings feedback on player behaviour including self-tests and alert systems which identify potentially problematic play self-exclusion options customer support 8. examples of best practice in other countries that have introduced regulated access to online gambling, including the architecture of regulation and taxation. Section 5.2 (Current approach to harm minimisation) pp Section 5.3 (Assessment of harm minimisation effectiveness measures) p 104 Section 4.6 (International regulation of online gambling) pp examples of best practice in other countries of limiting access to unregistered online gambling service providers Section 4.5 (Limiting unlawful provision of online gambling services) p 71 Additional material Section 3.4 (Consumption of Internet gambling) pp Characteristics of online gamblers The Allen Consulting Group 4

18 IN-THE-RUN BETTING 1. the prevalence of in-the-run betting and micro betting in Australia and overseas, whether using telephone or online betting services or other services Section 3.5 (Prevalence of online gambling): pp the extent to which these types of gambling raise additional risks from a problem gambling perspective, including whether there are different problem gambling risks associated with betting on the final outcome of an event after the event has started compared to micro or ball by ball betting 3. the issues that arise from having different rules regarding the same services delivered online and via the telephone Section 4.1 (Prevalence on problem online gambling) pp Section 4.4 (Australian regulation of online gambling) pp approaches taken overseas to these types of online wagering, including regulatory measures, harm minimisation measures and measures to protect consumers and the integrity of sport Regulatory measures Section 4.6 (International regulation of online gambling) pp Harm minimisation measures and customer protection Section 5.2 (Current approach to harm minimisation) pp Section 5.3 (Evidence base for harm minimisation) p the extent to which permitting either of these two types of wagering online is likely to create a greater level of risk in terms of problem gambling, consumer protection and the integrity of a sports event this should be considered in terms of accessing these services both online or via the telephone Section 4.1 (Prevalence on problem online gambling) pp Section 4.3 (Sports integrity associated with in-the-run and micro betting) pp what additional measures might be applied to in-the-run betting and micro betting to preserve the integrity of sports events and consumer protection Additional material Section 4.4 (Australian regulation of online gambling) pp Section 4.4 (Australian regulation of online gambling): pp The IGA: Comprehension and lack of clarity 1.4 Assessment on the evidence bases The authors of this report have conducted a comprehensive review of the research literature on online gambling, especially the psychology literature, including online problem gambling. What stands out is that the literature is still immature and fragmented, particularly in comparison with the literature on gambling in general. As a result, while there is some evidence that can be used to answer the questions in this report s Terms of Reference, there is not a lot of evidence, and not all of the evidence is consistent e.g. on risk factors for problem online gambling. There is no evidence in the literature on online micro and in-the-run betting. The Allen Consulting Group 5

19 This is to be expected. gambling is a relatively new phenomenon, and academic research always lags contemporaneous phenomena. It takes time for researchers to realise that a particular issue is worth investigating, to finish what they are already doing, to raise the resources to study the issue in question, to agree on an acceptable research methodology, to collect sufficient data and analyse that data, and to publish their results. In the case of online gambling, which around the world is relatively small but growing rapidly, the problem is compounded by the fact that conclusions about what has been a niche activity may become inapplicable when it becomes mainstream, perhaps as mainstream as gambling in general. Furthermore, the study of problem online gambling can become conflated with the study of problem gambling (in general) and problem internet use (in general). Teasing out the factors that are truly causal (as opposed to correlative) is a difficult research task. Finally, specific Australian evidence in the literature is, at this stage, very sparse. The authors of this report have supplemented their study of the literature with other sources, but each of these is limited as well. The Roy Morgan database provides a comprehensive breakdown of the socio-economic breakdown of online gamblers and their spending patterns, but is silent on questions of problem gambling, regulation and in-the-run and micro betting. Consultations with gambling service providers, problem gambling counsellors, focus groups and overseas regulators all provided interesting insights, but it is in the nature of this kind of information gathering that the evidence is necessarily anecdotal and partial. Furthermore, particularly with gambling service providers and to a lesser extent sporting bodies, the information they presented is self-interested. The table below provides a summary assessment of the evidentiary base. The primary sources of evidence are denoted by with useful secondary sources denoted by. What stands out in the table is the amount of blank space. For most questions, only a small number of information sources were useful as sources of evidence. This is not a criticism of those sources but reflects the new and evolving nature of online gambling. The Allen Consulting Group 6

20 Table 1.2 SOURCES OF EVIDENCE BY TERMS OF REFERENCE Source of Evidence Terms of Reference Research literature Roy Morgan data Gambling Service Providers Sporting Bodies Problem Gambling Counsellors Overseas regulators Focus Groups Access to Gambling 1. current prevalence of online gambling by Australians on Australian based sites and overseas based sites. 2. the relative prevalence of problem gambling amongst Australian online gamblers on both allowed and prohibited services 3. relative frequency of different payment methods used by Australian online gamblers using both allowed and prohibited services 4. problem online gambling risk factors 5. for those people that already gamble online, preferences to play on a regulated site if one was available rather than on an unregulated site 6. for those that do not currently gamble online, likelihood of gambling on a regulated site if a regulated site was available 7. effectiveness of different harm minimisation measures for online gambling including those adopted overseas as well as those suggested by the Productivity Commission 8. examples of best practice in other countries that have introduced regulated access to online gambling, including the architecture of regulation and taxation. 9. examples of best practice in other countries of limiting access to unregistered online gambling service providers 1. the prevalence of in-the-run betting and micro betting in Australia and overseas, whether using telephone or online betting services or other services In-the-run Betting The Allen Consulting Group 7

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