By Associate Professor Charles Livingstone, Monash University
Pre-commitment technologies are a part of a suite of measures proposed to tackle gambling harm in Australia. Pre-commitment is a highly effective preventive gambling harm intervention, requiring gamblers to set predetermined limits on how much they can spend – sometimes with a statutory upper limit in place.
Tasmania will introduce a universal pre-commitment system for electronic gambling machines – EGMs, known colloquially as pokies – in 2024, utilising a statutory limit of $100 in losses per day, $1,000 per month, and $5,000 per year. This will apply collectively to all EGMs in the state, meaning that no EGM user can spend more than the limit, regardless of how often they move from EGM to EGM, or venue to venue. This is within a system of individual venue licenses, mostly in commercially operated pubs or taverns. The Victorian government has announced a similar proposal, but timelines for implementation have yet to be announced.
Where do pre-commitment systems already operate?
In Germany, a cross-provider deposit limit of €1,000 applies (agreed by the German states with the urging of the Federal Government), and in Sweden, operator-based limits apply.
Finland, Norway and Quebec operate monopoly gambling providers and limits apply to all lawful gambling provision (lotteries, slot machines, and wagering).
The Norwegian pre-commitment system has been in place since 2009 and is regarded as highly successful (Rossow & Hansen 2015; Lund 2009). The other European jurisdictions noted above have introduced pre-commitment more recently, but in Sweden, since 2014, all gambling providers who wish to obtain a Swedish gambling license – including online providers – must agree to utilise the multi-provider pre-commitment system.
The most effective systems are those which are universal (i.e., all users must use them to gamble), which apply to all forms of gambling and across all providers, and which include personalised messaging when users are exhibiting signs of harmful gambling behaviour (Sulkunen et al. 2019). However, systems that apply only to specific gambling forms (such as EGMs or online wagering across all providers) would also be highly effective in preventing gambling harm.
What are the essential characteristics of an effective system?
Pre-commitment systems should apply across all providers, preferably across all forms of gambling. This means that users cannot exceed their limits by swapping between providers as they reach a specific limit.
Identification requirements should be of high integrity, involving electronically verifiable identification documents such as users’ driver’s license or passport. This is similar to the verification process required for BetStop. BetStop is the National Self-Exclusion Register, through which individuals can opt to block themselves from all licensed Australian online and phone gambling providers. BetStop demonstrates the effectiveness of a multi-provider pre-commitment system, since self-exclusion is a specific form of pre-commitment, where the chosen limit is zero.
Statutory limits are thought to be effective, and this has been demonstrated in Norway. The Tasmanian system will apply to Electronic Gambling Machines only, as will the proposed Victorian system, but there is no technical reason why limits could not apply across all providers (as is the case in Sweden).
Users should be able to reduce their limits at any time, but not be able to instantaneously increase them. For example, the system may require two weeks’ notice for an increase to take effect. Further, limits on the amount wagered made within specific periods, and on deposits to wagering accounts, should both be required.
Introducing pre-commitment systems for online wagering is much more straightforward than for terrestrial gambling, although contemporary monitoring systems for EGMs facilitate this by allowing instant communication between individual machines and a central server.
The ‘cashless’ EGM system, proposed by the Perrottet government prior to the last NSW election, would have linked the pre-commitment system to a registered account, requiring users to nominate a bank account in their name from which funds would be drawn and into which any winnings would be paid. This is similar to the Norwegian system.
Why does the system have to be universal, or mandatory?
Multiple trials have demonstrated that voluntary systems, although useful to those who use them, have low uptake and little effectiveness as harm prevention or minimisation tools. This has been amply demonstrated in the case of the Victorian system ‘YourPlay’, which is required for all EGMs operated in Victoria, but which is voluntary (SACES 2019). Other trials have generated similar conclusions. Universal systems also prevent the stigmatisation of those who wish to use pre-commitment systems, given the stigma associated with those who experience harm from gambling.
Are the technical issues significant?
The existence of pre-commitment systems in multiple jurisdictions demonstrates that technical issues do not present major difficulties (including Australia, where voluntary pre-commitment operates for online wagering providers and in Victoria, where ‘YourPlay’ operates for all EGMs). As previously noted, BetStop requires an ability to share information across multiple providers, as a pre-commitment system would similarly require; especially if a universal system were to be phased in over a reasonable period of 12 to 18 months.
A third-party provider could be commissioned to develop and implement the system and provided with clear guidelines about the integrity of data, the functionality of the system, and the timelines for introduction. This should include a requirement for high grade verification of users’ identity, and development of a mobile and internet-based interface to allow users to register, verify their identity, and set binding limits for expenditure and deposits into online accounts across all licensed wagering providers. These limits should be set with regard to specific time periods (per day, per week, per month, per year) and for amount of time spent wagering across all wagering providers. This system should also be required for those using terrestrial wagering services such as TAB outlets or PubTabs or telephone wagering accounts.
Would punters simply use offshore providers without gambling limits?
Some may do this, although the available evidence suggests that this did not occur to any significant extent in Norway or Sweden (Lund 2009, Rossow & Hansen 2015). The point of pre-commitment is to give gamblers a tool to manage their gambling and avoid the harm that occurs when gambling is out of the control of the user; to prevent addiction and the spiral into loss-chasing.
References
Lund, I. Gambling behaviour and the prevalence of gambling problems in adult EGM gamblers when EGMs are banned. A natural experiment. J Gambl Stud 2009;25(2):215-25. https://doi: 10.1007/s10899-009-9127-y
Productivity Commission. 2010. Gambling. (Chapter 10: Pre-commitment strategies). Productivity Commission, Canberra. Available at: https://www.pc.gov.au/inquiries/completed/gambling-2010/report
Rintoul, A & Thomas, A. 2017. Pre-commitment systems for electronic gambling machines. Australian Gambling Research Centre, Australian Institute for Family Studies. Available at: https://aifs.gov.au/resources/policy-and-practice-papers/pre-commitment-systems-electronic-gambling-machines#recent-experiences-with-pre-commitment
Rossow, I. Hansen, M. 2015. Gambling and gambling policy in Norway – an exceptional case. Addiction 111(4): 593-598. https://doi.org/10.1111/add.13172
Steve Whetton, Michael O’Neil, Professor Paul Delfabbro, Kerry Sproston, Suraya Abdul Halim, Tania Dey, Clare Hanely, Lauren Kay, Anthony Kosturjak, Katherine Tran and Alison Wood, (SACES). Evaluation of YourPlay Final Report. South Australian Centre for Economic Studies, Adelaide, 2019. Available at: https://www.justice.vic.gov.au/safer-communities/gambling/evaluation-of-yourplay-final-report
Sulkunen, P., Thomas F. Babor, Jenny Cisneros Örnberg, Michael Egerer, Matilda Hellman, Charles Livingstone, Virve Marionneau, Janne Nikkinen, Jim Orford, Robin Room and Ingeborg Rossow. 2019. Setting Limits: Gambling, Science, and Public Policy. Oxford University Press. doi: 10.1093/oso/9780198817321.003.0003
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