Chapter 4 - Regulating online gambling to reduce harm

  1. Regulating online gambling to reduce harm
    1. Chapter two found that, as part of a national public health strategy to reduce online gambling harm, Australia needs national regulation and a national regulator for online gambling. This chapter examines the specific elements that should be included in national regulation by considering the adequacy of current:
  • legislation and industry codes
  • consumer protections, including National Consumer Protection Framework for Online Wagering (NCPF) measures and operator-led interventions
  • enforcement and penalties
  • complaints and dispute resolution.
    1. Other issues considered are online wagering service providers (WSPs) encouraging losses while banning gamblers who win, and whether there should be exemptions that allow in-play sports betting in some circumstances.

Current regulation inadequate to reduce harm

4.3There are two possible explanations for Australia’s world-leading online gambling losses. The first is that there is a level of cultural acceptance in Australia about gambling. The second is that there is insufficient regulation of online gambling and restrictions on gambling advertising in Australia, and our federal system makes it harder to achieve consistent approaches with national reach.[1]

4.4The Alliance for Gambling Reform (AGR) described the Australian love of gambling as a ‘culturally constructed myth’:

The truth is that we've had the worst policies, the least regulation of gambling. That is why we have the greatest losses. And those losses are not a cultural, innate tendency; they're a structural certainty because of the failure of proper regulation and proper policies that other nations have had.[2]

4.5Similarly, after examining gambling harm prevention regulation in Norway, Sweden, Spain, Belgium, Netherlands, France, Ireland and the United Kingdom, MsLaurenLevin from Financial Counselling Australia (FCA) concluded ‘we are by far the worst of all the countries I went to.’[3] Ms Levin said:

With each gambling regulator, I showed them the gambling statement…from a man called Christopher. It was his betting for five weeks of gambling. On the first day of opening his account, he deposited $206,000 in eight deposits, including three of $50,000, in eight hours. He gambled for five weeks and very tragically was left with 79 cents and took his life. So I showed each regulator this and asked each of them, 'Could this happen in your jurisdiction?' They said, categorically, no.[4]

4.6According to Ms Levin, the European regulators identified mandatory deposit limits, a statutory duty of care on gambling operators and regulators having visibility of customer data through data vault facilities as the reasons why the tragedy of Christopher’s experience with online gambling couldn’t happen in their jurisdictions. They also identified banning all forms of gambling inducements, restricting gambling sponsorship, advertising and other marketing as making the most difference in gambling harm reduction.[5]

Legislation and codes

4.7The regulatory framework for online gambling includes over 60 pieces of Australian, state and territory legislation[6] and several industry codes of practice. Responsible Wagering Australia (RWA) said its members ‘are subject to over 17,000 pages of legislation and regulation nationally, whilst remaining accountable to 26 different regulatory bodies.’[7]

4.8As noted in earlier chapters, while the Australian Government currently has some responsibility for online gambling through the Interactive Gambling Act 2001 (IGA), online gambling is mainly regulated by state and territory legislation and voluntary or mandatory industry codes.

4.9The IGA prohibits a range of activities, such as online casinos, slots and poker and sports betting or wagering services offered by operators that don’t hold an Australian licence, and prohibitions on in-play and credit betting. The Australian Communications and Media Authority (ACMA) is responsible for enforcing the IGA and for administering the national self-exclusion register, BetStop, that apply to licenced online WSPs.[8]

4.10Most online WSPs are licenced in the Northern Territory, which means they are regulated under the Racing and Betting Act 1983 (Northern Territory) by the Northern Territory Racing Commission (NTRC). WSPs must also comply with the Northern Territory Code of Practice for Responsible Service of Online Gambling 2019. Breaches of this mandatory code can result in a reprimand, fine, or suspension or cancellation of a license. The code has recently been reviewed and a revised code is expected in mid-2023.[9]

4.11FCA described the Northern Territory’s code as being ‘more comprehensive than the ministerial orders and legislation in other states.’[10] FCA said that ‘the states for the most part have only codified specific items’ from the NCPF, while the Northern Territory puts a general duty on WSPs to pick up ‘red flags’ of risky customer behaviour.[11] However, the NorthernTerritory allows inducement advertising, while other states, such as NewSouth Wales and South Australia, do not.[12]

Box 4.1Case study

Mr Gavin Fineff is married with two children. Until recently, he was a senior financial planner and lived on Sydney’s north shore. MrFineff was diagnosed as having severe gambling disorder from late 2016. His gambling escalated in 2018, after he received unsolicited offers to bet with two of Australia’s largest online WSPs. In less than two years, he lost $4.4 million, including about $3.4million of his clients’ money.[13]

In April 2023, MrFineff was found guilty of 12 counts of dishonestly obtaining financial advantage by deception and sentenced to serve at least five years and four months behind bars. Mr Fineff is now in jail, bankrupt and was permanently banned from working as a financial advisor.

On 27 February 2023, the NTRC reached a decision about a dispute lodged by MrFineff in relation to Ladbrokes. The NTRC found:

The Gambler was actively targeted by a Ladbrokes’ Business Development Manager due to his knowledge or the knowledge of his supervisor that the Gambler had been sustaining heavy gambling losses with another bookmaker. Rather than making any inquiries of substance as to whether the Gambler could afford to gamble to these levels, Ladbrokes encouraged the Gambler to open a betting account with it by providing attractive bonus and deposit rebate incentives as an inducement to open a betting account and appears to have been more focused on realising its own profits from the Gambler rather than ensuring that it was providing a responsible gambling environment.[14]

The NTRC imposed three fines on Ladbrokes at the maximum penalty rate for licence breaches, totalling $78,540.[15] During the 21-month life of his Ladbrokes betting account, Mr Fineff turned over $17.5million, making a loss of $758,510.[16] The NTRC did not refer Ladbrokes to the police because it considered that Ladbrokes could not have formed reasonable suspicion that some of the funds used by Mr Fineff may have been the proceeds of crime.[17]

Mr Fineff has expressed shame and remorse for how his offending impacted his victims and how his gambling has affected his family. He provided the Committee with personal insights into how his severe gambling disorder shaped a belief that he could not lose and how this belief was further cultivated and exploited by the predatory behaviour of online WSPs.

Mr Fineff’s case demonstrates multiple points of regulatory weakness:

  • It is an example of online WSPs failing to intervene when an individual’s gambling is clearly demonstrating a high risk of harm and instead offering inducements to continue betting.
  • Staff are moving between WSPs and are taking individual’s personal information with them. They are using this to target high risk customers with inducements.[18]
  • Online WSPs are accepting and are allowed to keep stolen money, despite the obligation to ‘know your customer’ under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act), and state and territory proceeds of crime legislation.
  • The fine levelled by the NTRC against Ladbrokes was so inadequate that Ladbrokes profited from its dealings with Mr Fineff.
  • There are no pathways for Mr Fineff’s victims to get their money back from the WSPs and state and territory victims of crime compensation schemes do not provide redress for victims of fraud and theft.[19]

Consumer protections

4.12Australia’s licenced wagering providers had substantial input into the development of the NCPF.[20] RWA described the NCPF as a ‘significant, world-leading regulatory framework that RWA is fully committed to’.[21]

4.13While there was support for the concept of the NCPF,[22] which demonstrates that the Australian, state and territory governments can work together to reduce gambling harm, it has been criticised for not providing sufficient consumer protections.[23] The effectiveness of the NCPF is yet to be demonstrated, with a multi-staged evaluation commencing in 2023.[24]

4.14AGRC said that part of the difficulty in assessing the effectiveness of NCPF measures ‘is the extent to which these are known, understood, and used by consumers.’[25] AGRC explained:

Research shows that most people who wager online do not use any strategies to limit or control their gambling. For example, our baseline study of the NCPF found that less than half of participants had employed any strategies to try to limit or control the amount of time or money they spent betting online during the past 12 months. Specifically, only around one third reported that they had ‘monitored how much money they spent betting’ (39%), or that they had ‘set limits for how much they can spend each week’ (34%). Usage of the temporary self-exclusion or permanent self-exclusion options in online wagering apps/websites was particularly low at the time of data collection (4.2% and 4.7%, respectively).[26]

4.15The low uptake of such consumer protection features may be attributed to both a general lack of awareness that these tools exist, and negative perceptions (stigma) that such tools are only intended for people experiencing ‘problem’ gambling. Public awareness and education campaigns and comprehensive WSP staff training may help to increase awareness and reduce stigma surrounding these tools and increase uptake.[27]

4.16The NCPF features consumer protection measures including:

  • prohibiting lines of credit and discouraging the use of small amount credit contracts (SACCs or ‘payday loans’)
  • reducing the customer verification period to 72 hours
  • prohibiting certain types of inducements and the introduction of the national self-exclusion register, Betstop
  • making it easier for customers to close accounts
  • the availability of voluntary opt-out pre-commitment
  • providing customers with meaningful activity statements
  • the introduction of new, consistent gambling messaging about the risks and harm of gambling in all online gambling marketing
  • requiring wagering staff to be trained in responsible service.
    1. Eight of the 10 measures have already been implemented, including the introduction of new warning messages on gambling advertisements to replace the ‘gamble responsibly’ slogan. The Government has announced it will ban the use of credit cards for online wagering, and legislation is expected to be introduced this year.[28] The final measure to be introduced will be BetStop, which will allow consumers to exclude themselves from all Australian licensed wagering services. BetStop is expected to be launched in coming months.

Payment methods

4.18The Australian Government’s recent decision to ban the use of credit cards for online gambling (measure one of the NCPF) is recognition that people should not be gambling with money they do not have. However, the Committee heard that Australians are also accessing SACCs to gamble. Concerns were also raised about other payment methods.

Payday lending

4.19SACCs are loans of up to $2,000, where the term of the contract is between 16 days and 12 months. SACCs can be accessed via mobile phone apps with the potential for money to be deposited into a consumer’s bank account within minutes.[29]

4.20Measure two of the NCPF is intended to discourage the use of SACCs by online gamblers. The measure prohibits payday lending from being advertised or marketed on an interactive wagering service provider’s or affiliated organisation’s website.[30] FCA said this measure has worked to prevent online WSPs collaborating with payday lenders, but it has not prevented gamblers from taking out payday loans. FCA reported that ‘many if not most, of the financial counselling gambling clients have payday loans. So, a problem remains.’[31]

4.21Connect Health and Community reported that people who have been denied credit with mainstream lenders are accessing SACCs on a revolving basis to fund gambling, alcohol and drug use.[32]

4.22SACCs are subject to the general consumer protections that apply under the National Consumer Credit Protection Act 2009 (National Credit Act). Providers of SACCs must comply with the responsible lending obligations that require lenders to determine that the credit is not unsuitable for the consumer before providing the loan.

4.23The Financial Sector Reform Act 2022 amended the National Credit Act to impose additional obligations on providers of SACCs, including:

  • restrictions on unsolicited offers to consumers[33]
  • a new requirement for licensees to document in writing the suitability of a loan for a consumer.[34]
    1. FCA recommended that the Australian Securities and Investments Commission investigate and report on whether the payday lending sector is compliant with its responsible lending obligations, ‘vis-à-vis gambling customers.’[35]

Other payment methods

4.25The Australian Banking Association (ABA) advised that most banks have developed technological solutions to reduce gambling harm, including tools to track and cap spending and enable customer-directed blocks. Some banks have trained customer support teams and provide referrals to support services to customers that are experiencing gambling harm. Other assistance measures vary across different banks but can include immediate gambling blocks that are able to be activated via banking apps and contact centres, and delays on the removal of blocks.[36] Approximately 500,000 Australians have applied gambling blocks to their bank accounts.[37]

4.26Concerns were raised that other payment methods offer fewer protections from gambling harm. For example, the Committee heard that use of cryptocurrencies to gamble carries a higher AML/CTF risk and should be prohibited.[38]

4.27Sportsbet recommended that Buy Now Pay Later should be treated the same way as credit and should be similarly banned from gambling services.[39]

4.28The Committee also heard that POLiPayments is used by many online WSPs to facilitate fast cash transfers and enables customers to drain their bank accounts quickly.[40] POLiPayments allows funds to be deposited into a gambling account even if a person has gambling blocks set up on their bank accounts. However, POLi will allow customers to request a six-month gambling block on their POLi account.[41] The NTRC said it would be open to a ban on payments to betting accounts from POLi style payment systems.[42]

Customer verification

4.29Measure three of the NCPF reduced the period in which wagering providers must verify their customers from 90 days to 72 hours or less. The 72-hour time frame is required by the Australian Transaction Reports and Analysis Centre (AUSTRAC)’s AML/CTF rules.

4.30When asked why wagering companies are not required to ‘know their customers’ prior to opening accounts and accepting bets from them, AUSTRAC said that ‘the 72-hour time frame is a business efficacy measure for gambling services’ and explained:

Customers opening accounts online will not always be able to provide the necessary documentation when they attempt to open an account. The delay enables the customer to provide the necessary documentation at a later time, within the 72-hour time limit.

The AML/CTF risks are mitigated in this period, as the customer is not permitted to withdraw any funds from the account before they have been identified and their identity verified. Customers may also need to be identified in other circumstances, such as where a suspicious matter arises, or where it becomes necessary for other customer due diligence purposes.[43]

4.31The Committee heard that customer verification should be completed before accounts go ‘live’,[44] and that identity verification prior to wagering has been in place in the United Kingdom for some time.[45] Allowing people to gamble for three days before their identity is verified risks harm to minors and to individuals who have self-excluded and are relapsing back into harmful gambling.[46]

Risks to those under 18 years

4.32While it is illegal for Australians younger than 18 years of age to gamble, about two thirds to three quarters of children will have participated in some form of gambling in their pre-teen and teenage years.[47] A study of young men found that 23 per cent of participants first bet on sports when they were under 18 years.[48] The Committee heard that requiring customer verification before gambling would assist in preventing individuals under the age of 18years from opening accounts.[49]

4.33In February 2020, the former Standing Committee on Social Policy and Legal Affairs’ inquiry Protecting the age of innocence – Inquiry into age verification for online wagering and online pornography, recommended that the NCPF require pre-verification to prevent Australians under 18 years of age from gambling online.[50] Wesley Mission noted that, despite this, ‘it does not appear that there have been improvements to both the mechanisms of age verification, or prohibiting accepting bets until age has been verified.’[51]

4.34The Office of the eSafety Commissioner submitted a roadmap on age verification to the Australian Government for consideration in March 2023 as part of the Australian Government’s response to the former committee’s inquiry. Some options for age assurance measures were raised, including digital identity apps, physical age tokens and facial analysis technology.[52]

4.35Wesley Mission said that the current absence of a viable age verification system ‘suggests that online bookmakers are not necessarily able to securely identify minors attempting to gamble.’[53]

4.36RWA claimed its members have ‘strict age verification procedures in-place to prevent minors opening and operating accounts with our members’.[54] RWA noted that ‘if a person is verified as under 18 years of age, all deposited funds must be returned and the account immediately closed.’[55]

Implications for BetStop

4.37The Committee heard that the three-day verification window may undermine the effectiveness of BetStop. For example, the Queensland Government said ‘it is unclear how operators can prove due diligence if they have allowed an excluded individual to gamble for up to 72 hours before verifying their identity’.[56] Similarly, the NTRC said:

…if a self-excluded person in the grip of a gambling addiction is able to modify their personal details in such a way that their details are not assessed by BetStop as belonging to a self-excluded person, BetStop will not assess the person as being self-excluded, and the gambling operator will allow them to open a new account and commence gambling. Absent any other mechanism, the true identity of the person will not be revealed until the mandatory verification process has been completed by the gambling operator.[57]

4.38The NTRC noted that, under current requirements, a gambler ‘in the grip of an addiction can cause themselves (and their families and loved ones) a great deal of harm and distress in a 72-hour timeframe.’[58]

4.39ACMA noted that provision of consumer protection measures is reliant on online WSPs knowing their customers and said that pre-verification would ‘increase quality of customer data and limit the ability for consumers to provide false information to wagering providers to circumvent their exclusion with BetStop.’[59] ACMA noted that the NCPF flagged that the customer verification period will change to a customer pre-verification measure after BetStop is operational.[60]

Inducementsand VIP marketing

4.40Inducements are a type of marketing used by online gambling operators to attract new customers or to encourage existing customers to gamble. Inducements are offered via advertising and direct messaging and include offers such as deposit matches,[61] multi-bets, bonus bets, rewards programs and early cash-outs.[62] Inducements are effective in marketing gambling, especially to young people, because they encourage a belief that gambling isn’t risky and that gamblers are minimising losses.[63] However, inducements do the opposite; they increase losses by encouraging riskier bets and increased betting expenditure, and draw gamblers’ attention away from harm minimisation messages.[64]

4.41WSPs have VIP programs to incentivise the people they regard as high value customers. FCA described VIP programs as ‘incubators of consumer harm’ and said that ‘VIP gambling marketing has been documented as particularly harmful as a small cohort of people account for a disproportionate share of customer losses.’[65] The Committee heard how high value customers are individually case managed and encouraged to gamble more through personalised inducements, regardless of whether they are experiencing gambling harm.[66]

4.42Consumers can currently self-exclude from receiving marketing messages through registers operated by state and territory governments and individual wagering providers.[67] The Committee heard from several Australians who, after experiencing severe gambling harm, voluntarily closed their online betting accounts. Despite this, they were targeted with inducements, including from betting companies with which they had no prior association. The personal details of these vulnerable customers, who had clearly demonstrated high-risk gambling behaviours, were shared with competitors when staff changed jobs. Those customers were then offered inducements to gamble with the new companies, which contributed to the escalation of the customers’ gambling harm.[68]

4.43MrFineff described how he received about ‘$3.6 million of free betting money’ in inducements over a two-year period,[69] which resulted in his gambling escalating:

I would make a deposit to the operator because they gave me a significant inducement if I made a deposit. That’s what they said – for example, ‘If you make a deposit, you’ll get 50 per cent of the amount of that deposit as free bonus cash.’ Sometimes it was 100 per cent, and other times it was 30 per cent. My rationalisation and logic was that, from the money I borrowed from lenders to invest, I’d just use a small portion of that to deposit into the wagering operator to get their free cash. Then I’d use that free cash to generate some winnings; I’d withdraw the amount I original deposited, from the amount that I’d borrowed, to invest in the shares that I desired; and I’d then use the winnings to generate more winnings to repay people.

But…this never works out. I would lose the free bonus bet, and then I’d lose the deposit that I’d put in there, but the logic and rationalisation was the same, time and time again. It didn’t matter how many times I lost because I didn’t think about losing.[70]

4.44Similarly, Mr Mark Kempster lost about $100,000 over a seven-year period to online gambling, spent all his savings and redundancy payments and accessed money from his superannuation to pay off his gambling-related credit card debts. He tried unsuccessfully to quit and used the ‘take a break’ features on betting apps between 20 to 30 times. Mr Kempster said:

After I'd come back from those breaks I was offered bonus bets or deposit matches from these companies. Obviously, you'd think that, if I was taking this many breaks from their app, they'd probably realise I had a problem. But not once was I contacted by anyone around this and I was continually offered inducements when I came back. To me, this is just predatory behaviour and a complete lack of duty of care that these companies are showing to their customers.[71]

4.45Mr Aaron Smith reported that, prior to the COVID-19 pandemic, he had self-excluded from 25 to 30 online bookmakers to try to control his gambling. However, he continued to receive inducements from new market entrants via unsolicited text messages and email, and from WSPs with whom he had self-excluded.[72]

4.46Measure 4 of the NCPF introduced the following restrictions on inducements:

  • The offer of any credit, voucher, reward, or other benefit as an incentive to open an account or refer another person to open an account is prohibited.
  • Any credit, voucher, reward, or other benefit (that is directed at encouraging customers to gamble) that is not part of an approved loyalty program must not be offered in a jurisdiction that only permits such inducements as part of an approved loyalty program.
  • Winnings from a complementary betting credit or token (i.e. bonus bet) must be able to be withdrawn without being subject to any turnover requirements.
  • All direct marketing to customers may only be sent to customers who provide their express consent to receive this material.[73]
    1. FCA argued that these restrictions do not go far enough to prevent harm and noted that ‘marketing naturally flows to the unregulated gaps.’[74] FCA reported that:
  • Restrictions on incentives to open an account are being circumvented by incentives being provided just after a person’s account has been opened.[75]
  • The prohibition on referring another person to open an account are being bypassed by gambling affiliates, such as tipping sites and sport streaming services. FCA claimed that affiliates ‘receive a trailing commission on the referred person’s future net losses.’[76] FCA also claimed there are ‘affiliate staff employed by gambling operators on a commission basis, who use personal outreach to gamblers who are customers or former customers of other operators, and they offer inducements to ‘bring them over’.[77]
  • The requirement for consent to marketing is being undermined by WSPs pre-ticking consent boxes, not requesting consent at sign up, or providing inducements to those who do not complete the sign-up process and do not verify their age and identity.[78]
    1. The South Australian Liquor and Gambling Commissioner reported there is inconsistency in how the states and territories regulate inducements, noting that some inducement advertising is not allowed in South Australia but is allowed in other jurisdictions. The Commissioner said, ‘you may see ads that say, “not available to South Australian residents”. It is because of that.’[79]
    2. The Queensland Government noted that the NCPF measures still allow wagering advertising that contain inducements to participate in gambling or to bet a certain way and argued for the Australian government to take action to ensure consistency across jurisdictions and coverage of broadcasters, social media platforms and influencers, among others.[80]
    3. Similarly, Sportsbet recommended a nationally consistent framework for inducement advertising ‘to reduce customer confusion and limit the likelihood of accidental breaches by operators and/or their partners.’[81]
    4. There was strong support for greater restrictions on direct marketing of inducements and inducement advertising.[82] For example, Suicide Prevention Australia said:

Inducements to gamble and unsolicited credit offered by gambling companies that incentivise people to gamble pose harm to people unable to control their gambling habits in a safe manner. Stronger consumer protections are required to minimise harm to gamblers and ensure that those who self-exclude are not then drawn back into gambling by another company.[83]

4.52Turning Point and the Monash Addiction Research Centre said that ‘consideration should be given to prohibiting wagering services from offering any free credit, voucher, reward, or benefit to both new and existing customers.’[84]

4.53Central Queensland (CQ) University recommended that there should be strict opt-in requirements for direct messages with inducements.[85]

4.54FCA called for Australia to either ban inducements entirely, or to limit them (as Sweden has done) to a single one-off bonus over a customer’s lifetime. FCA noted that ‘removing inducements to gambling has the effect of…depleting the momentum of VIP programs, as there is little to offer in the way of inducements’.[86]

4.55RWA argued that discussions of regulating the offer of inducements should ‘start from the premise that we're dealing with responsible adults engaging in a form of entertainment’, and that to ban inducements therefore ‘would require evidence that it is a substantial evil...on the face of it, there's nothing inherently wrong with offering a reason why you'd bet with A and not with B, except to the extent that it can be established that it's significantly adding to the issue of problem gambling.’[87]


4.56When it is launched, BetStop (measure 10 of the NCPF) will allow consumers to self-exclude from all licensed online WSPs in a single process for a minimum of threemonths to a maximum of a lifetime. Once a person registers with BetStop, online WSPs must not let the person place a bet or open a new account, or send them marketing messages. If the person is an existing customer, the WSP must close their betting accounts and refund any credit.

4.57ACMA is responsible under the IGA for administering BetStop and for ensuring national compliance by around 150 licenced online WSPs. BetStop is funded by industry through a cost recovery levy. ACMA said ‘the system has been designed to cater for high-demand occasions such as Melbourne Cup Day and respond in fractions of a second.’[88] ACMA said:

…we've undertaken extensive consultation and that's involved multiple rounds of user testing with people with lived experience of gambling harm, to really get this right. We're aiming to have a process that's as simple as possible to register, of course. Testing's showing that it's about a five- to 10-minute process and doesn't take much more than opening a gambling account. It's providing your email and phone number and verifying your identity.[89]

4.58The rollout of BetStop has been delayed because the operator who was contracted to deliver it went into voluntary administration in January 2023. ACMA said it was working to establish alternative arrangements for the delivery of BetStop but was unable to provide a ‘go live’ date.[90]

4.59FCA recommended that BetStop be given ‘a generous marketing budget and a marketing plan’ and explained ‘people will need encouragement to use it as those experiencing gambling issues and addiction are likely to be ambivalent about stopping gambling.’[91]

4.60The Gambling Treatment and Research Clinic, University of Sydney (GTRC) noted that BetStop allows registrants to nominate up to five support people to assist them with their self-exclusion but does not include a third-party pathway for affected others to apply for a family member to be registered in the program.[92] GTRC recommended there be ‘a standardised assessment of third-party self-exclusion applications …conducted by an independent body, with clearly defined and delineated lines of responsibility and reporting.’[93]

Account closure

4.61Measure five of the NCPF is intended to make it easier for a customer to close their wagering account and prohibits online WSPs from marketing to a customer once the account is closed.[94] In this way, the effect of an account closure is like voluntary self-exclusion. However, according to FCA, this has caused confusion and is a weak form of protection. FCA explained:

People don’t know the difference between ‘self-exclusion’ and ‘account closure’. Some ask for their account to be closed permanently, thinking that they will never be allowed to open it. However, in practice account closure just means that the data is archived. The person then finds that they can reopen the account. On a ‘bad day’ the account is re-opened in a few minutes or sometimes there is a7-day lag. Regardless, the account gets re-opened. There might be new inducements or rewards and a vulnerable person is back to betting. Many a relapse plays out like this.[95]

4.62FCA recommended that there needs to be a single self-exclusion process and encouraged regulators to examine failed customer exit strategies. FCA called for a process to be designed and legislated that assumes ‘the person re-commencing gambling is likely to be on a relapse pathway.’[96] FCA said:

It should be enough for a customer to flag verbally or in writing that they want to stop gambling without having to use any magic words with a specific operator meaning. The penalties need to be commensurate with IGA self-exclusion breach penalties, recognising the likely harm to this extremely vulnerable cohort.

If an account has been closed, and is re-opened, a ‘vulnerability flag’ should remain on that account. The opening process must involve the person setting a modest limit commensurate with income, and proof of source of funds.[97]


4.63Measure six of the NCPF establishes a voluntary opt-out pre-commitment scheme. The measure requires online WSPs to prompt customers during the account sign-up process to set a binding deposit limit and offer other types of limits such as spend limits. Customers who want to increase their deposit limits must wait seven days for the changes to be actioned.[98]

4.64RWA said that its ‘members have long supported the mandated offering of deposit limit tools to customers and continue to conduct awareness campaigns to encourage the adoption of these tools.’[99]

4.65FCA reported that online WSPs’ systems allow people to set ‘nonsense limits such as $1 million a day’ and that some WSPs contribute to the low uptake of voluntary pre-commitment with behavioural nudges.[100]

4.66The Committee heard that opt-in consumer protection tools like deposit and spend limits are ineffective for individuals experiencing gambling harm[101] and their uptake and use by gamblers has been limited.[102] For example, GTRC said:

They provide insufficient barriers to gambling; for example, even if an individual has deposit limits, or has self-excluded or closed their account, it is not difficult to find another operator (including offshore sites) to easily and quickly open an account to allow ongoing gambling.[103]

4.67There was support for mandatory deposit limits with a single limit for a customer betting across multiple gambling operators, as has been implemented in Germany.[104] Mr Mark Kempster said that a universal deposit limit that applies to all WSPs would have prevented him from continuing to gamble with multiple different companies.[105] Similarly, when asked if voluntary limits would have prevented him from gambling, MrFineff said that ‘if there’s any pathway to change them then it doesn’t work for someone like myself.’[106]

4.68CQ University’s research with Australians struggling to control their online gambling found that those individuals ‘have explicitly said that they want regulation mandating more proactive operator practices that provide harder barriers to prevent them from gambling their life away.’[107]

4.69In Norway, the Government sets maximum limits and the regulators enforce them, but operators are expected to encourage consumers to set limits appropriate to their means. In Belgium, consumers need to put in an application to operators and provide supporting evidence in order to change their limit.[108] Germany has a ‘single player view’ with a limit of 1,000 euros across all gambling operators.[109]

4.70Dr Angela Rintoul argued that a centralised account registration system for online gambling would provide consistent consumer protections across all wagering providers. All users would set a binding limit on losses that apply cumulatively across all licensed online gambling providers. She noted that a similar system used by Norway has helped to significantly reduce gambling harm and suggested that BetStop could be used to deliver this in Australia.[110]

4.71As part of measure six of the NCPF, governments committed to assessing the feasibility and costs of a centralised pre-commitment system.[111] This work has not been progressed.[112]

4.72GTRC suggested that improvements in how gamblers access consumer protection features on products could improve their uptake. Deposit limit controls should be accompanied by more education and tools to help customers stick to their limits. Introducing friction in the process, such as having to call or text, may reduce the likelihood people increase their deposit limits. Increased friction could also reduce limit setting,[113] although the Committee notes this would be less of an issue if there was a mandatory minimum limit.

Affordability checks

4.73There was support for regulation to require affordability checks to be conducted on customers’ capacity to fund their gambling, such as when customers want to increase their deposit limit.[114] MrFineff said that if appropriate checks were carried out on his capacity to fund his gambling it is likely his gambling would not have escalated:

I ask myself, what would have stopped me? All it would have taken is a letter from the online wagering operator requesting proof of funds and affordability. Technology makes this effortless to implement – automated process can generate a letter upon a ‘trigger’, which is emailed to the customer, notification of temporary restriction is given until affordability certification is provided.[115]

4.74FCA acknowledged that ‘some operators are having robust discussions with customers about some large bets. Some are discussing “affordability” on occasions. But many others are not.’[116] FCA noted that ‘financial counsellors also see other cases where those same operators have allowed another person to spend huge, implausible sums without intervention (and some of that money is the proceeds of crime). The inconsistency is an issue.’[117]

4.75The previous chapters noted that licenced online WSPs and those who derive revenue from their products are opposed to mandatory limits. Furthermore, customers may be unwilling to provide financial documents to WSPs due to privacy and security concerns.

Activity statements

4.76Measure seven of the NCPF provides that customers should receive meaningful statements on their wagering activity from online WSPs. Research conducted by GTRC prior to this measure’s implementation indicated that, of people who used online gambling consumer protection tools, between half and three-quarters wanted to see activity statements.[118]

4.77FCA noted that measure seven is a world first, however it said there are several weaknesses in its implementation:

  • there is uncertainty around whether the Australian government or the states and territories are responsible for compliance
  • some online WSPs have deviated from the ‘best practice guide’ for the activity statements
  • online WSPs do not have to report whether a customer has opened the transaction statement, nor are they required to achieve targets
  • customers have no way of knowing how their gambling compares to other customers, and whether their gambling is risky or unsafe.[119]
    1. FCA called for the activity statements ‘to provide risk-based feedback to customers, with the opportunity to reflect and act, such as reducing their deposit limit, taking a break, or self-excluding.’[120]
    2. Turning Point and the Monash Addiction Research Centre suggested that activity statements could be ‘built upon by piloting the use of pop-up messaging, which cannot be ignored as easily as an email and can be delivered more frequently, providing users with same day or real-time updates.’[121]

Responsible service of gambling

4.80Measure nine of the NCPF requires that, from March 2023, all staff involved in the provision of wagering services, or with the capacity to influence the wagering service, must complete industry-funded responsible service of gambling training, and ongoing, annual refresher training.[122]

4.81DSS reported that the training module is based on a national unit of competency that was agreed by all state and territory skills ministers. TAFEQueensland is offering a Responsible Service of Online Wagering micro-credential and is developing the annual refresher micro-credential. To meet the NCPF requirements, online WSPs must:

  • ensure that relevant staff complete the micro-credential
  • undertake accredited training on the unit of competency, or
  • undertake internal training that is independently assessed.[123]
    1. FCA raised concerns about the quality and appropriateness of responsible service of gambling training under the NCPF:

The contracts to first design the training framework and then produce the video training and resources were given to organisations that had no experience in gambling harm. It is difficult for those not experienced in gambling harm and its idiosyncrasies and sensitivities to nail this sort of training, in the way it was conceived—as a measure to actually prevent harm. The training does not appear to have the message that in some circumstances, service must be withdrawn. Itdoes not detail, when an operator should stop ‘serving the opportunity to gamble’.[124]

4.83By contrast, Clubs Australia noted that the Responsible Conduct of Gaming training courses offered to staff in clubs in New South Wales were developed by GTRC.[125]

4.84Concerns were raised that VIP managers receive commissions based on the losses that their group of clients make.[126] Wesley Mission called for ban on commissions for referrals to any gambling product.[127]

Operator-led interventions

4.85Online WSPs are uniquely placed to identify patterns of risky behaviour and to deliver personalised interventions to reduce gambling harm, and have some obligations to do so, depending on where they are licenced. However, the evidence suggests that these obligations are not being met, or are being met inconsistently, by online WSPs, which can result in catastrophic consequences for consumers. Furthermore, concerns were raised that the methodologies used by online WSPs to identify patterns of risky behaviour that warrant interventions are not based on rigorous independent research.

4.86RWA submitted that its members ‘…are able to provide personalised interactions with customers and where necessary, implement controls at the individual account level which can have far more impact than general restrictions.’[128] RWA commented:

While ultimately customers will choose whether and how they respond to a customer safety interaction, they often result in a customer taking advantage of the range of tools available to them to better control their gambling or plant the seed to take such action in the future.

There is significant evidence to demonstrate that industry developed tools, such as time-outs, exclusions and deposit limits, are effective in creating change in customer wagering behaviour and limiting risk of the development of people experiencing gambling harm behaviours.[129]

Red flags and data monitoring systems

4.87This inquiry heard directly from individuals that online WSPs did not adequately monitor their betting activity for risky behaviour or were aware of the risks to the individual but did not do anything about it.[130]

4.88By contrast, online WSPs told the Committee that their responsible service of gambling teams monitor customers’ betting behaviour to identify red flags and intervene to minimise harm.[131] For example, RWA said its members are required under existing regulation to have policies and procedures to identify customers at risk of gambling harm and to respond appropriately. RWA commented:

The personalised data driven approach to identifying customers at risk of harm is necessary because no two customers are identical or behave the same, and no single indicator can determine risk across all customers. Areas that our members monitor include but are not limited to:

  • Changes in customer’s daily average deposits (by volume or value), with additional focus for new customers (i.e. first month of activity)
  • Changes in level of gambling spend, gambling intensity and/or time spent gambling
  • Failed payment alerts or customers cancelling large pending withdrawals.[132]
    1. Entain uses a ‘real time data monitoring system’ to identify customers exhibiting red flag behaviours. These customers are referred to Entain’s Responsible Gambling Team.[133] Entain noted that it is currently working with the University of Sydney to examine ‘the individual red flag indicators and the various weightings that we use in the algorithm to test whether we are actually identifying the customers that we need to identify.’[134]
    2. Sportsbet uses machine learning to determine gambling risk scores for every customer on a daily basis, allowing it to monitor activity and intervene quickly. Sportsbet claimed this system resulted in 97,000 interventions in 2021, including both automated and personal interactions. Sportsbet said it uses both predictive alerts from historic data and behavioural alerts from changes in customer behaviour to determine if a customer intervention is warranted.[135] Sportsbet commented:

Importantly, behavioural alerts build on the predictive model by identifying significant changes in behaviour for a particular customer. Any customers triggered would have their accounts reviewed and an intervention would take place over the phone, usually within 30 minutes of behavioural trigger, if high risk, has been identified.[136]

4.91Sportsbet provided the Committee with transcript of a phone intervention as demonstration of what it says occurs.

4.92Sportsbet said it would be happy to share its technology with its competitors and the government, and recommended that ‘these types of alerts should be mandatory, and nationally consistent, across all forms of gambling.’[137]

4.93There is concern that the red flags or risk indicators used by online WSPs may not be reliable. GTRC advised that ‘behavioural algorithms are still in an infancy stage in terms of what are the red flags or risk indicators that are reliable.’[138] GTRC said there is not yet enough evidence to say, ‘this is what you should legislate that operators have to detect and respond to’ and suggested that the government supports further research in this area to give the research legitimacy.[139]

4.94FCA noted that while the Northern Territory Code obliges online WSPs licensed by the NTRC to pick up red flags of gambling harm, ‘it doesn’t have a clear obligation on operators to do anything once they have picked up a red flag.’[140]

4.95There was support for regulation that requires WSPs to identify and respond consistently to red flags and risk indicators.[141] For example, John said Australia needs to ‘establish a national regulator with the power to ensure a consistent approach is applied by all bookmakers to customers and all red-flag behaviours are identified along with what those red-flag behaviours might look like.’[142]

4.96Mr Fineff commented:

Whilst technology is a primary reason for earlier and escalating problem gambling onset, it is also the solution. Online detection and monitoring systems already exist, and with clear and concise inputs (reform), the harm severity can stop.[143]

4.97The South Australian Liquor and Gambling Commissioner argued that governments should take strong action to ensure the development of consistent thresholds which would quickly identify those at risk of harm:

Governments should take the lead on establishing consistent, national thresholds and triggers to identify those at-risk of or currently experiencing harm. Thresholds should not be set too high, to ensure players at risk of harm are flagged early enough.

The onus must be placed on the gambling provider to intervene where indicators of gambling harm have been identified. Accounts should be suspended until the customer can confirm they are not suffering harm and affordability checks must be completed. There must also be procedures in place that prevent this data being used for any purpose besides identifying and responding to people at risk of gambling harm.[144]

4.98Both Sweden and Spain have a statutory duty of care to ensure online gambling operators are taking steps to prevent harm, while France and Denmark employ similar legal concepts.[145] Suicide Prevention Australia noted that Sweden’s statutory duty of care includes a requirement for operators to ‘continually monitor gambling patterns among players, make individual risk assessments, implement effective responsible gambling measures, and follow up on the effectiveness of responsible gambling measures.’[146]

4.99FCA proposed that Australia adopt a statutory and continuous duty of care that sets out specific expectations to reduce gambling harm.[147] FCA said ‘the serious harm that financial counsellors see in their case-work rarely fits into the boxes provided by our limited legislation’ and explained that the NCPF’s ‘ongoing weakness is that it doesn’t have an overarching requirement for operators to guard against excessive, unhealthy and damaging gambling.’[148]

Enforcement and penalties

4.100There was support for a nationally consistent regulatory framework for online gambling with robust and transparent monitoring, compliance and enforcement, and penalties that strongly discourage contravention.[149]

4.101Current penalties for breaches of online WSPs’ responsibilities to their customers neither match the seriousness of the breaches nor provide an adequate deterrent to change behaviour. For instance, the fine levelled by the NTRC against Ladbrokes represented less than onetenth of the money Ladbrokes retained from MrFineff and his victims.

4.102ACMA can issue formal warnings, infringements notices, or seek civil penalties for contraventions, and can refer complaints about criminal offences to the Australian Federal Police.[150] ACMA recommended it be given additional powers to accept enforceable undertakings and issue remedial directions, so it could compel WSPs to change their practices. This would help create a culture of compliance.[151]

4.103ACMA provided the example of its actions under the Spam Act 2003 against Sportsbet in February 2022 to show what can be achieved when regulators are given a broad suite of powers backed up by strong penalties. Sportsbet were fined $2.5million and given a three-year court-enforceable undertaking for sending more than 150,000 marketing text messages and emails to over 37,000 consumers who had tried to unsubscribe. The enforceable undertaking included an independently administered compensation program to customers of around $1.2 million.[152]

4.104As previously noted, ACMA’s regulatory role in relation to online gambling under the IGA is narrow. Much of its regulatory work focusses on the IGA’s prohibitions on casino-style services, slot machines and poker, and in-play betting on sports and racing, which are predominately offshore operations. ACMA’s enforcement of the IGA is limited by difficulty in identifying the owners of illegal offshore services.[153] Where the owners of a prohibited service are known, ACMA can impose significant civil penalties. ACMA can also impose smaller civil and criminal penalties for contraventions of advertising, lines of credit, and the National Self-Exclusion Register.[154]

4.105FCA noted that in the United Kingdom, the regulator has unlimited penalties to ‘do whatever it needs to do’ and regularly imposes very large fines.[155]

4.106The Northern Territory Government is considering new legislation to increase the regulatory powers of the NTRC, which may include the capacity to enter into enforceable undertakings and issue larger fines, and a requirement for licensees to contribute to the costs of regulation and enforcement.[156]

Crime prevention

4.107Concerns were raised that while Australia has laws preventing companies from dealing with the proceeds of crime, these are not adequately protecting victims of gambling-related offences and gambling operators are keeping stolen money.[157]

4.108The AML/CTF Act requires companies that engage in the transfer of money, including online WSPs, to conduct due diligence on customers’ sources of funds and wealth, and to report suspicious transactions over $10,000 to AUSTRAC. According to FCA, Mr Fineff’s case shows that online WSPs are not meeting these obligations.[158]

4.109Licensed online WSPs claimed they take their crime AML/CTF responsibilities seriously. For example, Sportsbet said its processes for detecting and preventing money laundering ‘are based on every customer being verified and their activities monitored for suspicious behaviour.’[159]

4.110FCA noted that many European gambling regulators and the United Kingdom Gambling Commission can investigate operator AML breaches while investigating responsible gambling breaches. FCA explained:

Responsibility for AML compliance is part of a gambling regulator’s remit. If for example, an operator is not doing ‘enhanced due diligence’ about a customer depositing a very large sum of money from an unknown source, then that operator is probably not fulfilling its obligations to prevent customer harm. Having AML investigative powers is a critical for regulators.[160]

4.111Wesley Mission observed that ‘there appear to be poor AML/CTF checks made on sources of funds’ and suggested that, if undertaken properly, these could ‘double as affordability checks to ensure people are not putting themselves at risk.’[161]

4.112In addition to the AML/CTF Act, there are a range of laws that prohibit companies from dealing in the proceeds of crime, including the Criminal Code Act 1995, the Proceeds of Crime Act 2002 and various state and territory acts. FCA argued that none of these are working to prevent online gambling companies from keeping stolen money or assist victims of crime.[162] FCA called for regulation to have a clear objective to keep gambling crime free, with guidelines to regulators to be developed by a legal taskforce.[163]

4.113Mr Andrew Wilkie MP proposed that ‘online gambling companies must be prevented from profiting from stolen money’ via his Anti-Money Laundering and Counter-Terrorism Financing Amendment (Making Gambling Businesses Accountable) Bill 2022. Mr Wilkie said the Bill would put ‘a positive obligation on companies to report to AUSTRAC if they have reason to suspect a person is paying for a gambling service with money they've obtained illegally.’[164] In cases where a person is gambling with the proceeds of crime, Mr Wilkie’s Bill would also enable the Federal Court to order the gambling company to financially compensate victims.[165]

4.114Licenced online WSPs claimed they face an unlevel playing field with land-based gambling regarding crime prevention. For example, Pointsbet noted that ‘recent arrests made for illegal betting activity on the AFL Brownlow Medal were only made possible by strict “know your customer” obligations placed on online wagering operators.’[166] Pointsbet argued that the ‘know your customer’ and other regulatory obligations placed on wagering operators should be similarly applied to cash-based forms of gambling.[167]

4.115Similarly, Sportsbet claimed ‘there is a greater risk in retail wagering of minor participation, excessive time and money spent gambling, and poor visibility over a customer’s source of funds, which can lead to a heightened Know Your Customer/Anti-Money Laundering risk environment.’[168]

Complaints and disputes

4.116The Committee understands that many Australians experience frustration when they raise complaints with online WSPs and regulators. The various existing regulations and codes provide limited consumer protections,[169] and state and territory regulators may not always handle complaints efficiently.[170]

4.117Most complaints and disputes with online WSPs must be raised with the relevant state or territory regulator in which the operator is licenced. It is up to the consumer to figure out if the operator is licenced and who they should be contacting about their complaint. This requires language, literacy and digital literacy skills that many Australians, including the most vulnerable, may not have.

4.118ACMA administers a register of licensed interactive gambling providers that operate in Australia. This register allows consumers to identify the jurisdiction where the company they want to raise a complaint about is licenced and provides the contact details of the relevant licencing authority.[171] ACMA only handles complaints about activities of unlicenced providers or if a licenced provider is offering credit or in-play betting, which are banned by the IGA. Most of the complaints ACMA receives about gambling advertising are not covered by the current rules.[172]

4.119This fragmented and inconsistent framework for complaints and disputes can lead to poor outcomes for consumers. For example, an individual who ‘had a special disadvantage by reason of an abnormal, pathological interest in gambling, rendering him unable to make decisions in his own self-interest’ was induced to open accounts with a WSP that was licenced by the Norfolk Island Gaming Authority (NIGA).[173] NIGA was shut down in 2016 following a performance review conducted by the Australian Government, which found it failed to fulfil its regulatory role to an acceptable level, was ‘grossly under-resourced’ and lacked basic internal controls.[174] WSPs previously licenced by NIGA took out new licences with the NTRC in August2016. The individual attempted to raise a complaint with the NTRC but was advised that the NTRC could not review any of the alleged activity because it occurred prior to August 2016.[175]

4.120There was support for an online gambling ombudsman to be established to handle all complaints about online WSPs.[176]

Encouraging losses, banning those who win

4.121While this inquiry focussed on gambling harm, the Committee also heard from Australians who do not consider themselves to be experiencing harm and who say that the current regulatory system is not fair for them. It appears that online WSPs are encouraging gambling losses while banning some individuals who win. Concerns were raised that online WSPs will reduce allowed bets or block access to customers when they are winning,[177] while encouraging the highest risk customers, who lose the most money and experience the most harm.[178]

4.122Online WSPs were indirect in their responses to the Committee’s questions about whether so-called ‘successful’ gamblers were banned. Sportsbet claimed it only blocked customers in a very narrow range of cases, stating ‘if we believe that they're acting with information that the rest of the market doesn't have, and if their behaviour is distorting the market, which means that other customers' experience is affected, then we will take action’.[179]

4.123Entain responded:

In relation to minimum-bet limits, where the customer is betting on an Australian racing event, there absolutely are bets that we are required to take, and we would take a bet from all customers. For some other events where there's less liquidity and less certainty in relation to the markers, we may impose some restrictions on a small number of customers.[180]

4.124RWA said that blocking gamblers who are winning was not industry practice but noted that ‘…inevitably, there will be occasions when a customer is excluded and there doesn't appear to be any adequate explanation other than they're winning.’[181]

4.125There was support for increased transparency around why online WSPs close customers’ accounts and for there to be consistently applied minimum bet limits for all sports betting and racing.[182]

4.126Associate Professor Charles Livingstone said that national regulation should allow Australians to realise their skills by winning a reasonable amount if they have figured out a method for doing so. He said:

This is a real scandal in the United Kingdom that has given rise to a very successful advocacy network called Justice for Punters, which is constantly advocating for reasonable minimum bets for people who are good at predicting outcomes of sporting events. If the punters are able to win consistently, my view is they should be rewarded for that, up to a point—bearing in mind that they are few in number and, as a proportion of everyone who bets, minuscule.[183]

Other issues

4.127Some Australians who gamble support a relaxation of restrictions on online in-play sports betting, which is currently prohibited under the IGA.[184] In-play or ‘live betting’ allow bets to be placed after a sporting event has begun, for example on the next goal in a football match. In-play betting is allowed at electronic betting terminals at retail outlets and through telephone betting services.[185] Some online WSPs, such as Sportsbet, provide ‘fast codes’ for specific in-play bets on their online platforms to speed up interactions on their telephone services.

4.128ACMA said that online in-play sports betting is prohibited under the IGA because it enables fast gambling. The IGA does not prohibit telephone betting services from offering in-play sports betting because ‘these services have a level of supervision or personal interaction that reduces the risks associated with in-play betting.’[186] Similarly, ‘the in-play betting prohibition does not apply to horse, harness or greyhound races as these shorter events do not provide the same opportunity for rapid-style betting.’[187]

4.129Some Australian gamblers feel they are being disadvantaged because they cannot place online in-play bets while overseas gamblers can. MrScottSinclair said:

The current playing field is not level with overseas bettors being able to place their bets within seconds whilst telephone players are faced with delays measured in minutes not seconds, particularly if it is a popular event. By the time a local punter rings up to take a price it has in many cases been taken by a punter based outside Australia.[188]

4.130There was support for closing the loophole that allows telephone services to accept in-play bets. Wesley Mission described the ability to place in-play bets over the phone as a gap in consumer protections.[189] Turning Point and the Monash Addiction Research Centre recommended that all in-play betting be banned, including via telephone services, because ‘people who bet in-play experience significantly greater gambling harm.’[190]

Committee comment

4.131Australia has the highest online gambling losses in the world, per capita, because of regulatory failure. We have been taught to believe we are a culture of gamblers by the advertising budgets of multinational gambling companies competing for market share of our losses. But the reality is that we lose so much because our gambling regulation is too weak.

4.132For many people, online gambling does not lead to significant harms. However, adding a modest amount of friction to online gambling for everyone, to help people make safe decisions and to keep gambling crime free, is not unreasonable given the harms online gambling does cause to too many Australians.

4.133The ban on the provision of credit by online WSPs and the use of credit cards for online gambling is recognition that people should not be gambling with money they do not have. As such, there is a need to ensure the compliance of the SACC sector with their responsible lending obligations relating to customers who gamble, following the Australian Government’s 2022 reforms.

Recommendation 12

4.134The Committee recommends that the multi-stage evaluation of the NationalConsumer Protection Framework for Online Gambling (NCPF), due to commence in 2023, includes an investigation into whether the small consumer credit contract sector is complying with its responsible lending obligations to customers who gamble.

4.135While most Australian banks have introduced measures to assist their customers in managing their gambling, such as gambling blocks on accounts, there is inconsistency in the approaches taken by individual banks.

Recommendation 13

4.136The Committee recommends that the Australian Government work with the Australian Banking Association to develop a set of minimum gambling consumer protection standards for implementation by all banks, including a block on gambling merchant categories for self-excluded individuals using BetStop. If agreement is unable to be reached, minimum standards should be mandated in legislation.

4.137Other payment methods do not offer similar protections and allow Australians to bypass the blocks they have placed on their bank accounts. Some payment methods are widely accepted by illegal online gambling operators and may facilitate criminal activity.

Recommendation 14

4.138The Committee recommends that, in developing national regulation, the Australian Government conduct a risk assessment of available payment methods. Payment methods that do not minimise the risk of criminal activity and gambling harm should be prohibited from being used for online gambling.

4.139Allowing WSPs 72 hours to verify their customers creates a window of opportunity for minors to gamble and for the highest risk gamblers to circumvent self-exclusion. AUSTRAC’s description of the 72-hour window for gambling companies to verify their customers as a business efficacy measure demonstrates that we should not be relying on AUSTRAC to reduce gambling harm.

Recommendation 15

4.140The Committee recommends that national regulation should require customers’ identities to be verified prior to the commencement of online gambling.

4.141An industry that encourages losses from people who cannot afford to lose while banning people who win deserves to be called out. While inducements, inducement advertising and VIP programs are used by online WSPs to attract customers and develop market share, they can also do this by offering fair value and showing that they care for their customers. The Committee notes that inducements and VIP programs are also used to entice individuals to return to betting after a time out, or to continue to bet and lose. There is no doubt that banning inducements and inducement advertising is a key measure for reducing online gambling harm and ensuring that one of the significant incubators of gambling harm, VIP programs, have no place in Australia.

Recommendation 16

4.142The Committee recommends that the Australian Government prohibit all online gambling inducements and inducement advertising, and that it do so without delay.

4.143The unforeseen delay to the implementation of BetStop is disappointing. BetStop has the potential to be a powerful consumer protection tool once there is a requirement that a customer’s identity is verified before they are allowed to open an account. Until then, it is likely to be effective for most Australians, but may not offer protections for those who are at the highest risk of gambling harm. While this should not further delay the rollout of BetStop, the integration of identity pre-verification should be of the highest priority.

4.144While there is evidence suggesting that universal mandatory pre-commitment, with a requirement for individuals to prove they can afford to gamble at higher levels, may offer the best protection for people who are struggling to control their gambling, this may be too much of an imposition for most people who gamble. Customers should be encouraged to set deposit and bet limits that are safe for them and be provided with research-informed education and tools to help them bet within their limits. Further work is needed to demonstrate that universal mandatory pre-commitment will, on balance, lead to better outcomes in Australia, noting that the other reforms recommended in this report should substantially reduce online gambling harm.

Recommendation 17

4.145The Committee recommends that the evaluation of the NCPF:

  • analyse deidentified customer data to determine whether voluntary pre-commitment is working to reduce harm
  • examine the strengths and weaknesses of universal, mandatory pre-commitment systems overseas, in comparison to Australia’s current voluntary system, and undertake further reforms if it can be demonstrated that an alternative approach will drive improved outcomes overall.
    1. While some licensed online WSPs are developing practices and technology to allow them to be more systematic and rigorous in managing risk and harm, much more work needs to be done. There needs to be a legal requirement that online WSPs demonstrate a duty of care to their customers. A WSPs’ performance should be assessed against a set of standard indicators of risk and harm to determine whether they are meeting their duty of care to customers.
    2. The national regulator should develop clear legal obligations and research informed guidelines for consistent, minimum WSP practices in responsible service of online gambling.

Recommendation 18

4.148The Committee recommends that national regulation impose a customer duty of care on online WSPs. An online WSPs’ compliance with this legal duty should be assessed against a set of standard indicators of risk and harm.

4.149The Committee welcomes Sportsbet’s willingness to share its propriety behavioural algorithm with its competitors and government, although notes that the technology’s effectiveness requires further research. A standard behavioural algorithm, based on a set of risk and harm indicators, could significantly improve early identification of risky behaviour and enable appropriate interventions. It would also help ensure consistency of practice in the responsible service of gambling.

Recommendation 19

4.150The Committee recommends that the Australian Government should investigate the benefits and feasibility of requiring online WSPs to apply a standard behavioural algorithm to reduce online gambling harm.

4.151The Committee is concerned to ensure that the training requirements and curriculum being provided to gambling staff in Australia is adequately informed by research.

4.152Following the implementation of national regulation, online gambling staff should be required to demonstrate a sound awareness of the new legal obligations and guidelines for practice in responsible service of online gambling. This may require the national unit of competency, CHCFIN005 - Provide responsible online wagering services, to be updated. Research-informed curriculum should be developed based on the national regulation and regulatory guidelines for operators.

Recommendation 20

4.153The Committee recommends national regulation require online WSP staff to undertake research-informed training that demonstrates a sound awareness of the legal obligations and guidelines for practice in responsible service of online gambling. Staff should also undertake annual refresher training.

4.154Harmful industries should not be allowed to pay commissions to incentivise the harm they cause.

Recommendation 21

4.155The Committee recommends national regulation prohibit commissions being paid to staff or any third party involved in the referral or provision of online gambling to an individual.

Recommendation 22

4.156The Committee recommends that national regulation include provisions to prevent the proceeds of crime from being used to fund online gambling. Alegal taskforce should be established as soon as practical to develop these provisions.

4.157Requiring online WSPs to have strong legal obligations to their customers must be supported by a strong and well-resourced monitoring, compliance, and enforcement regime.

4.158Current penalties for serious breaches of WSPs’ legal obligations, where they exist, are manifestly inadequate, as was highlighted by the NTRC’s fine against Ladbrokes in Mr Fineff’s case. There should be a low threshold for what is considered a serious contravention, and penalties of a scale that act as genuine deterrent to multinational gambling companies breaching their legal obligations. The regulator needs a broad suite of powers so that enforcement decisions can be targeted at particular activities, can compel behavioural change and create a culture of compliance.

Recommendation 23

4.159The Committee recommends that the national regulator be provided with a broad suite of powers to monitor online gambling, ensure compliance and enforce the law. Penalties should be severe enough to be a genuine deterrent to multinational corporations breaching their legal obligations.

4.160Australians should have a single point of contact for raising complaints about the behaviour of online WSPs, which provides timely and efficient dispute resolution.

Recommendation 24

4.161The Committee recommends that the Australian Government establish an appropriately resourced national online gambling ombudsman, to sit within the national regulator.

4.162Evidence to this inquiry shows that online WSPs have heavily incentivised the gambling of Australians who experience the most gambling harm, while banning some who win more than others. These revelations are extraordinarily damning for an industry that claims to provide entertainment and whose business model depends on customers having faith they will be paid when they win. The Committee suggests that it is in the industry’s best interests to agree to modest minimum bet limits to demonstrate good faith with their customers.

Recommendation 25

4.163The Committee recommends the Australian Government consult with industry and people who gamble to determine minimum bet limits for online wagering for inclusion in national regulation.

4.164While outside of the scope of this inquiry, the Committee notes that extending regulatory requirements and consumer protection measures to land-based WSPs would create a level playing field and provide greater safeguards for people who gamble.


[1]Ms Liz Hefren-Webb, Deputy Secretary, Families and Communities, Department of Social Services (DSS), Committee Hansard, 23November 2022, pages 5 and 7.

[2]Reverend Tim Costello, Chief Advocate, Alliance for Gambling Reform (AGR), Committee Hansard, 5December 2022, page 1.

[3]Financial Counselling Australia (FCA), Exhibit 20, ‘The sky didn’t fall in’, Winston Churchill Trust, March2023.

[4]Ms Lauren Levin, Director, Policy and Campaigns, FCA, Committee Hansard, 28 March 2023, page 1.

[5]Ms Lauren Levin, FCA, Committee Hansard, 28 March 2023, page 1.

[6]Salvation Army, Submission 43, page 11.

[7]Responsible Wagering Australia (RWA), Submission 106, page 2.

[8]Australian Communications and Media Authority (ACMA), Submission 96, page 1. ACMA is also responsible for regulating gambling advertising on broadcast television and radio, and online in conjunction with live sport.

[9]Northern Territory Racing Commission (NTRC), Submission 143, pages 1-2.

[10]FCA, Submission 152, page 47.

[11]FCA, Submission 152, pages 36 and 47; NTRC, NT Code of Practice for Responsible Service of Online Gambling 2019, ‘Item 3.2 Recognising potential problem gamblers’, March 2023.

[12]RWA, Submission 106.2, page 1.

[13]Mr Gavin Fineff, Committee Hansard, 21 March 2023, page 4.

[14]NTRC, Decision Notice, ‘Entain Group Pty Ltd (Ladbrokes), Investigation by the Northern Territory Racing Commission (Concerning Dealings with Gambler – MrF)’, 27 February 2023, page 20.

[15]NTRC, Decision Notice, ‘Entain Group Pty Ltd (Ladbrokes), Investigation by the Northern Territory Racing Commission (Concerning Dealings with Gambler – MrF)’, 27 February 2023, page 23.

[16]NTRC, Decision Notice, ‘Entain Group Pty Ltd (Ladbrokes), Investigation by the Northern Territory Racing Commission (Concerning Dealings with Gambler – MrF)’, 27 February 2023, pages 2 and 16.

[17]NTRC, Decision Notice, ‘Entain Group Pty Ltd (Ladbrokes), Investigation by the Northern Territory Racing Commission (Concerning Dealings with Gambler – MrF)’, 27 February 2023, page 21.

[18]See also, Name withheld, Submission 161, pages 3-6, 9 and 17.

[19]FCA, Submission 152, pages 32-33.

[20]RWA, Submission 106, page 1.

[21]RWA, Submission 106, page 2.

[22]Queensland Government, Submission 140, page 7; Entain, Submission 61, page 4; RWA, Submission 106, page 2.

[23]Australian Psychological Society, Submission 109, page 3; Wesley Mission, Submission 85, page 4; STRSConsultants, Submission 28, page 1.

[24]DSS, Submission 87, page 2.

[25]AGRC, Submission 76, page 3.

[26]AGRC, Submission 76, pages 3-4.

[27]AGRC, Submission 76, pages 3-4.

[28]The Hon Amanda Rishworth MP, Minister for Social Services and The Hon Michelle Rowland MP, Ministerfor Communications, ‘Albanese Government will ban credit cards for online wagering’, Mediarelease, 28April 2023.

[29]Australian Psychological Society, Submission 111, page 5.

[30]DSS, National Consumer Protection Framework for Online Wagering, November 2018 (updated May 2022), page 7.

[31]FCA, Submission 152, page 38.

[32]Connect Health and Community, Submission 111, page 2.

[33]Financial Sector Reform Bill 2022 Explanatory Memorandum, para 4.74.

[34]Financial Sector Reform Act 2022, sch. 4, s. 14.

[35]FCA, Submission 152, page 38.

[36]Australian Banking Association (ABA), Submission 84, page 1.

[37]Ms Anna Bligh, Chief Executive Officer, ABA, Committee Hansard, 4 April 2023, page 2.

[38]Government of South Australia, Liquor and Gambling Commissioner, Submission 121, page 7; Sportsbet, Submission 81, page 3.

[39]Sportsbet, Submission 81, page 3.

[40]Name withheld, Submission 153, page 1; Connect Health and Community, Submission 111, page 3.

[41]POLi Payments, Contact us, ‘Greater support for gamblers and other POLi Service customers’,, viewed 29 March 2023.

[42]NTRC, Submission 143, page 4.

[43]Australian Transaction Reports and Analysis Centre (AUSTRAC), Submission 135, page 1.

[44]Connect Health and Community, Submission 111, page 4; Queensland Government, Submission 140, page7; NTRC, Submission 143, pages 3-4; Central Queensland (CQ) University, Submission 24, page 7; MrAlastair Shields, Chairperson, NTRC, Committee Hansard, 28 February 2023, page 40.

[45]NTRC, Submission 14, page 4.

[46]FCA, Submission 152, page 11.

[47]Association of Heads of Independent Schools of Australia (AHISA), Submission 62, page 11.

[48]AGRC, Submission 76, page 10; Seealso: Zoe Peet, Submission 94, page 5.

[49]NTRC, Submission 14, page 4.

[50]House of Representatives Standing Committee on Social Policy and Legal Affairs, Protecting the age of innocence – Inquiry into age verification for online wagering and online pornography, February 2020, pagexvi.

[51]Wesley Mission, Submission 85, page 3.

[52]Office of the eSafety Commissioner, Age verification, ‘Age assurance measures and alternative safety tech’, March 2023,, viewed 17 May 2023.

[53]Wesley Mission, Submission 85, pages 3-4.

[54]RWA, Submission 106, page 3.

[55]RWA, Submission 106, page 12.

[56]Queensland Government, Submission 140, page 7; NTRC, Submission 14, pages 3-4.

[57]NTRC, Submission 14, pages 3-4.

[58]NTRC, Submission 14, page 4.

[59]ACMA, Submission 96, page 15.

[60]ACMA, Submission 96, page 15. See also, DSS, National Consumer Protection Framework for Online Wagering, November 2018 (updated May 2022), page 8.

[61]Mr Gavin Fineff, Committee Hansard, 21 March 2023, page 5.

[62]Turning Point and the Monash Addiction Research Centre, Submission 68, page 8; CQ University, Submission 24, page 6-7.

[63]Professor Samantha Thomas, Dr Hannah Pitt and Dr Simone McCarthy, Submission 126, page 7.

[64]CQ University, Submission 24, page 4.

[65]FCA, Submission 152, pages 29-30, 40.

[66]FCA, Submission 152, page 29; Name withheld, Submission 161, pages 6-11.

[67]Department of Infrastructure, Transport, Regional Development and Communications and the Arts (DITRDCA), Submission 104, page 4.

[68]Mr Gavin Fineff, Committee Hansard, 21 March 2023, pages 4-5; Mr Mark Kempster, Committee Hansard, 10 February 2023, page 8; Mr Aaron Smith, Committee Hansard, 10February 2023, pages 3-5; Namewithheld, Submission 161, pages 8-11.

[69]Mr Gavin Fineff, Committee Hansard, 21 March 2023, page 4.

[70]Mr Gavin Fineff, Committee Hansard, 21 March 2023, page 5.

[71]Mr Mark Kempster, Committee Hansard, 10 February 2023, page 8.

[72]Mr Aaron Smith, Committee Hansard, 10 February 2023, pages 3-5.

[73]DSS, National Consumer Protection Framework for Online Wagering, November 2018 (updated May 2022), page 8.

[74]FCA, Submission 152, page 39.

[75]FCA, Submission 152, page 39.

[76]FCA, Submission 152, page 39.

[77]FCA, Submission 152, page 39.

[78]FCA, Submission 152, pages 39-40.

[79]Mr Dini Soulio, Liquor and Gambling Commissioner, Government of South Australia, Committee Hansard, 28February 2023, page 51.

[80]Queensland Government, Submission 140, page 3.

[81]Sportsbet, Submission 81, page 4.

[82]FCA, Submission 152, pages 30 and 40; Connect Health and Community, Submission 111, page 5; HobsonsBay City Council, Submission 38, page 2; Suicide Prevention Australia, Submission 41, pages 2 and 9; AGR, Submission 48, page 2; Turning Point and the Monash Addiction Research Centre, Submission68, page 12; The Synods of Western Australia and Victoria and Tasmania, Uniting Church in Australia, Submission 86, page 1; Queensland University of Technology, Submission 91, page 3; Zoe Peet, Submission 94, page 3.

[83]Suicide Prevention Australia, Submission 41, pages 2 and 9.

[84]Turning Point and the Monash Addiction Research Centre, Submission 68, page 12.

[85]CQ University, Submission 24, pages 6-7.

[86]FCA, Submission 152, page 40.

[87]Mr Nick Minchin, RWA, Committee Hansard, 4April2023, page 55.

[88]ACMA, Submission 96, page 9.

[89]Mr Matthew Anderson, Manager, National Self-Exclusion Section, ACMA, Committee Hansard, 4April 2023, page71.

[90]Ms Cathy Rainsford, General Manager, ACMA, Committee Hansard, 4 April 2023, page71.

[91]FCA, Submission 152, page 42.

[92]Gambling Treatment and Research Clinic, University of Sydney (GTRC), Submission 65, page 10.

[93]GTRC, Submission 65, page 10.

[94]DSS, National Consumer Protection Framework for Online Wagering, November 2018 (updated May 2022), page 9.

[95]FCA, Submission 152, page 41.

[96]FCA, Submission 152, pages 41-42.

[97]FCA, Submission 152, page 41.

[98]DSS, National Consumer Protection Framework for Online Wagering, November 2018 (updated May 2022), page 10.

[99]RWA, Submission 106.2, page 2.

[100]FCA, Submission 152, page 42.

[101]GTRC, Submission 65, page 4; CQUniversity, Submission 24, page 6.

[102]CQ University, Submission 24, page 2; GTRC, Submission 65, page 4; STRSConsultants, Submission 28, page 1; FCA, Submission 152, page 42.

[103]GTRC, Submission 65, page 4.

[104]FCA, Exhibit 20, ‘The sky didn’t fall in’, Winston Churchill Trust, March 2023, page 8; CQ University, Submission 24, page 6; Professor Nerilee Hing, Research Professor, Gambling Studies, ExperimentalGambling Research Laboratory, CQ University, Committee Hansard, 28 March 2023, page 6; CQUniversity, Submission 24, page 6.

[105]Mr Mark Kempster, Committee Hansard, 10 February 2023, page 13.

[106]Mr Gavin Fineff, Committee Hansard, 21 March 2023, page 6.

[107]CQ University, Submission 24.1, page 2.

[108]Ms Lauren Levin, FCA, Committee Hansard, 28 March 2023, page 6.

[109]Ms Lauren Levin, FCA, Committee Hansard, 28 March 2023, page 5.

[110]Dr Angela Rintoul, Submission 150, page 2.

[111]DSS, National Consumer Protection Framework for Online Wagering, November 2018 (updated May 2022), page 11.

[112]Mr Patrick Burford, Group Manager, Communities, DSS, Committee Hansard, 4 April 2023, page68.

[113]GTRC, Submission 65, page 5.

[114]Mr Gavin Fineff, Submission 7, page 7; Care Incorporated, Submission 45, page 5; ProfessorSallyGainsbury, Director, GTRC, Committee Hansard, 1 March 2023, page 39; GovernmentofSouth Australia, Liquor and Gambling Commissioner, Submission 121, page 4; Namewithheld, Submission 112, page 4; Anna Bardsley, Submission 128, page 3; AGR, Submission 48, page 2; John, Committee Hansard, 5December 2022, page 12.

[115]Mr Gavin Fineff, Submission 7, page 7.

[116]FCA, Submission 152, page 37.

[117]FCA, Submission 152, page 37.

[118]GTRC, Submission 65, page 5.

[119]FCA, Submission 152, pages 43-44.

[120]FCA, Submission 152, page 44.

[121]Turning Point and the Monash Addiction Research Centre, Submission 68, page 12.

[122]DSS, National Consumer Protection Framework for Online Wagering, November 2018 (updated May 2022), page 15.

[123]DSS, Submission 87, page 4.

[124]FCA, Submission 152, pages 44-45.

[125]Clubs Australia, Submission 124, page 4.

[126]Mr Gavin Fineff, Committee Hansard, 21 March 2023, page 4; Ms Lyn McDermott, Submission 27, pages2-3.

[127]Wesley Mission, Submission 85, page 2.

[128]RWA, Submission 106, page 7.

[129]RWA, Submission 106, page 7.

[130]Mr Gavin Fineff, Submission 7, page 5; John, Submission 37, page 4; John, Committee Hansard, 5December 2022, pages11 and 13; Mr Aaron Smith, Submission 12, page 1; Mr Mark Kempster, Submission 26, page 2; Mr Michael Depangher, Submission 136, page 2.

[131]PointsBet Australia, Submission 105, page 2; RWA, Submission 106, page 7; Entain, Submission 61, page6.

[132]RWA, Submission 106, page 7

[133]Entain, Submission 61, page 6.

[134]Mr Stephen Lang, Director, Regulatory Strategy and Safer Gambling, Entain, Committee Hansard, 4April2023, page 21

[135]Sportsbet, Submission 81, pages 5-6.

[136]Sportsbet, Submission 81, page 6.

[137]Sportsbet, Submission 81, pages 6 and 9.

[138]Professor Sally Gainsbury, GTRC, Committee Hansard, 1 March 2023, page 39.

[139]Professor Sally Gainsbury, GTRC, Committee Hansard, 1 March 2023, page 39.

[140]FCA, Submission 152.2, page 2.

[141]AGRC, Submission 76, page 5; The Synods of Victoria and Tasmania, Uniting Church in Australia, Submission 86, page 1.

[142]John, Committee Hansard, 5December 2022, page 13.

[143]Mr Gavin Fineff, Submission 7, page 7.

[144]Government of South Australia, Liquor and Gambling Commissioner, Submission 121, page 4.

[145]FCA, Submission 152, page 47; FCA, Submission 152.2, page 1.

[146]Suicide Prevention Australia, Submission 41, page 5.

[147]FCA, Submission 152.2, page 2.

[148]FCA, Submission 152.2, page 1.

[149]Royal Australian and New Zealand College of Psychiatrists and Royal Australasian College of Physicians, Submission 110, page 9; AGRC, Submission 76, page 11; Government of South Australia, LiquorandGambling Commissioner, Submission 121, page 4; Mr Gavin Fineff, Submission 7, page 7; AssociateProfessor Charles Livingstone, Committee Hansard, 28 February 2023, page 24.

[150]DITRDCA, Submission 104, page 16.

[151]ACMA, Submission 96, page 11.

[152]ACMA, Submission 96, page 11.

[153]ACMA, Submission 96, pages 6 and 11; Ms Cathy Rainsford, General Manager, ACMA, CommitteeHansard, 30 November 2022, page 7.

[154]DITRDCA, Submission 104, page 16.

[155]FCA, Submission 152, page 34.

[156]NTRC, Submission 143, page 2.

[157]FCA, Submission 152, page 22.

[158]FCA, Submission 152, page 31.

[159]Sportsbet, Submission 81, page 10.

[160]FCA, Submission 152, page 47.

[161]Wesley Mission, Submission 85, page 4.

[162]FCA, Submission 152, page 22.

[163]FCA, Submission 152, page 10.

[164]Mr Andrew Wilkie MP, Submission 79, page 1.

[165]Mr Andrew Wilkie MP, Submission 79, page 1.

[166]Pointsbet, Submission 105, page 3.

[167]Pointsbet, Submission 105, page 4.

[168]Sportsbet, Submission 81, page 9.

[169]Mr Shaun McDonough, Submission 17, page 3.

[170]FCA, Submission 152, pages 6 and 9.

[171]Australian Communications and Media Authority (ACMA), Check if a gambling operator is legal,, accessed 4 May 2023.

[172]ACMA, Submission 96, page 16. See also, Chapter four.

[173]Name withheld, Submission 161, pages 11 and 18.

[174]DITRDCA, Performance review Norfolk Island Gaming Authority, 30 June 2016, page 4.

[175]Name withheld, Submission 161, page 18.

[176]FCA, Submission 152, page 9; AGR, Submission 48, page 10; Salvation Army, Submission 43, page 11; Wesley Mission, Submission 85, page 2; Dr Sophie Scamps, Submission 100, page 6; Hobsons Bay City Council, Submission 38, page 3.

[177]Name withheld, Submission 144, page 1; S Cannane and K Taylor, ‘In this sports betting company, the winners are called 'problem customers'’, ABC News, 5 December 2019.

[178]Name withheld, Submission 31, page 1; Name withheld, Submission 63, pages 3-5.

[179]Mr Barni Evans, Chief Executive Officer, Sportsbet, Committee Hansard, 4 April 2023, page 46.

[180]Mr Steven Lang, Director, Regulatory Strategy and Safer Gambling, Entain Australia, Committee Hansard, 4April 2023, page 24.

[181]Mr Nick Minchin, Chairman, RWA, Committee Hansard, 4 April 2023, page 55.

[182]Mr Richard Irvine, Submission 107, page 2; Name withheld, Submission 63, page 3-5.

[183]Associate Professor Charles Livingstone, Committee Hansard, 28 February 2023, page 3.

[184]Mr Richard Irvine, Submission 107, page 2; Mr Scott Sinclair, Submission 108, page 1.

[185]ACMA, Submission 96, page 7.

[186]ACMA, Submission 96, page 7.

[187]ACMA, Submission 96, page 7.

[188]Mr Scott Sinclair, Submission 108, page 1.

[189]Wesley Mission, Submission 85, page 4.

[190]Turning Point and the Monash Addiction Research Centre, Submission 65, page 14.