Clarity Points
Firstly, while non-profit associations selling bingo games or lotteries do not accept payments by bank cards, they still sell through digital sales channels that accept credit cards or credit financing. The proposed ban would not affect the associations despite this flaw.
“The memorandum lacks an analysis regarding the consequences that this situation may entail for the public benefit lotteries,” SGA said.
Secondly, there is ambiguity in the interpretation of credit. The proposed credit ban only applies to account credits used to gamble. According to the regulator, since credit linked to a bank account is also account credit.
This means licence holders and gambling agents would be required to ensure that a credit space is not used for payments with debit cards.
More so, the proposed measures do not include investigative duties for licence holders and gambling agents. This makes it difficult to ensure payees check whether their debit card has credit limits with each purchase.
Finally, there are no instructions for licence holders and gambling agents to introduce technical solutions or create agreements with payment service providers. These would prevent payment through credit facilities linked to debit cards.
“Spelinspektionen instead interprets the proposal as meaning licence holders and agents may not allow such a payment if it is possible for the payee to discover without special investigative measures that the payment is made with a credit,” said the Swedish Gambling Authority.
“That is if the payee knows for some other reason that the gambling bet is financed with such credit. The scope of the proposed credit ban regarding debit cards could, for the reasons stated, be specified more clearly,” the regulator added.
Other Global Examples of Similar Measures
The measures are not unique to Sweden. In April 2020, the UK had a smooth implementation of a similar ban with no unintended consequences. In September 2023, Australia followed suit with the Interactive Gambling Amendment Bill 2023 which focused on banning credit card use.
Other countries with similar measures include Norway, Ireland and Brazil.