Public gaming: the reorganisation of the sector and the role of territorial supply. Data and proposals

Public gaming: the reorganisation of the sector and the role of territorial supply. Data and proposals

A round table was held today in Rome at the “Sala delle Bandiere” of the European Parliament in Italy, promoted by the Permanent Observatory on Games, Legality and Pathologies of Eurispes on the theme “The reorganisation of public gaming and the role of territorial supply in Italy”. The Institute has long noted the widely felt need for an overall reorganisation of the public gaming offer in our country. Repeatedly announced, and as many times postponed, today this path appears to be finally taking shape. Any further delay would be detrimental. This also considering the fact that the measures and adjustments that have been implemented over the years by the State and the Regions, outside of criteria of homogeneity, in order to respond from time to time to what emanated from the public debate, to the chase of technological developments, to the needs of the Inland Revenue or to the difficulties of entrepreneurial subjects, have created stratifications that jeopardise the very resilience of an economic sector of significant importance.

Regarding the imminent start of the discussion on the implementation of Article 15 of the enabling act on reorganisation, the hope is that, in terms of method and merit, the Government can proceed with the care that the complexity of the sector requires.

As for the method, it is essential that the debate is also developed through a new “State, Regions, Local Authorities Agreement”, which covers all channels of the public gaming offer, and that also the requests of the representatives of civil society and of the sector’s enterprises are taken into consideration, as they hold know-how that must be put at the service of the attempt to find a solution that balances the public interests involved.

In terms of merit, the aim of the reorganisation should be to work with the utmost care to produce a more advanced and secure system, but one that is compatible with the maintenance of pre-existing balances which are often already over-stressed. When working on a complex organism, it is indeed essential to take into account the impacts that each individual intervention generates on the overall framework.

In this regard, some decisive and intrinsically interconnected aspects can be highlighted.

• The proper attention that must certainly be paid to the phenomenon of the explosion of online gaming (which in 2022 absorbed 73.1 billion euro, while in the physical network it fell to 62.9 billion), must be matched by similar attention to physical gaming, which needs urgent and organic interventions. The recent elements that have come to the forefront in the public debate on the betting of well-known sports personalities through illegal platforms certainly have their relevance but, on the one hand, they cannot lead to homologating in widespread awareness the legal online offer to the illicit one, or focus so much attention as to obscure the problems of the physical network that impacts the territories to which organised crime looks with unchanged interest.

The reorganisation should work to overcome the impact of “federalism” on public gaming, i.e. the tendency of the Regions and Municipalities to legislate in random order on the distances of the gaming offer from “sensitive places” and to issue resolutions on the opening hours of the physical network offer in order to combat gaming addiction. This because the history of the last decade has demonstrated the practical impossibility of combining, for example, the application of the “distance meter” and the existence of the physical offer of public gaming. Given the awareness acquired on this aspect by most of the Regional Councils and Councils that have already worked to defer these measures, as the deadline for their enactment drew nearer, it would be desirable to return to the spirit of the 2017 Agreement on the basis of which, moreover, an important reduction in the offer has already taken place in the various territories. As far as the relationship between physical and online gaming is concerned, the lack of practicability of what has so far been put forward for combating Gambling Disorder should be noted, as it is somewhat paradoxical that the tools proposed for physical gaming (distance meter and time reduction) can be circumvented through online gaming, which remains “open” 24 hours a day and can be used via smartphones even from within “sensitive places”.

• It is necessary to avoid the marginalisation and/or outcasting of the public gaming offer, in order to preserve the objective of maintaining the function of guardian of legality that the physical network exercises, with its 85,000 points of sale. The fight against illegal gaming, as recognised by the Judiciary and the law enforcement agencies responsible for it, finds precisely in the presence of the public gaming offer an essential ally. On the other hand, the reduction and concentration of the offer in establishments dedicated exclusively to gaming, with the sacrifice of the generalist network, which for bars alone counts almost 49,000 points of sale, threatens to create, precisely, a “ghettoisation” effect that risks being amplified by the persistence of the aforementioned “federalism”.
• In the reorganisation, therefore, the important role occupied by generalist sales outlets must be recognised, as they are the places where the vast majority of social citizens-players, who consume multiple products and, as far as gaming machines are concerned, those (AWP) more classically “entertainment”; they also generate about two-thirds of the takings for the Treasury. It should also be considered that the offer of public gaming by generalist establishments relies on the essential support of the operators who, in their activities, generate work for many small and medium-sized companies, contributing to the labour-intensive connotation of the physical gaming supply chain, which employs about 140,000 people.
• Regarding the fight against Gambling Disorder, one must start from the observation of the inadequacy of the current social-health offer and work to strengthen it along with implementing prevention initiatives aimed at raising risk awareness among the younger generations. In addition to this, it is useful to enhance the role of shopkeepers who, supported by adequate and specialised continuous, compulsory and certified training, can intercept problem gambling manifestations in the bud. Trained and “networked” with local institutions and social and health services, these are precisely the subjects that should be activated, to enhance human intermediation in the exercise of gaming.
• As far as the revenue aspects are concerned, and with a view to balancing the different areas of public gaming, care must be taken not to make certain types of offerings – those already heavily burdened – less attractive to the player, with a further reduction in payout percentages; this applies especially to AWP machines. In general, it should be kept in mind that lowering the payout for physical gaming makes online gaming more attractive.
• Finally, with a glance at the European framework within which the reorganisation takes place, the protection of health, minors and public order may justify restrictions on the freedom to conduct business, but these restrictions must always be proportionate, non-discriminatory and appropriate to the pursuit of the purpose for which they were introduced. This is the European challenge of every regulated market and the central pillar of the regulatory reorganisation of the sector, which cannot look solely at increasing tax revenues.

It is essential that on the issue of the reorganisation of the public gaming offer, a wide-ranging debate should take place with the participation and contributions of all the institutional, entrepreneurial and civil society actors involved in the sector. The more in-depth this debate goes, the greater the chances of redesigning a functional system. Guaranteeing an orderly and safe entertainment offer, able to counter the area of illegality; limiting the risks of problematic behaviour in the consumption of public gaming, also by enhancing the role of duly trained operators; ensuring certain resources for the Treasury (10.2 billion euro in 2022); making it possible to consolidate an important entrepreneurial chain for the country: these are the objectives to be achieved.

Finally, Eurispes points out the need for this reorganisation process – as well as the overall public gaming offer that will result from it – to make use of studies adequate to the relevance that the sector has in the economic and social panorama of the country; studies that are currently lacking or even absent. In particular, there is a lack of an in-depth analysis of the reality of illegal gaming, both in its physical and online dimension, which is now more necessary than ever to establish a firm distinction between legal and illegal and to overcome those reconstructions that, particularly in the area of online gaming, erroneously qualify as infiltrations into the legal game those that are illicit businesses completely divorced from the gaming systems authorised and controlled by the Customs and Monopolies Agency. Gambling Disorder also requires constant studies that lead to the development of protocols suitable for the treatment of pathological subjects taken care of by Addiction Services. Eurispes intends to continue on these plans, in a line of commitment and research consolidated over the years.

The full study is available online at https://eurispes.eu/ricerca-rapporto/il-riordino-del-gioco-pubblico-e-il-ruolo-dellofferta-territoriale-2023/ after registering on our website