Q 1: In your view, what is the main role of the Association in relations with the government: is it more of a lobbyist for business interests or a strategic partner and advisor?

In my view, the European Gambling and Betting Association cannot, at this moment, act mainly as a polite discussion partner for government. Its first task is to address the sector’s central structural problem. Legal operators are often regulated so heavily that they are expected to absorb every conceivable risk in advance, yet are denied the practical conditions needed to compete in a contested market.

The Association should therefore say clearly that excessive regulation does not strengthen the legal market. It weakens it and helps illegal providers. A system that keeps adding new burdens on licensed operators, without a clear idea of the market it is trying to build, is not balanced regulation. It is structural overregulation.

That is where an institution like EGBA must start. It must insist that lawful operators finally be given a real chance to compete. Only a legal market that is commercially viable can draw players away from illegal offers, generate tax revenue, and sustain meaningful consumer protection.

Q 2: To what extent does an effective dialogue exist today between the regulator and the business, and how can the Association make this communication more productive?

In my view, the dialogue between regulators and the industry often exists only on paper. There may be consultations, meetings, and official exchanges, but in substance the communication is often one-sided. Too often, the regulator approaches the market in a spirit of suspicion and risk containment. Operators, by contrast, are expected simply to absorb new burdens rather than being treated as participants in shaping a workable legal framework.

That is precisely where the Association must step in. It should make the communication more productive by forcing the real structural issues onto the table: whether the legal market can still compete, whether regulation is actually meeting its stated aims, and whether the current model is protecting consumers or simply pushing demand into illegal offers. Dialogue is not productive when the regulator speaks only in the language of restriction and the industry is left to ask for relief after the fact.

Q 3: How should the Association demonstrate to the government that over-regulating the business directly harms the country's economy and budget revenues?

The Association should make one point absolutely clear: overregulation does not remove demand, it pushes it out of the regulated market. If legal operators are burdened with excessive restrictions, costs, and compliance obligations, the result is not a safer market but a weaker legal one. That strategy directly harms player protection, tax revenue, legal employment, and the wider economic contribution of the sector.

It should also say clearly that the idea that the gambling-market might cease to exist is totally unrealistic. Gambling has been part of human life for centuries, and likely for thousands of years. No government can ignore or stop the basic human desire to gamble. The real question is therefore not whether gambling will exist, but whether it will take place in a viable legal market or increasingly outside it.

The Association should argue with a simple structural logic: the less viable the legal market becomes, the more the state loses in revenue, control, and credibility. The answer, however, cannot be quasi-authoritarian measures such as broad IP blocking or payment blocking. Even aside from their constitutional problems, such measures do not solve the real issue. The basic question is whether the legal market is regulated in a way that allows it to remain economically competitive.

Q 4: The gambling industry often has a negative public image. What role should the Association play in improving the industry's reputation in the eyes of the government?

The Association should begin from a simple point: gambling is a lawful industry like any other. The state has already made the basic political decision to allow it. Once that decision has been made, structural mistrust towards the industry is no longer a neutral regulatory stance. It begins to clash with the basic principles of equal treatment and non-discrimination.

The Association should therefore insist that licensed gambling operators must not be treated as inherently suspect simply because of the nature of their business. If an activity is legal, taxed, licensed, and supervised by the state, then the operators within that framework must be treated as lawful market participants, not as tolerated outsiders. A state cannot permit and profit from an industry while continuing to treat it with exceptional distrust.

Q 5: As Georgia is on a European path, how can the Association help the government implement European regulatory standards without shutting down the market?

First of all, it is no serious argument to say that a regulatory policy is sound or logical simply because it is described as a European standard. “European” is not, in itself, a mark of quality. That is especially true in gambling law. The European Union and the ECJ have not created a single, uniform regulatory model in this field. Most of the relevant powers still lie with the Member States. For that very reason, it is entirely possible to move closer to a European standard without repeating the same structural mistakes already visible in parts of Europe.

The Association should therefore make clear that European alignment in gambling law does not mean copying the most restrictive national models. What should be taken from Europe is a commitment to proportionality, legal certainty, consumer protection, and coherent regulation. What should be rejected is an approach that burdens the legal market so heavily that lawful operators are weakened while the underlying demand keeps on moving towards the black market.

 

 

 

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