Discussions about the partial opening of the online market

The topic of "partial opening" of the online gambling market in Austria periodically pops up in expert circles. This is usually understood not as "complete liberalization," but as a limited admission of additional licenses and/or verticals (for example, online casinos or poker) while maintaining strict supervision, high standards of Responsible Gaming (RG) and strict advertising. Below is a systematic analysis of what may include partial discovery, which pros/cons are heard more often, and which scenarios are realistic by 2030.

1) What is "partial discovery"

Limited number of licenses in individual verticals (e.g. 3-5 federal online casino/poker licenses) under the unchanged sports betting model.

Pilot mode: temporary permits for 3-5 years with mandatory re-audit.

Geo/technical restrictions: mandatory placement of servers/logs in the EU, whitelisting payment and content providers.

A single base of self-exclusion and "hard" limits by default.

2) Arguments of the parties

"For"

Detenization and protection of players: transferring part of the demand from the "gray" segment to the licensed one with KYC/AML, limits and ombudsman.

Fiscal effect: GGR taxes and earmarked contributions to the RG prevention fund.

Technical control and integration: regulator access to telemetry, RNG/live feed audits.

"Against"

Growing online engagement: concerns about expanding the pool of players and increasing the risks of ludomania.

Surveillance spray: Resources needed to monitor more operators/affiliates.

Marketing pressure: the risk of aggressive advertising and a "bonus race" if you do not introduce a "watershed" and clear T & C.

3) Possible partial opening models

Model A - Stepped Vertical

Admission of a limited number of licenses only in online casino/poker.

Hard RG threshold: deposit/loss limits and mandatory "affordability check" to raise limits.

Recertification every 3 years.

Pros: controlled volume, fast launch.

Cons: Narrow neck risk and market concentration.

Model B - Federal Multi-Registry

Unified register of online licenses by verticals (sports, casino, poker, bingo), but with quotas and KPIs for RG.

Flexible network of tax rates by vertical.

Pros: Transparency and comparability.

Cons: Higher cost of administration.

Model C - Pilot + Sandbox

Limited pilot licenses + regulatory sandbox for innovation (e.g. strict conditions for tokenized wallets/loot box games).

"sunset clause" mode: automatic revision after 36 months.

Pros: Testing without irreversible steps.

Cons: uncertainty for investors.

4) Taxes and RG financing

Basis of taxation: transition to GGR (gross operator profit) or hybrid model GGR + fixed vertical charges.

Bet differentiation: higher rate for "high risk" mechanics (high volatility/intensity), lower for sports betting.

Earmarked contributions: a fixed percentage to the national fund for the prevention, research and treatment of gambling addiction.

5) Advertising and affiliates: "watershed"

Watershed/time slots for TV/streams, ban FOMO messages "get to the whistle."

White/black lists of tools and formats for partners; joint liability of the operator for the creativity of affiliates.

Transparent T&C: key parameters of bonuses on the first screen, prohibition of the wording "without risk."

6) RG and "affordability"

Default limits (deposits/losses/time) with an increase only after a behavioral assessment and a check document.

Single self-exclusion base for all licensed brands with 24-hour synchronization.

Personalized notifications: in-game time, net result, deposit frequency; easy timeouts and self-exclusion.

7) Process loop and compliance

KYC/AML stack: eID/Bank-ID, liveness, sanctions and PEP screenings; revalidation once every N years.

Antifraud and betting integrites: automatic alerts, stop trading in suspicious markets, agreements with sports leagues and feed providers.

Enforcement: proportional ISP/payment locks for unlicensed sites, public registry of locks and appeals.

8) Impact on stakeholders

Players

More transparency (history, reports, limits), shorter cycles of disputes.

Operators

CAPEX/OPEX growth on compliance, but predictable rules of the game and understandable payback horizons.

Marketing: focus on analytics/product quality, avoiding aggressive CTAs.

State

Detenization of demand, additional tax revenues, reduction of social costs due to RG infrastructure.

9) Scenarios to 2030

Scenario	Essence	Probability	Risk	Effect
S1. Pilot discovery	2-5 online casino/poker licenses, hard RG and advertising	High	Average	Controlled growth, detenation
S2. Multi-register	Quota opening of all verticals with diff. taxes	Average	Medium/High	Market restructuring
S3. Status quo + latky	Spot edits without license extension	Low	Low	Limited effect, gray segment retained

10) Transition roadmap (practice)

1. Legislative framework: definitions of verticals, admission criteria, tax structure, player ombudsman.

2. Regulatory acts: reporting format, API for RG/self-exclusion, requirements for logs/content certification.

3. Sandbox: pilot projects with KPIs on RG, NPS and share of calls to support.

4. Audit of affiliates: pre-moderation of landing pages, SLA for removal of violations ≤24 h, crawlers for monitoring.

5. Communications: public reports on RG metrics, transparent T&C, educational campaigns for players.

6. Assessment of results after 12-18 months: adjustment of limits, taxes, advertising "watersheds."

11) Risks and mitigation measures

Problem game growth: hard default limits, behavioral analytics, prevention fund.

Regulatory burden: phased introduction of requirements, digital dashboards for monitoring.

Marketing excesses: frequency caps, prohibition of "aggressive" live-CTA, age filters 18 +.

Legal uncertainty: sunset clauses and planned revision of norms.

12) Partial Discovery Success KPI

The share of players who switched from the "gray" segment to the licensed one.

Level of RG incidents (complaints, self-exclusions, limit violations).

Dispute resolution time (SLA of the Ombudsman/Operators).

Tax revenues and share of prevention funding.

The level of "pure" advertising (the share of compliant creatives, the rate of removal of violations).

The partial opening of the online market in Austria is not "deregulation," but a managed configuration with RG priority, transparent advertising and technological compliance. The most realistic scenario is the pilot admission of a limited number of licenses with strict limits, a sandbox and subsequent revision of the rules. This approach allows you to combine detail, fiscal effect and social risk reduction - provided that control over affiliates, advertising and behavioral protocols are not on paper, but in daily practice.