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Possibility of liberalizing the online gambling market
The Polish online gambling model today relies on a state monopoly in the casino segment: slots and tables are available legally through the Total Casino platform managed by Totalizator Sportowy. Sports betting - licensed to private operators. The issue of "partial liberalization" is periodically raised in the context of sewage (the flow of demand from the "gray" zone to the legal one), innovation and user convenience. Below is a systematic analysis of what liberalization can mean in practice, what are the models, risks and benchmarks.
1) Starting point: why discuss liberalization at all
Sewer and player protection. If the gray segment retains a stake due to the assortment/UX, expanding the legal offer could return the audience to RG/AML control.
Innovation and UX. Competition drives catalog updates, mobile features, payout rates, and user standards.
Fiscal effect. The wider GGR base → the potential for tax and contribution growth, provided that social risks do not increase.
Balance with societal goals. Any indulgences should be "hardwired" into the rigid framework of responsible play and advertising.
2) Partial liberalisation options (models)
Model A - Monopoly + "content outsourcing."
Totalizator Sportowy remains the only showcase, but the list of providers/contractors is expanding according to transparent criteria (RNG certification, RTP threshold, RG telemetry).
Pros: control, single UX, fast launch. Cons: limited competition, moderate pace of innovation.
Model B - Limited number of licenses (quotas).
2-5 online casino licenses on top of the monopoly on hard KPI sewerage and RG.
Pros: market incentive, more assortment. Cons: oversight is more difficult, the risk of a marketing "race."
Model C - Sandbox on subticles.
Licenses only for certain products (for example, live tables or certain types of slots) and/or for a limited period with a mandatory impact assessment.
Pros: controlled experiment. Cons: Supply fragmentation.
Model D - Aggregator/Marketplace.
The state operator is a "hub" for private mini-operators in the format of subconcessions with a unified system of logins, limits and payments.
Pros: unified RG architecture, variety of content. Cons: high technological complexity.
3) Safety norms and barriers (which is invariable in any scenario)
KYC/e-ID before first deposit, periodic re-checks.
Centralized self-exclusion and cross-operator limits (deposits/expenses/time) with a "cooling period" upon increase.
AML/CTF and behavioral scoring, device-fingerprinting, event log, suspicious transaction investigation.
Transparent RTP and RNG logging, independent certification and audit.
GDPR and cybersecurity: data encryption, access management, incident reporting.
4) Fiscal design: how to "not go too far"
Taxation base: preferably a GGR approach for casino verticals, so as not to stimulate a retreat into the shadows through margin overstatement.
Rates and thresholds: reasonable rate + license fees and warranties.
Earmarked contributions: a fixed share for sports, culture and RG programs (transparent reports).
Tax symmetry: the same rules for the monopolist and licenses (without the "hidden" advantages of one side).
5) Advertising and promo: "yes, but according to the rules"
A ban on misleading promises ("guaranteed profits"), strict age filters and time slots.
Ceilings for bonus obligations (wagers, deadlines), clear disclosure of conditions in one click.
Limiting coverage of vulnerable groups and prohibiting "aggressive reminders"; Mandatory limit tooltips.
6) Player and product impact
The range and frequency of releases are growing: more providers, seasonal series, local themes (Polish legends, sports).
UX and payout speed: competition accelerates KYC and cashouts, improves application quality.
Margins and ratios: With reasonable taxes, margin corridors can become softer, especially in mass markets.
7) Liberalization risks and how to mitigate them
Marketing escalation. Risk of "overheating" promo → bonus ceilings, audit of creatives, sanctions for violations.
The difference between UX and limits. It is solved by unified cross-operator APIs of limits/self-exclusion and mandatory RG telemetry.
The growth of the "gray" segment due to advertising. Hard "black lists" of domains + blocking payments and public reports on enforcement.
Techdolg and glitches. SLA certification (uptime, response), load tests, backup of payment channels.
8) KPIs by which it makes sense to evaluate pilots
Sewerage: the share of legal turnover in the assessment of total demand.
RG metrics: coverage with personal limits, frequency of timeouts/self-exclusions, share of support "interventions."
Payments and KYC: average verification and cashout time, share of instant payments.
Fiscal indicators: GGR and tax revenues by vertical, stability of quarterly plans.
Enforcement: Domain/payment blocking rate, repeat violations.
UX and reliability: uptime, application speed, NPS/CSAT.
9) Roadmap (conditional) 2025-2030
Stage 1 - Preparation (6-12 months).
Legal adjustments; publishing a "white paper" on sewerage and RG targets; Consultation Paper for the market; draft technical standards (KYC, API limits, reporting).
Stage 2 - Sandbox (12-24 months).
Limited licences/subtitle, quarterly public KPI reports, external impact assessment.
Step 3 - Calibration (12 months)
Correction of taxes/advertising rules according to sandbox data; extension or folding of the pilot.
Step 4 - Scaling (optional).
Transition to a stable model (Model A/B/C/D) with fixed RG/AML standards and SLA requirements.
10) Process standards for all participants
Unified register of self-exclusion and cross-operator limits (deposits/time/expenses) - through secure APIs.
Event telemetry: deposits, sessions, "reality checks," limit activation - for RG supervision.
Payment protocols: confirmation of the account holder, instant local transfers, anti-chargeback mechanics.
Antibot contours and behavioral scoring (multi-account, bonus abuse, double device).
11) What will this give the state and the market with a successful design
Budget: increased revenues due to a wider base and less "toxic" promotional expenses.
Social effect: higher coverage of RG tools, reduced "gray" risks.
Innovation and employment: demand for IT, anti-fraud, analytics, content production; service quality growth.
12) Practical checklist for responsible liberalization
1. First, KPI sewage and RG, then - the volume of licenses.
2. GGR taxation + transparent fees so as not to push margins "into advertising."
3. Uniform cross-operator limits and self-exclusion.
4. Strict advertising code with real fines and license suspension for violations.
5. Public reporting quarterly, open dashboards by main metrics.
6. Technical standards and SLA as a condition of the license (uptime, KYC, cashouts).
7. Independent RG/AML audit annually.
Liberalization of online casinos in Poland is possible in different formats - from expanding content inside a monopoly showcase to limited licenses or sandboxes. The key to a sustainable model is not "more operators at any cost," but rigid RG/AML frames, reasonable fiscal design and a measurable sewer goal. By tying competition to single limits, fast CCM/payouts, transparent advertising, and regular public reporting, the market can gain more innovation and convenience without increasing social harm - and the budget and society have stable, predictable effects.