The EGBA declared that the new European protocol, EN 18144:2025, was published on May 31st, 2026. The document was developed through CEN’s National Standardisation Bodies (NSB).
Several niche representatives shared their opinions on the initiative. Among them are:
- Björn Fuchs, Janshen-Hahnraths Group’s Deputy CEO;
- Dr Joerg Hofmann, Melchers Law Firm’s Senior Partner;
- Dr Andreas Ditsche, igaming.com’s CEO;
- Dr Christian Piska, the University of Vienna’s associate professor (Law);
- Sarah Gardner, the UKGC’s Deputy CEO.
Casino Market has analysed these experts’ comments to highlight their key thoughts on the indicators of gambling-related harm that were revealed. We offer consultations and help for launching compliant projects.
Idea Behind the Initiative: How It All Started
The development of recommendations for the EU’s gaming jurisdictions began following the EGBA’s 2022 proposal to CEN. The project’s goal is to create a unified list of customer behavioural markers to help entrepreneurs identify potential signs of risky or problematic play earlier.
The initiative was approved in 2023. Then, work on the standard began by engaging a wide range of stakeholders.
The following parties were involved in document discussions and preparations:
- operators;
- researchers;
- national regulators;
- healthcare organisations;
- consumer protection agencies.
In September 2025, the majority of NSBs across European countries supported the project. The authors view it as a promising step toward a more systemic approach to keeping regional users safe.
EN 18144 contains a range of harm indicators and recommendations for their application. At the same time, the document is voluntary: national agencies and operators are free to decide how to implement it within the framework of their current legislation.
Market Fragmentation: Regulatory Differences
Mr Fuchs believes that the key issue in incorporating the initiative is related to its structure. In his opinion, the standard is static and cannot serve as a cross-border tool that takes into account various oversight models.
Let us explore the Deputy CEO’s major insights:
- Dealing with divergence. The document will not completely coincide with national legislation. The rules for its application should be the responsibility of local regulators. The key task of governments is to maintain stability and consistency. Dynamic changes in this field could ultimately disrupt the market.
- Finding a balance. The executive also drew attention to the standard’s vulnerability at the intersection of identifying harm and protecting personal data. Modelling and predicting user behaviour requires processing a wide range of private details from diverse sources. Meanwhile, combining and structuring them may conflict with GDPR and national privacy laws.
- Operator responsibility. Today, state authorities across Europe are largely limited to targeted measures, making it difficult to create a single sustainable system. In 2026, gambling studios need to step up and gradually shift from formal compliance to harm-prevention strategies to achieve better efficiency.
Dr Hofmann generally supports the EGBA’s initiative. He considers it a fundamental move in the right direction, although long overdue. For a while, gaming remained outside the EU’s clearly structured and aligned legal framework, resulting in fragmented connections among market participants.
The executive expects the EGBA to provide tools that guide countries toward more uniform approaches in identifying signs of harm. At the same time, he emphasises that the central issue is the practical application of the protocol. A too-short set of general indicators can lead to unjustified restrictions and, eventually, growing user churn.
The representative cites Germany as an illustrative example, where rigid limits reduced the efficiency of the legal market and increased the share of the illicit segment. The standard’s value will depend not on the number but on the quality of its integration into current regulations. Any implementation must be evidence-driven, proportionate, and systematically revised.
Real-World Efficiency and Shadow Sector Growth
Dr Ditsche notes that the main challenge in incorporating the EGBA’s initiative stems from the gap between formal oversight requirements and resultative audience protection. The expert believes that the problem arises when legal rules cease to fulfil their primary function and become mere compliance indicators on paper, with no true impact on efficiency.
If left unnoticed, this situation puts operators in constraints of rigid frameworks, while users increasingly switch to unlicensed portals. If the standard fails to account for player behaviour patterns, it could weaken rather than strengthen the existing security mechanisms.
About Soft Law and Legitimacy Confusions
Dr Piska was among those who expressed scepticism about the published document. The initiative’s juridical status and effect on national gambling regulation remain questionable. He argues that new markers are an attempt to circumvent the classic lawmaking process. They create significant pressure on businesses without full democratic approval.
As a result, strategies are converging in an area where the EU has no mandate for a unified iGaming regime. Voluntary coordination may eventually become a rigid guideline that goes beyond formal legislation.
The professor emphasises that regional markets differ significantly in:
- regulatory structures;
- enforcement practices;
- types of popular products;
- player behaviour patterns, etc.
He believes it is important for European states to maintain autonomy in developing their oversight systems rather than adopting general approaches from outside. Dr Piska notes that introducing a unified standard risks weakening existing national models. There is no sufficient evidence demonstrating the ineffectiveness of current programs, and cross-border differences add complexity.
Formally, the initiative is revealed as a set of voluntary recommendations, but in practice, its expansion could increase uncertainty. Given the lack of a clear legislative mandate and a justified need, this situation essentially amounts to another layer of regulation that is not always consistent with national strategies.
UKGC’s Perspective on the Presented List
Ms Gardner views EN 18144 as a logical outcome of developing oversight cooperation. She stated that the EGBA faces the complex task of supervising a global market. Its success depends on close collaboration between national authorities and industry participants. It should lead to the formation of a broad network across Europe.
To achieve these goals, the executive calls for stronger ties among worldwide and regional organisations, such as:
- IAGR;
- GREF;
- local regulators.
Ms Gardner emphasises that the new range of indicators is a voluntary recommendation, meaning each country decides for itself to what extent it is implemented. She believes that at this stage, operators should monitor the project’s development and build flexible processes that can adapt quickly to emerging requirements.
The representative also specified that British permit holders and those applying for the state’s certifications are not obligated to incorporate all provisions of the published document. Yet she highlighted the ultimate importance of adhering to the Licence Conditions and Codes of Practice (LCCP).
The Main Things About the New European Standard
The gambling market in Europe is expected to see a growing trend toward stricter regulation and consolidation of industry participants. The sphere has repeatedly faced the consequences of evolving requirements. Nevertheless, its organisations continue to promote standardisation and strengthened oversight.
As for the latest published list, analysts’ opinions are now divided. Currently, the reform’s status across various regional countries remains uncertain.
Let us remind you of the central insights from the article:
- EN 18144:2025 introduces a voluntary European framework of behavioural markers to identify gambling-related harm before problems escalate.
- Niche experts note significant differences in national regulations and oversight models that complicate the creation of a truly cross-border standard.
- Effective use of the published indicators involves balancing player-protection goals with GDPR requirements and the privacy laws of each country.
- Too restrictive or poorly calibrated safeguards may reduce the appeal of white markets and push the audience toward unlicensed websites.
- The initiative’s success will depend on evidence-based implementation, proportional measures, and systematic reviews of its outcomes.
- Some specialists question the legitimacy of soft-law mechanisms that may influence national policies without formal democratic approval.
- Operators should closely monitor regulatory novelties and establish adaptable safer-gambling processes to respond to potential future changes.
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