A lack of effective regulation is often cited as a drawback for gambling online, due to the fragmented and variable powers of licensing authorities around the world. On the other side of the coin, heavy regulation can grant monopoly status to privileged operators, such as in Norway.
Norwegian resident and experienced online player Lasse K. Olsen shares with us his experience and criticisms of the Norwegian licensing regime which has, in his opinion, lead to an abuse of its monopoly position by Norsk Tipping. The end result, as may be expected in a monopolised market, is lower payout rates, less choice, and poorer quality service offered to punters that are supposed to be protected by the strict regulatory process...
Gambling regulation in Norway
Norway has a gambling monopoly where Norsk Tipping (NT) and Norsk Rikstoto are alone authorised to offer gambling in the country, if you ignore some lotteries and a few bingo halls. "Lotteri og Stiftelsestilsynet" (Lottery and Foundation Authority) is the one that sits on the top of the throne in the Norwegian gambling market, deciding who gets, and who does not get, permission to offer gambling in Norway. One of the purposes of this monopoly is supposed to be protection for problem gamblers, and those who are at risk of getting themselves into trouble because of gambling. Norsk Tipping is also controlled by The Lottery and Foundation Authority, who ensure that Norsk Tipping follows the "current rules". But what are the "current rules", and does it help to have a gambling monopoly to protect the weaker souls in our society? I have lately been taking a closer look at Norsk Tipping and their relationship with the Lottery and Foundation Authority, and how the "current rules" are written to fit what I believe is Norsk Tipping's need of maintaining their gambling monopoly. I have also been taking a closer look at their marketing strategy, games, return to players, and whether the information on the websites of Norsk Tipping and the Lottery and Foundation Authority fits with reality.
Norsk Tipping's Commercials
In Norway it is illegal to advertise for gambling if you don't have permission from The Lottery and Foundation Authority. Norsk Tipping have permission, so they can advertise as much as they want in the Norwegian media. Our children can, in prime time, see a huge amount of commercials for NT's products. Surely it is good that NT has to follow strict rules for their marketing campaigns, so they are prevented from addressing their commercials directly to children, right? Below follows two of Norsk Tipping's commercials, where they use children to promote their business:
It was with disbelief that I first watched these videos because, according to the regulations, gambling commercials should not be directed to persons under the age of 18. In the marketing guidelines for gambling you find the following rule:
2.3 Gambling operators must not direct advertising in the direction of individuals under the age of 18.
I therefore sent an email to Norsk Tipping, asking them to explain why children are used in their commercials. They replied as follows:
1: We do not direct any advertising to children. In other words: It is NOT children that are the targeted group for the commercials you have seen. The commercial is targeting adults.
2: We do not use children when promoting individual products.
Where we can use children is in circumstances where the intention is to explain where Norsk Tipping's profit goes. A big part of Norsk Tipping's profit goes to facilities and activities for children. It is important for us that you and others know about this. The fact that our profit goes to facilities where children can enjoy themselves in many arenas all over the country, for example in sports and culture, is something we are proud of. The best way to show this is to show children in activity.
But I emphasise again - It is essential that the advertisement is not aimed at children, although children do act in it.
Norsk Tipping is, in addition to the ordinary law, subject to separate guidelines for gambling marketing. It states that we should not direct marketing to children, and that we should not use children in marketing. The exception to that is, as I stated above - when the communication is about showing what the profit is used for. This is formulated as this in the guidelines:
Information, activity or proclamation to show where the profit from gambling goes to, is not covered by the guidelines.
This is the reason you sometimes can see children involved in commercials about our profit.
So, Norsk Tipping says that the commercials are not meant for children, but they are still shown in prime time, when children sit in front of the TV screen. And there is one thing that comes to my mind - children do understand these commercials very well. And Norsk Tipping has actually inserted their logo at the end of the advertisement, a logo which is easy to recognise, even for children. Some will say that a small logo is not so bad - what harm could that possibly do?
It is proven that a good logo is one of the strongest tools used in successful marketing. Many companies spend millions on the development of a single logo, and the best logos will make you remember the company name forever. Here and here are two good articles describing this.
A good logo and a well known brand, which are seen enough times during your childhood, will follow you throughout your entire life. So Norsk Tipping's commercials are certainly not harmless for children. First they will get good feelings when they watch other children playing to the tune of "We are the Champions", followed by Norsk Tipping's well known logo. This will eventually give children good feelings when they see Norsk Tipping's logo elsewhere, like at various gambling facilities.
But NT and the Lottery and Foundation Authority are in the clear, because as the guidelines state: Information, activity or proclamation to show where the profit from gambling goes to, is not covered by the guidelines.
This was the rule that NT relied on in their reply to me. And it is quite convenient that they have such a rule, so they can create informative commercials (which by all means are not directed towards children) that show where their profit goes. And of course they must be allowed to put their logo at the end of the commercial, so that everyone (including children) know what it is all about.
Let's now give a few thoughts to the commercials of other casinos. It is not only Norsk Tipping's commercials that are shown on Norwegian TV in prime time. Several big betting companies are buying commercials from Norwegian television companies, which solve the issues around legality by broadcasting from abroad. This leads to major protests from Norsk Tipping and The Lottery and Foundation Authority. But it strikes me that commercials showing information about ROI, bonuses, odds and RTP are not understood by our children. They have no prerequisite for understanding these things, unless they are already gambling. So Norsk Tipping is now the only known company that uses commercials which are harmful for our children.
A monopoly on helping?
Its not only gambling that is controlled by monopoly in Norway. According to Norsk Tipping's Tonje Sagstuen there is also a monopoly on giving money to Norwegian sports clubs and associations. Even though Norsk Tipping would have the Norwegian people believe that they are the only betting company willing to give money to sport clubs and good causes, there are other betting companies trying to do the same. But NT and the Lottery and Foundation Authority are fighting against this with everything they have, even though such funds come in handy for small sports clubs with little funds.
In May this year the international gambling company Cherry started a foundation called "Stiftelsen Folkeandelen". The aim of this foundation was to give parts of their profits from gambling to charity in Norway. Just four weeks after the start over 700 clubs and organisations had signed up in hope of receiving well needed financial support. But then the Lottery and Foundation Authority set their eyes towards the organisation. This resulted in massive pressure that in the end forced the foundation to shut down its operations in Norway. Fortunately the foundation continues their business from Malta. But the Gambling and Foundation Authority did not stop there. They are now trying to push clubs and organisations to not accept funds from the foundation, by claiming that it is illegal. That several clubs are dependent on help from outside does not matter, Norsk Tipping and the Lottery and Foundation Authority only care about their own money bin. They care little or nothing if small clubs and organisations go down as a result of not being able to accept funds from foreign companies. You can read about the case in this Norwegian newspaper.
High profile sport stars have also gotten into trouble, and at times been directly bullied as a result of their association with gambling companies. One of these is former Liverpool FC footballer John Arne Riise, who became a target for the gambling monopoly when he returned to Norway to play for Aalesund. At the time Riise was an ambassador for the gambling company Betsson. This did not impress the representatives for the gambling monopoly in Norway. Norsk Tipping's Tonje Sagstuen stated that this would be a deal breaker for Norsk Tipping as a general sponsor, and as a result she meant that Riise could not play for Aalesund. In addition to this, representatives from the Norwegian Ski Association reportedly attempted to remove Riise from Holmenkollen when he was there as a private person due to his relationship with Betsson.
Norwegian football is in trouble at the moment. After Rosenborg's exit from Europe there are no teams representing Norwegian football in the major competitions this year, and the national team is a story in itself. The main reason for this is that Norwegian clubs, even the biggest of them, have microscopic budgets compared to their international competition. Abroad, even small teams land large and valuable sponsorship deals with betting companies. This provides money that comes in handy when developing new talent. But in Norway it is illegal to enter into sponsorship deals with these companies. As a result, our sport teams miss out on huge amounts of money. If this trend continues there may be long waits between Norwegian teams successfully representing Norway in the European arena. And that is just sad.
A monopoly on responsibility?
Todays online casinos are, according to Norsk Tipping and the Lottery and Foundation Authority, a bunch of criminal organisations that fool innocent Norwegians into gambling their money away. On the Lottery and Foundation Authorities website you can read that half of those who played online in 2015 are either problem gamblers or individuals in danger of becoming so. Foreign gambling companies are, according to the Lottery and Foundation Authority, engaged in illegal advertising filled with bonus offers and major winning opportunities, which in turn is supposed to increase the chances that the average Norwegian will suffer from gambling addiction. This autumn Norsk Tipping will introduce a max loss limit which they seem to be very proud of, since they are the first in the world with this. This loss limit is set at 20,000 NOK per month.
The Lottery and Foundation Authority's claim that half of all who played online in 2015 are problem gamblers doesn't match reality. It is estimated that approximately 500,000 Norwegians play online. So this claim means that there must be 250,000 problem gamblers in our little country. In the same statement they also claim that there are 122,000 problem gamblers, so already there we can pick their statistics apart. On Norsk Tipping's website you can read something completely different. They claim that approximately 20,000 of their 2 million users are problem gamblers. In other words, 1% of those who play are having problems. The information you find on Norsk Tipping's and their regulator's websites do not match whatsoever. And this makes it all look like pure fiction. These seem to be numbers put together using pure imagination for the sake of creating the impression that playing in casinos other than the one run by Norsk Tipping, almost without exception, leads to problematic gambling behaviour. Fortunately the Lottery and Foundation Authority have been so eager to exaggerate their numbers that they have forgotten to check if they fit together with Norsk Tipping's numbers.
Here is a news article that says that there are 22,000 problem gamblers in Norway. It also says that there has been a decrease in the number of problem gamblers in the country in recent years. This decline has happened after the foreign online casinos started offering their services to Norwegian players. This does not match the regulator's fantasy numbers.
Commercials advertising foreign casinos are something Norsk Tipping and their regulator react strongly against. According to them, offers such as bonuses and information about large jackpots tricks poor Norwegians into gambling away their homes and assets. But it is not only foreign companies who make the use of aggressive advertising directed towards Norwegian players. When preparing for this article, I created an account with Norsk Tipping in order to compare them with the casinos that I already play in. And I was in for a big surprise because when i checked my email I found that it is Norsk Tipping who send the most aggressive advertising to me, and they send a lot. Norsk Tipping sent out three times as much as their nearest competitor, and their emails contained six times more information and "baiting". They send an insane amount of advertisements about games I should consider playing, prizes I can win, and information about big winners.
So far in September they have sent me the following information:
- On September 2, they let me know that I can win 333 Million NOKs in the EuroJackpot lottery. I can bet on the football match Norway vs Germany. I can become a lotto millionaire without guessing any numbers correctly. I can play on their slots, and Arne Scheie (a famous Norwegian sports commentator) shares his betting advice with me.
- On September 6, I can gamble on the football match between Sweden and Netherlands. I could have won a trip around the world, I can win a DAB radio, and a skilled player has won big with 12 correct guesses in sports betting. And a guy from Oslo has won big on a slot machine.
- On September 9, Norsk Tipping tell me that I now have a chance of winning 409 million NOKs on the EuroJackot lottery. I can wager on the football match between Manchester United and Manchester City, and I can become a lotto millionaire without having to get all the 7 numbers right.
- On September 13, I can once again become a millionaire without 7 correct numbers. I can win two jackpots in their sports betting coupon, and one lucky player has won 621,000 NOK on an online slot machine.
- On September 20, they let me know that I can win 20,000 NOK per month for 20 years by buying their scratchcards. There is a double jackpot in one of their sports betting games, there is 17 million at stake in the game "Viking Lotto", and a man has become 1 million NOKs richer from one of their games.
- On 23 September, they make me aware that I can now become 592 million NOKs richer if I play the EuroJackpot lottery. I can bet on Arsenal vs Chelsea, a player has won 104,000 on a slot machine, their "Joker" jackpot is growing big and Arne Scheie gives me some more sports betting advice.
Meanwhile I received the following offers from their most active competitor:
- €10 free on first deposit.
- 100% bonus up to €200.
Only two small offers came in to my email from Norsk Tipping's most active competitor. And if we should think realistically about this - which commercials are most likely to make addicted players gamble? Is it the one that promise a small bonus on your deposit, or the one that promise you the chance to win several hundred millions, economic independence for 20 years to come, and betting tips from Norway's most experienced and recognised sports commentator?
As I mentioned earlier in the article, Norsk Tipping is now introducing a loss limit of 20,000 NOKs per month, and players will also have to set their own limits before they can start playing. Norsk Tipping is very proud of this loss limit, and makes a big deal about being the first casino in the world doing this. What they forget to mention is that online casinos have operated with personalised loss limits for years, long before Norsk Tipping even thought about this as an effective tool for preventing problematic gambling behaviour. And there is more. Just a few years ago there was no age limit on any of NT's games. I remember that I as a child could play their games as much as I wanted, and in the news you could find sunshine stories about children winning hundreds of thousands on scratchcards. Norsk Tipping was in fact the last casino in the world to introduce a minimum age limit of 18 on their games. Norsk Tipping is also the company that has created the biggest number of addicted gamblers in Norway. So what they are really proud of here is that they are finally about to become equal with other casinos when it comes to responsibility.
But Norsk Tipping still has a long way to go before they can compete with the elite, because they are still not ready to admit the most important thing: that their games and activities are at least as addictive as other casinos games and activities!
Responsibility is still one of the prime arguments Norsk Tipping and their regulator use to maintain their gambling monopoly in Norway. When looking at their campaigns against other gambling companies one would almost believe that Norsk Tipping also has a monopoly on responsibility. But in fact, that is wrong. Most gambling companies that are active in the Norwegian market are very serious when it comes to responsible gambling. They are recognising that problematic gambling behaviour gives the industry bad publicity, and they have for many years employed many of the same preventative actions that Norsk Tipping is only trying to introduce now. Today most reputable online casinos offer their players the ability to set their own custom loss limits or self-exclude from the casino, and they are more than willing to help problematic gamblers contact organisations that can help, such as GamCare, GambleAware, or Gamblers Anonymous.
Norsk Tipping is, as earlier mentioned, very proud of their new upper loss limit of 20,000 NOK per month. This is supposed to prevent problem gamblers from playing too much. But if we think a little about this we will quickly understand that this is just a show for the sake of good publicity. How big a percentage of the population can afford to lose 20,000 NOK a month (roughly USD $2400 at current exchange rates)? Only those with high earnings will be helped by this limit - and how big a percentage of those with such earnings are problem gamblers? The number of those that are actually being helped by this limit is vanishingly small. So the idea that Norsk Tipping, after decades of being irresponsible, now all of a sudden has become a "clean" company is pure gibberish. But it does look good on paper, so it will probably help keep the gambling monopoly safe for a while longer. And if you read a little bit between the lines, you will see that this is the main goal for Norsk Tipping: to protect their income, and not Norwegian players!
Norsk Tipping now have, as do many other casinos, customised loss limits set by the player. These you can decide before you start playing, and they will help you avoid spending too much on gambling. But who is responsible if the system fails and you exceed your loss limit without being stopped by this system, like you are supposed to be?
One would believe that it is Norsk Tipping's responsibility that this system works, so that you as a player can feel confident that you have control when you have set such a limit in the first place. But think again. In the terms and conditions section 6.2, which is about denial of responsibility you can read the following line:
Norsk Tipping is not responsible for the player's total loss exceeding personal limits or boundaries set in section 6.1 if an error causes further play to not stop when those limits are exceeded.
So if you lose control and lose more than you want due to a failure in Norsk Tipping's systems, the responsibility for this is solely laid on you. And you have nothing to complain about. Should you chose to complain anyway, a written complaint must be sent to Norsk Tipping by mail. If they choose to reject your complaint you can, within 30 days from the refusal, send a complaint to the Lottery and Foundation Authority. But then there is this thing about "whoever holds the money..." because Norsk Tipping is responsible for the paycheque of the Lottery and Foundation Authority. So do not get your hopes up when turning to them for justice. You will actually have a greater chance of success against foreign companies regulated by totally independent countries and regulators.
Norsk Tipping is regulated by the Norwegian Lottery and Foundation Authority. On their website, lottstift.no, you can read that they are to supervise Norsk Tipping according to current rules. But there is one major problem with this regulator. The Lottery and Foundation Authority is funded by Norsk Tipping. This again is a great subject for speculation. The regulator is dependent on Norsk Tipping's profit at the same time as they are the only one responsible for regulating them. Believe it or not!
As a comparison, there is a much stricter control on foreign online casinos. If you look at the Betsson Group as an example, you will see that they operate with loads of licenses. On their website you can read about the following licenses in Malta:
Betsson holds a license issued by Malta, a member of the European Union. BML Group Ltd. (reg. no C34836) is also registered in Malta and holds the following licenses: LGA/CL1/183/2004 (issued March 30, 2011), LGA/CL2/183/2004 (issued March 17, 2009), LGA/CL3/183/2004 (issued March 17, 2009), LGA/CL1/566/2009 (issued Jan 9, 2010), LGA/CL1/587/2009 (issued July 9, 2009), LGA/CL3/566/2009 (issued July 9, 2009). These licenses have been awarded to Betsson by Malta Gaming Authority (MGA), formerly known as Lotteries and Gaming Authority (LGA) (LN176/2004), and cover sports betting, casino, lotteries, bingo, games, Turkish poker and Betsson Euro Tables. Betsson Poker is owned by BML Group Ltd. and operate on the Ongame network under a network license issued by Gibraltar's Government. Betsson Euro Tables is owned by BML Group Ltd. and operates on a network owned by Entraction Network Ltd, acting under a license issued by MGA.
In addition to this, The Betsson Group is licensed in Estonia, England, Italy, Ireland, Lithuania and Georgia, and they must at all times fulfil all requirements of these countries in order to keep these licenses. Compared to Norsk Tipping, who fund the paycheque of those who regulate them, Betsson are superior when it comes to licenses.
Norsk Tipping can at best be said to operate under a rubbish-license. The commercial videos you saw above are a good example of this. If a foreign gambling company had made a commercial featuring children in a country where they hold a license, they would have lost this immediately, and most likely been given a huge fine. But since the Norwegian regulator receives its paycheque from Norsk Tipping, there is of course a section in the guidelines that exempts NT from responsibility. It's the least they could do!
The worst RTP in the world
Norsk Tipping is a nightmare for players that are concerned about odds and RTP (return to player). Of all the casinos I know, Norsk Tipping is on the bottom of the list when it comes to such things. And I know the majority of them! The RTP is so bad that if Norsk Tipping would have tried to compete on the world market, they would have been blacklisted by all serious casino reviewers worldwide. Here I will try to explain how big the difference between Norsk Tipping and other casinos really is.
- If you bet on sports with Norsk Tipping the average RTP over time is around 80%. With other bookmakers this number is around 92%.
- If you buy a scratchcard from Norsk Tipping you can expect a RTP on 45%-65% over time. But if you buy it in a online casino like Betsson or Comeon, the RTP will be around 93%. I first thought the reason for this was that Norsk Tipping sold their scratchcards in shops which have a higher base cost than selling online. But that was until I saw that the scratchcards in NT's online casino have a RTP on 45%-65%, the same as if you buy them in a shop.
- If you play Lotto, their sports betting coupon, Viking Lotto, Joker, Keno, EuroJackpot, and Extra games, then you are really looking to get ripped off big time. These games have a RTP of 50-55%, which would be considered pure theft by players if it happened in another casino.
But it was when I checked NT's slots that I really got a big shock. If you play in a regular casino with slots from developers such as Microgaming and Net Entertainment the RTP will be around 95-98%. But if you read the terms for Norsk Tipping's games you will see that their land based slots can have a RTP as low as 30%. This you will find an example of in section 4.1 in the "rules for Belago". It is also written that it is only possible to win 1500 NOK on the Multix games, and 2500 NOK at the Belago games, which is ridiculously low when you consider that you can play for 50 NOK per spin. This means that you will need to be really lucky to win something of significance, and at the same time you can lose the maximum monthly amount pretty fast.
When it comes to slots in Kong Kasino (Norsk Tipping's online casino), these also had very low RTP a while back. But the RTP was raised due to heavy competition from foreign online casinos. However if you look at the terms for Kong Kasino you will find the following information about slots in section 4.1.4, which is about winnings:
If you play on games with a RTP higher than 70%, the maximum win can not be higher than 5,000 NOK, plus a chance to win a jackpot.
If a player plays on games with a RTP lower than 70%, the maximum win can be 100,000 NOK in addition to the chance of winning a jackpot.
So, the RTP was indeed raised in Kong Kasino, but at the same time they made it more difficult to win big at these games. However, if you choose to play the games where the RTP is still low, then they can give you the chance to win a lot more. This is simply an attempt to camouflage that the slots still, even after the changes in RTP, cannot compete with other slot providers' games when it comes to RTP and chances of winning. In my opinion this looks like a serious attempt to give players the false impression that the chances of winning are much higher than they really are.
Some simple calculations you should think about next time you play:
- If a total of 1 million is bet on sports, NT will pay back on average 800,000 to players. As a comparison a average bookmaker will pay back 920,000. This is a difference of 120,000!
- If Norsk Tipping sell scratchcards for 1 million, either in shops or online, then between 450,000 and 650,000 will go back to players as prizes. If you buy scratchcards in an online casino, this number will be 930,000. The difference is between 280,000 and 480,000.
- If you are playing various lotto and keno games with Norsk Tipping, the RTP will be between 500,000 and 550,000 per 1 million in bets. This number is so ridiculously low that we wont even compare it to other games.
- Ridiculously low is also the description for the RTP on Norsk Tipping's land based slots. These can be as low as 30%, and I can't think of any games that are worse. This means that per 1 million NOK Norwegian players put at risk, the returned amount may be as low as 300,000. Such a low RTP would be hard to find elsewhere, unless you play in dark underground bars in the 3rd world.
- Kong Kasino's slots do a little bit better. As I understand the information about their games, the RTP on them must be above 50%, and on some of them it is over 70%. This means that for every million at stake, between 500,000 and 700,000+ will be paid back to players. But the problem there is that it's almost impossible to win big on slots with an RTP higher than 70%. In contrast, almost any slot in a regular online casino will pay back 950,000+ for every million in bets. In addition, it is possible to win much larger prizes on these slots.
Embracing the competition
Norsk Tipping and their regulators have to realise that the competition is here to stay. Norwegian players can now find some of the best online casinos just a few clicks away. And as long as Norsk Tipping continue their unethical business practices and offer games that can be compared with fraud, then they can not expect that Norwegian players will stay away from other casinos. Norwegians are intelligent people who understand that they are being deceived by Norsk Tipping when they see the difference between them and other casino operators. If Norsk Tipping continues to chase other casinos' shadows instead of changing their own business for the better, then more players will most likely find their way out on the web.
This article was originally written in Norwegian by Lasse K. Olsen. It has been translated by its original author and Casino Listings staff. You can read it in its original form at Norge-Casino.com.