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// Public Gaming International // March/April 2015
Social Gaming
and How
Responsible
Gaming
Requirements and
Efforts are Being
Circumvented
B
y
P
hilippe
V
laemminck
& L
ucas
F
alco
—ALTIUS
www
.A
ltius
.
com
T
his article is intended as part of a wider debate
concerning the impact of games offered on social
media platforms that have the same features as classi-
cal gambling activities (e.g. Bingo Blitz, Zynga Poker).
It stresses how other social gaming activities, typically
marketed to consumers as being mere skill or strategy
games, could actually impact on consumer gaming hab-
its and behaviors and could cause or enhance future ad-
diction that would effectively destroy national and EU
authorities’ efforts to prevent problem gambling, gam-
bling addiction and to improve youth protection against
the risks linked with gambling activities. This article
does not enter into the more narrow discussion on how
to define or regulate social gaming or so-called social
gambling activities and their inherent risks.
“Social gaming” is defined here as either social gam-
bling activities (i.e. “for-fun” gambling activities) and/or
“Freemium,” which the International Social Games As-
sociation (“ISGA”) defined as activities for which game
access and play is free, with certain additional and spe-
cial features—for example extra lives, extra energy, tools
more, participation in social networks is associated with
dependency. Earlier studies have shown that addiction
to online gambling often starts with simulation games
on Facebook in which children lays ‘bets’ using virtual
money so they cannot incur any losses. Unfortunately,
for many of these children, the next step is dependency
which leads them to lose real money through gambling
[…] Dependence on online gambling is linked to depen-
dence on social networks and games.”
2
The MEPs under-
lined that such a phenomenon is not limited to a single
EUMember State and is spread out among an increasing
number of EU jurisdictions (e.g. Greece, Romania and
Spain). In light of this information, the European Com-
mission was asked to clarify whether it believes the same
restrictions for children’s access should apply to both on-
line gambling and simulation games.
3
It is increasingly clear that there is a connection between
simple social gaming activities and the addiction that
players could develop towards real-money online gam-
bling. That not only applies to the relationship between
social gambling activities, it also includes any games pro-
vided on social platforms or through apps (although often
depicted as skill or strategy games rather than games of
chance e.g. Candy Crush Saga, Game of War or Clash of
Clans). Those games are not simply video games as they
increasingly include buying options that enable players to
either: progress further in the game, enhance their gam-
ing experience and, in certain cases, such games even re-
quire players to buy virtual credits to continue their par-
ticipation in the game itself. Consequently, although such
games could qualify as strategy games or skill games and
not as strictly games of chance (be it real-money or virtual
currency games of chance), it is clear that money plays a
significant and increasing role in the gaming experience.
The EU legislative “landscape” applying to social gam-
ing activities remains fragmented. Three main distinctive
features characterise this “landscape.” The first major reg-
ulatory category includes EU Member States that do not
specifically regulate social gaming through particular regu-
lations and instead monitor social gaming based on their
current gambling legislation; in other words, the national
regulator assesses whether social gaming could qualify as
gambling under national legislation and acts accordingly
(examples of this type of regulatory regime include Aus-
tria, Bulgaria, Denmark, Finland, Italy, the Netherlands).
The second regulatory category comprises EU Member
States that implement basic gambling qualification analy-
sis by being aware of social gaming’s inherent risks and
monitoring those activities and which are concurrently
developing specific legislative proposals to address the is-
sue (examples include Belgium, France, Malta, Norway
and Spain). Finally, other countries, such as the UK, do
or map to expand the game experience are available for
a real money payment.
1
This matter was addressed recently by two Members
of the European Parliament (“MEP”) who used various
examples and statistics to demonstrate how online gam-
bling could generate or multiply the likelihood of depen-
dent behaviours. Given the unanimous acknowledgment
of the influence of gambling activities on consumer ad-
diction, that aspect will not be assessed further. However,
the two MEPs also emphasised that social gaming activi-
ties provided through social networks, such as Facebook,
could be the first step leading young people towards real-
money gambling activities. The MEPs stated: “Further-
