Lost in translation
How one analyst interpreted the European Commission’s letter to the second draft Intrastate Gambling Treaty.
Treaty must be noti?ed EC: “The [EC] will only be in a position to assess compliance...once all relevant legislation has been amended and noti?ed”. Our translation: “Thanks for the letter but you will have to go through the proper process.” Technical regulations EC: The EC “would like to remind [Germany] of the obligation to notify”. Our translation: “and when you do go through the proper process, don’t forget the important details like last time”. Ban on casino and poker EC: 15 States attempt to justify ban in current
draft Treaty on the basis that “such games are vulnerable to rigging and have signi?cant addiction potential”. The EC notes that “no data has been provided” as “evidence”. Our translation: “If you want to ban a game online that is permitted offline, you have to provide data to justify ban.” Restriction on number of licences EC: The initial draft Treaty provided for seven licences to be issued but the revised draft provides for 20. The EC con?rmed that Germany is entitled to restrict the number of operators “if it pursues the objective to reduce gambling opportunities”. However, the EC goes on to say that “the suitability and proportionality of the measures needs to be properly demonstrated”. Our translation: “You haven’t shown why a 20 licence limit achieves your supposed social policy o