TL;DR:
Europe is close to finalising a common set of “markers of harm” for online gambling (evidence-based indicators that flag risky behaviour). It’s a big step toward consistent, effective safer gambling policy and regulation that can be demonstrably effective.
In this blog, we explore:
Why common standards matter for both regulators and operators How the CEN process works, and why it gives the initiative real weight What emerging markets like the US and others can learn (and avoid) from Europe’s journey How shared harm definitions can make interventions smarter, earlier, and more effective
Imagine a regulatory meeting where everyone finally speaks the same language about gambling risk
That scenario is becoming reality. In early 2025, the Gambling Regulators European Forum (GREF) endorsed a landmark initiative to create a standardised list of “markers of harm” (evidence-based behavioural signals that can flag at-risk gambling)(legba.eu).
For regulators, operators, and support services, this marks a critical moment: the chance to align on what really matters in player protection, and the opportunity to act on it.
After many years of effort, spearheaded by industry and experts, Europe is on the verge of agreeing a shared framework to identify risky gambling – a critical step towards more effective and coordinated safer gambling policies; and something we at Carn Advisory have long publicly advocated for.
A long-running effort to harmonise Safer Gambling
The journey toward a common set of harm markers began several years ago. The European Gaming & Betting Association (EGBA), a Brussels-based industry body, recognised a core problem: many organisations use behavioural indicators of gambling harm, but there was no standard, agreed-upon list across Europe (egba.eu).
“Markers of harm” typically include observable changes in a person’s gambling habits – for example, a sudden increase in bet frequency, unusually long play sessions, or abrupt changes in spending patterns. These changes can flag that a player may be at risk, enabling early intervention.
Yet without a common definition, each operator or regulator might track different signals, making it hard to align efforts and direct resources effectively; but more importantly to act with complete confidence that the efforts are measuring what actually matters.
To solve this, EGBA proposed back in 2022 that Europe develop a unified, evidence-based set of harm markers (egba.eu).
By the end of 2022, members of the European Committee for Standardisation (CEN) (the official body for developing standards in Europe) voted to take up the task.
Work kicked off in 2023 within CEN’s framework, bringing together a wide range of expertise including:
- academics who study gambling behaviour,
- health professionals,
- gambling regulators from various countries,
- operators with years of player data, and
- harm prevention specialists.
This broad collaboration gives all stakeholders the best chance of ensuring the standard developed isn’t just an industry wish-list nor a regulator’s decree, but truly evidence-based and well-rounded.
Crucially, the CEN process is designed to build consensus. Through national delegations and technical committees, stakeholders have a forum to contribute research and insights. The goal is to finalise and publish the standard by the end of 2025(egba.eu).
It will outline a common set of markers of harm for online gambling, becoming essentially a pan-European checklist of warning signs that an online player may be experiencing or approaching harm. Whilst the standard will be voluntary by default, it carries weight: regulators could (and in our view should) incorporate it into their regulatory frameworks, and operators will be encouraged to adopt it as best practice.
Even as a voluntary guideline, having a CEN standard means a shared reference point that all parties recognise, and one that is evidence-based, which gives it the best chance of actually being effective in its impact.
CEN’s Role: From proposal to pan-European standard
So why develop these harm markers through CEN? Because CEN provides a formal, Europe-wide approach to standardisation.
It’s the same body that harmonises everything from technical product specifications to safety guidelines across EU and EEA countries, and in the context of safer gambling, CEN’s involvement elevates the initiative from an informal agreement to an official European Standard, with all the rigour that entails.
The CEN process ensures transparency and broad input, and its outputs are respected by both industry and regulators. By working through CEN, the markers of harm project gains legitimacy and a pathway for adoption in multiple jurisdictions at once.
Critically, CEN standards are evidence-driven. Which means the markers of harm are being developed are based on existing research and data from those on the front lines of gambling harm prevention. For example, academic experts can contribute findings from studies on what betting behaviours correlate with problem gambling, while operators can share practical knowledge from responsible gambling tools they’ve tested.
The result should be a set of harm indicators that are science-based and validated by real-world experience. This means any measures triggered by these indicators (such as automated alerts to staff, player notifications, or tailored interventions) are more likely to pinpoint genuinely at-risk individuals, rather than casting too wide a net and spreading resource too thinly, or missing crucial signs altogether because they aren't actually considered as the important metrics to track from a regulatory perspective.
Those working in the industry understand that the current situation is well below optimal.
Another advantage of the CEN route is flexibility. The forthcoming standard on markers of harm will not automatically override national rules – GREF has been careful to stress that compliance will remain voluntary unless national regulators decide otherwise(CasinoBeats). This respects the fact that Europe’s gambling markets aren’t identical; some countries already enforce strict “duty of care” requirements on operators, while others have minimal guidelines.
The CEN standard can act as a common baseline so that jurisdictions with fewer safeguards can use it as a ready-made toolkit for duty of care, and those with established rules can compare and enhance their frameworks against the European benchmark. In short, CEN’s role is to provide a unifying foundation – a common language of harm markers – which everyone can build upon.
GREF’s 2025 Endorsement: Regulators rally
This collaborative approach received a major vote of confidence earlier this year. GREF (comprising regulators from across the continent), publicly welcomed CEN’s markers of harm initiative(GREF.eu). GREF’s endorsement is significant: it signals that regulators themselves see the merit in a common, evidence-based standard and are keen to support it.
For an industry-led proposal (originating from EGBA) to gain formal support from regulators is a welcome alignment of interests. It reflects a growing recognition that safer gambling requires collaboration. No single group – not regulators, operators, nor researchers – can effectively tackle gambling harm in isolation. By backing the CEN process, GREF essentially reinforces the idea that working together on shared definitions will benefit all sides.
When Good Intentions Backfire:
A key motivation for developing common harm markers is to improve the effectiveness of safer gambling interventions. Across Europe, many regulatory actions to curb problem gambling have always been well-intentioned but not always grounded in solid evidence. In some cases, regulations introduced “in good faith” have missed their mark or even produced unintended consequences for consumers.
Take the example of the United Kingdom. Over the past decade, UK authorities have rolled out various measures to protect gamblers - from strict limits on betting machines to tougher identity and affordability checks. While some of these moves were necessary, others were implemented before a robust evidence base existed, essentially, they are experiments in real-time! Results, unsurprisingly have been mixed.
Certain blunt measures ended up inconveniencing or alienating ordinary customers without significantly helping the most vulnerable. In the worst cases, heavy-handed rules have backfired by driving players away from regulated sites toward the unregulated black market, where no protections apply (A lesson from Britain to America).
The UK’s Betting and Gaming Council has warned that “draconian, arbitrary and blanket rules” (such as blanket affordability checks that don’t distinguish between players) risk pushing responsible players into the arms of illicit operators. This is a perverse outcome: a policy meant to enhance safety can end up exposing players to greater harm.
Beyond the black market issue, lack of evidence-based standards can lead to inefficient use of resources for both regulators and operators. If each regulator defines “at-risk behaviour” differently it creates confusion and increased risk for players.
To illustrate the point - an online operator with customers in five countries might have to configure five separate monitoring systems - one looking at time spent playing, another focusing on money lost in a week, and so on.
Compliance teams end up stretched, chasing a multitude of alerts and thresholds. Some genuinely risky players might slip through because the warning signs weren’t recognised in a particular jurisdiction, while elsewhere, staff might be flagging lots of false positives (players who hit a numeric threshold but aren’t actually experiencing harm).
This patchwork approach is inefficient and confusing. It also makes it hard to measure what actually works in preventing harm, since everyone is using different methodologies. This is why the evidence-based, common markers of harm are so important.
By drawing on empirical research and expert consensus, the CEN standard aims to define the most reliable indicators of gambling harm i.e. the signals that truly merit action. With those agreed indicators, regulators can enact policies that target proven risk factors, and operators can direct their safer gambling tools and teams toward the players who need help most.
In short, an evidence-led approach helps ensure that interventions are both effective and proportionate. It reduces the guesswork and the trial-and-error that characterised some earlier policies, and unfortunately still under development.
Instead of acting on hunches or public pressure alone, policymakers must refer to a solid framework of risk markers and say, “These are the behaviours we should be concerned about. We know they matter as the evidence supports them; and when we see them, here’s how we respond.”
New Markets, New Opportunity: The US and Lessons from Europe
Europe’s hard-won lessons are especially valuable for emerging gambling markets like the United States, Brazil etc.
Since the US began rapidly expanding legal online betting and gaming in 2018, many states have opened up sports betting and online casinos. However, responsible gambling measures in the US have not always kept pace. There’s a real risk that, without proactively adopting best practices, new markets could repeat the same mistakes Europe made in the past – or even introduce risky features that European operators have since abandoned.
A 2024 Reuters special report stated: “Amid a U.S. boom in betting online, the European companies behind FanDuel and BetMGM are using features in America that they dropped in Britain after acknowledging them as risks to gamblers.”(Reuters). Put succinctly, practices that UK regulators and operators have ruled out (like specific aggressive advertising tactics or high deposit incentives) are still being used in the U.S. Moreover, many European firms operating in the US have not been required to implement many of the safeguards now common in Britain as their regulators have not deemed them to be of concern to player safety.
The problem is that without clear evidence to support the control requested it is one regulators view of what is potentially problematic vs that of another. We don't actually know who is right.
Yet, the US (and other new markets) also have a golden opportunity to do things differently from the start. They can leapfrog the learning curve by studying what worked (and what didn’t!) in Europe. Adopting evidence-based harm markers and interventions early on would allow American regulators and operators to hardwire safer gambling into their market infrastructure, rather than retrofitting it after problems emerge.
Encouragingly, there are signs of progress: for example, some large US operators have voluntarily agreed to a set of responsible gaming principles, and state regulators are increasingly consulting research experts when drafting rules.
The development of Europe’s common markers of harm standard can support these efforts globally. If a shared set of harm indicators is published through CEN, it could serve as a reference well beyond Europe. Forward-looking policymakers and companies might choose to align with those standards, recognising that they represent the collective wisdom of international experts.
In essence, emerging markets have the chance to avoid the pitfalls, reduce effort and spend by targeting effective measures, and most importantly give consumers the most effective levels of protection. By embracing an evidence-led approach from day one, rather than waiting until incidents or public outcry force reactive measures, jurisdictions can implement policies informed by the data and definitions that Europe’s collaborative process is now producing.
This transatlantic cross-pollination of safer gambling practices would be a win-win: it raises the bar for consumer protection in new markets while reinforcing the value of the European initiative on a global stage.
Shared Definitions as the Foundation for Safer Gambling
The push for common markers of harm is about more than just creating a list. It’s about establishing a foundation for unified safer gambling efforts.
When regulators, operators, and support services all align on what constitutes harmful behaviour, it becomes much easier to work together to prevent it.
Shared definitions create clarity. Regulators can set targets and evaluate policies knowing that “harm” is being measured consistently. Operators can build detection systems and staff training around known risk markers without juggling conflicting criteria. Treatment and support organisations (like helplines and clinics) can also benefit from clarity on risk indicators, helping them coordinate with the industry on when and how to intervene.
This alignment helps ensure that everyone is “on the same page” when it comes to identifying and acting on gambling-related harm. For example (and purely hypothetically) if “10+ deposits in a 24-hour period” becomes an accepted marker of harm, then a regulator might require operators to flag any customer who hits that metric.
The operator’s team, following the standard, will already be monitoring for exactly that pattern and can reach out to the customer or impose a cooling-off period as needed. A counselling service, aware of the same marker, might develop specific advice for people who find themselves depositing repeatedly. The entire ecosystem, from policy to practical help, starts to move in sync. This cohesion multiplies the effectiveness of safer gambling initiatives: rather than fragmented efforts, we get a concerted, reinforcing approach.
Finally, having an agreed set of harm markers is a critical first step toward more meaningful and data-driven gambling policies. It opens the door to deeper collaboration, such as sharing anonymised data on these harm markers across operators or borders to improve early warning systems. It also allows for better evaluation of interventions – if everyone uses the same definitions, we can compare outcomes and refine our strategies across jurisdictions.
In the long run, the hope is that evidence-based standards will lead to evidence-based regulations that truly protect players while allowing the gambling market to function responsibly. As one industry campaigner put it, safer gambling must be hardwired into everything – and that starts with knowing exactly what we’re looking for.
In conclusion, the European initiative to develop common ‘markers of harm’ signals a new era of cooperation and rigor in safer gambling.
By rallying expertise from all corners and securing support from regulators, this CEN standard promises to raise the level of consumer protection across Europe.
Importantly it acknowledges past missteps and aims to correct course by putting evidence front and centre.
For industry professionals, regulators, and policymakers, it’s an exciting development: a chance to replace fragmented guesses with unified, science-based action.
For consumers, it means the promise of a safer gambling environment – one where help can arrive sooner, and where everyone involved is working from the same playbook to minimise harm.
The journey is far from over when the standard is published, but agreeing on what to look for is a pivotal beginning. With shared markers of harm in hand, we can have increased confidence that Europe is taking a decisive step toward more effective, coordinated, and genuinely safer gambling practices.
Taking the Next Step with Carn Advisory
At Carn Advisory, we’re proud to support organisations in navigating and implementing effective, evidence-based safer gambling strategies.
Our expertise combines deep regulatory understanding with practical industry insight and critically - experience. This helps clients turn standards into meaningful and actionable policies.
Whether you’re an emerging regulator seeking clarity on best practice, an operator aiming for effective player protection, or a policymaker shaping your jurisdiction's future in gambling regulation, we can help you deliver safer gambling initiatives that work.
Reach out to our expert team using the button below to help build a safer gambling environment together.
Sources:
- European Gaming & Betting Association – “EGBA Welcomes GREF Support For European Standard On Markers Of Harm”, Feb. 2025 (EGBA Welcomes GREF Support For European Standard On Markers Of Harm - EGBA).
- GREF – “Statement on the CEN draft standard regarding online gambling’s markers of harm”, Feb. 2025 (Statement on the CEN draft standard regarding online gambling’s markers of harm in support of identification and prevention of risky and problem gambling behaviour - Gref)
- EGBA – “CEN to develop a European standard on markers of harm for online gambling”, Jan. 2023 (CEN to develop a European standard on markers of harm for online gambling - EGBA).
- Betting & Gaming Council (UK) – “A lesson from Britain to America: Safer gambling must be hardwired…” (A lesson from Britain to America: Safer… | Betting & Gaming Council)
- Reuters Special Report – “Online-gambling giants conquer U.S. with tactics deemed too tough for Britain”, July 2024 (Online-gambling giants conquer U.S. with tactics deemed too tough for Britain | Reuters)
- CasinoBeats News – “GREF and EGBA Endorse New European Standards for Safer Gambling”, Feb. 2025 (GREF and EGBA Endorse New European Standards for Safer Gambling - CasinoBeats)
