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. 

“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. 

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.

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. 

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.”

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.

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.