Our Position on Gambling Harm

When we began operating in July 2022, we committed ourselves to:

• minimising the harm caused by gambling
• ensuring gambling activities are provided safely and fairly
• holding gambling operators to account against their social licence, not just their regulatory obligations.

Protecting patrons, their families and the community from gambling harm is at the centre of everything we do. It must also be central to the approach of gambling operators. This is why we are making our views on gambling harm crystal clear to the industry and the wider community.

The Commission has released a position statement on gambling harm. With it, we intend to embed a harm minimisation focus into every element of our regulatory activity, including how we evaluate all licencing approvals and applications. 

The VGCCC’s 7 core and supplementary statements on harm:

1. Our harm minimisation objective guides all our regulatory decisions, actions and expectations.

• The commission exists because gambling is a legal, but regulated, activity in Victoria.
• Our new legislative objective requires we minimise gambling harm and problem gambling.
• In the past, the regulator was only required to focus on minimising harm caused by problem gambling.
• We are required to minimise harm regardless of its prevalence.

2. Gambling causes harm.

• Harm from gambling is experienced in countless ways.
• Gambling also harms people not directly participating in gambling.
• Gambling that has not led to harm is sometimes called recreational gambling.
• A person’s characteristics and motivations do not alter the harm caused.
• The harm experienced by one person is not lessened by any associated benefits accruing to other people.
• Harm from gambling is not lessened by the risk-taking inherent in a game of chance.

3. Recovery from harm does not alter the causal role played by gambling.

• Financial resources, psychological resilience, access to social supports and services, may aid someone’s recovery from harm, but they do not diminish:

- the role gambling played (is playing) in causing that harm, or
- the severity of the harm caused in the first instance.

• The potential for someone to recover from harm does not lessen the importance of preventing harm (or reducing the risk of harm) in the first place.

4. Harm is preventable.

• A possibility of harm remains whenever someone is gambling.
• Disregarding the possibility of harm is equivalent to disregarding harm.
• Preventing harm means acting immediately and decisively whenever there are signs of harm or possible harm.
• Preventing harm involves: Community education and support, Regulation and enforcement, and Gambling providers acting responsibly.

5. Gambling markets gravitate toward harmful offerings.

• Gambling providers compete to attract customers.
• Products and environments that make gambling more attractive can be expected to also make more gambling more attractive.
• More gambling increases the risk of harm.
• Lawful offerings do not remove the possibility of harm.

6. Gambling regulation seeks to prevent harm.

• Regulators must remain alert to new sources and risks of harm.
• Regulation and regulatory practices must evolve to prevent new industry products and practices from causing harm.
• Regulation reduces harm but will not prevent it entirely.

7. Gambling providers have a duty to care for the wellbeing of their customers and their communities.

• Gambling providers’ obligations extend beyond merely complying with the law because:

- they alone choose to provide gambling services which cause harm, and
- harm occurs despite education and regulation.

• Providers are responsible for turning their minds to identifying and preventing harm.
• A duty to act exists wherever harm is identified or might reasonably be suspected.
• Failure to honour the duty invites scrutiny into whether a gambling provider is complying with its legal obligations.
   

The VGCCC’s wider program on reducing harm around gambling
 

This is a positioning statement outlining our expectations and the industry’s responsibilities. It is part of a series of initiatives placing obligations on operators to minimise harm from gambling.

Other initiatives the Commission is undertaking include:

• A new ‘Harm Minimisation Assessment Tool’ that considers a range of harm minimisation criteria when assessing applications for new, or variations to existing, Electronic Gaming Machines (EGMs) - due to the tool, several applications have been refused.
• Imposing new conditions to improve harm minimisation measures at venues seeking to increase the number of Electronic Gaming Machines on site.
• Placing maximum bet limits on a new online keno game and preventing customers from reinvesting winnings.
• Anti-harm measures at Crown Casino, including a direction banning marketing programs targeting at risk and vulnerable members of the community.

Download Our Position on Gambling Harm (PDF, 174.18 KB)