Operating in multiple regulated jurisdictions is a great way to expand your customer base, especially as the online market continues to flourish across the globe. However, remaining compliant across fragmented regulatory frameworks whilst remaining competitive is a continual challenge leading operators face on a daily basis.
Bluem is an independent transaction specialist based in the Netherlands, Bulgaria, and Armenia. A one-stop shop transaction factory for business critical services, onboarding to payment.
We caught up with the CEO, Rieko Kester and CTO, Aviël Ossi to hear their thoughts on some of the most important tools and tech solutions on the market that will help operators to finally master their compliance processes and gain a competitive advantage in the market.
Budget Check, a new approach for income checks
The Budget Check is a revolutionary method for verifying income, bringing positive news to the gambling sector. Unlike traditional approaches, which are often disliked by players for being overly complicated, intrusive, expensive, and unreliable, the Budget Check offers a streamlined and trustworthy alternative. Traditional methods, such as uploading pay slips or granting access to bank accounts (PSD2), are outdated and cumbersome. Bluem’s Budget Check introduces a standardized way to assess an individual’s spending capability using income statements directly from the Tax Authority, ensuring a more efficient and privacy-respecting process.
Why the new approach is welcomed by licensed gambling markets?
More and more countries are including playing limits in their e-gaming rules. Operators must follow this strictly and temporarily block if the player reaches such a limit. The law, on the other hand, also indicates that this is not necessary unless the player can demonstrate that she can easily afford a significant loss. This is where the need for a simple, cheap and reliable income check emerges.
For instance, in the Dutch online gaming market, income verification is mandatory for operators. Similar regulations exist in other regulated markets like France, Germany, and Belgium. Legislators require operators to ensure that players have sufficient financial resources before they are allowed to spend large amounts, with the aim of preventing financial problems related to gambling. In the Netherlands, for example, there is a legally established monthly playing limit (net loss) of €700. Once a player reaches this limit, the operator will not permit further play for the remainder of the month. If the player wishes to continue, they must first prove they have the financial capacity to support larger expenditures.
How does the Budget Check work?
With the Budget Check you can demonstrate that you have sufficient financial resources to spend more. Bluem offers this solution for multiple regulated markets. The process is simple and fast:
- Login via a national eID, like DigiD in the Netherlands, to your My Tax Authority site
- Download your income statement
- Reopen the Budget Check tab and upload your income statement
- Review, confirm and submit your information
- Return to the gambling site
The customer journey explained
By clicking the “Start Budget Check” button, you will be redirected to DigiD.nl* to log in to the Tax Authorities and retrieve your most recent income statement. (*Please note that the eID used to log in to the Tax Authorities may vary depending on the regulated market). Once logged in to My Tax Authorities, download the latest income statement to your device’s download folder. After completing this step, return to the Budget Check tab in your browser. Next, click the “Upload income statement” button. Once uploaded, the income statement will be automatically processed. On the following Budget Check page, you can review the personal details found, such as your name, income, and the relevant year. You will then be prompted to give final approval for the Budget Checker to share this information with the operator. The data will only be sent to the operator after you provide your explicit consent.
Additional key features that set this product apart include:
- The income statement will be deleted by Budget Check immediately after reading.
- The statement is not stored or shared with the operator.
- No information other than the name, income and the year will be sent.
After the confirmation, the player is automatically redirected to the operator site. They then assess whether your income qualifies for a higher playing limit and determines the new limit.
Why not just uploading a pay slip instead of an income statement from the Tax Authority?
While a pay slip might seem like a convenient option for an income check, there are several reasons why it is not the most effective solution. Firstly, not everyone receives a monthly pay slip. This includes freelancers, entrepreneurs, retirees, and the unemployed, who may not have regular pay slips to present. Additionally, automating the reading of pay slips can be challenging due to the wide variety of formats in use, making it difficult to standardize the process.
Moreover, unlike the income statement from the Tax Authority, a pay slip typically lacks a digital signature, which makes it difficult to verify its authenticity and ensure it hasn’t been tampered with. Perhaps most importantly, a pay slip only provides a partial view of an individual’s income, omitting other potential sources such as capital gains, allowances, or donations. In contrast, an income statement from the Tax Authority offers a comprehensive overview of all income sources for the year, which is crucial for a complete and accurate assessment. With the Budget Check, you can easily download this verified income statement directly from the Tax Authorities, ensuring a reliable and thorough income verification process.
Why the Budget Check is also preferrable above the PSD2 open banking solution?
Another method for income verification is through open banking or PSD2 access, where the player must grant the operator access to six months of their incoming and outgoing transactions. The operator then classifies all income and expenses to determine the player’s discretionary income. However, this method is complex and prone to errors. Additionally, from both privacy and user experience perspectives, it is far from ideal. Granting access to one’s bank transactions is highly intrusive, leading many players to hesitate or refuse to provide this level of access.
In contrast, the Budget Check offers a vastly different approach, prioritizing privacy and user convenience. At Bluem, privacy is considered a fundamental right, which is why the Budget Check is designed with privacy by design principles. Unlike other methods, the Budget Check does not share the entire income statement with the gambling site. Instead, only the necessary information—such as name, income, and year—is provided to fulfill the legal requirements. Additionally, Budget Check ensures that your income statement is not stored; it is deleted immediately after it is read.
In conclusion, the Budget Check represents a much-needed innovation in income verification. Given the increasing regulatory demands and its privacy-friendly, efficient features, it provides an effective and cost-efficient way to assess whether a player can be granted a higher playing limit.
Responsible Gaming and the RG Smart Assistant
In most regulated markets, players have to set a playing limit when they create an account. This is also the case in the Dutch market. The government does not want gamblers to set too high a limit without thinking about it, simply to be able to continue with the registration process. Therefore, the new regulations require gambling sites to contact players directly who set a deposit limit of more than €350 per month. If you are younger than 24, such a contact moment must already take place when setting a deposit limit of €150 or higher.
While the concept might sound straightforward, the reality is more complex. Customer service teams are already stretched thin, and adding the responsibility of contacting every gambler who wishes to set a higher limit would be both impractical and burdensome. Additionally, many players would likely find such conversations uncomfortable or intrusive, further complicating the process.
So, how can operators effectively manage this without overwhelming their teams or alienating players? The solution lies in automation and streamlined processes. By integrating tools like the RG Smart Assistant into their systems, operators can (semi-) automate the contact handling process, reducing the need for direct intervention by customer service. Players can complete the necessary questionnaire independently, in a secure and private manner, without the need for a potentially awkward conversation.
This approach not only lightens the load on customer service teams but also enhances the player experience by making the process more efficient and less intrusive. By leveraging technology, operators can ensure compliance with regulatory requirements while maintaining a positive relationship with their players.
Bluem’s solution: a risk-based approach to the handling of contact moments
The new “RG Smart Assistant” (partly) automates the process and supports the contact moment to a greater or lesser extent depending on the provider’s settings, risk appetite and perceived risk of the player in question.
The operator has the flexibility to determine the level of support provided by the RG Smart Assistant, ranging from fully automated with supervision (Straight-Through Processing or STP) to semi-automated (Semi STP) and assisted manual, where a responsible gaming employee of the online casino manages the chat, while the RG Smart Assistant assists by asking questions and preparing responses. The degree of automation is tailored by the gambling site according to the player’s risk profile.
For instance, in a scenario where an 18-year-old student requests a monthly limit of €2,500, the interaction would always involve direct human oversight. In this case, a responsible gaming employee would handle the conversation, supported by the insights of the smart assistant. This ensures that high-risk cases receive the necessary human attention while AI still bolster quality and efficiency.
On the other hand, if a 40-year-old player decides to set a deposit limit of €360 per month, the fully automated assistant can manage the interaction. If the player’s responses are clear and meet the necessary criteria, there would be no need for further approval by a human responsible gaming staff member. This approach balances efficiency with the need for human intervention, based on the level of risk associated with the player’s request, ensuring that both high-risk and low-risk scenarios are handled appropriately.
For example, in the Dutch context, we have to ask the player three questions and warn the player against gambling addiction. This conversation is supported by a smart Live Chat as part of the onboarding flow. A Large Language Model (LLM) ensures that you can say more in the chat than “yes” or “no” to the question of whether you really want to set €350 as a playing limit. Even if you use different wording, the assistant can handle it and should understand what you mean. And if someone starts cursing in the chat, the smart assistant understands that it might be better not to set a high limit at that moment. The advantage is that the digital assistant does not get irritated and always acts consistently and according to protocol.
However, Bluem emphasizes that operators must still have the right RG employees and knowledge in-house. The responsible gaming staff can watch live multiple chats that are handled simultaneously by the RG Smart Assistant. This way they can intervene when they deem it necessary, or when the assistant indicates that it still needs a human evaluation.
Afterwards, the gambler receives an email with a copy of the conversation, whether it was with the RG Smart Assistant or with an employee. The gambling site itself also receives a copy for the archives. This one is saved in the TOP Onboarding Dashboard.
Legally auditted by Betcomply
Bluem subjected their RG Smart Assistant to an audit by compliance consultancy firm BetComply. They were positive about the product but indicates that trained personnel must master the new tool:
“Following this research, we at BetComply Limited believe that the RG Smart Assistant is a tool that not only increases the likelihood that operators will adhere to Article 3.19 of the Dutch Gaming Limits Regulations and more conscious gaming behavior, but also that their output will be higher and the quality is better if it is deployed as described in this report, guided by trained personnel.
“However, it is of utmost importance that these people, even though they are trained in
addiction prevention, also familiarize themselves with the tool, its interfaces and how to use it correctly and safely in Live environments before fully deploying it to ensure user safety and smooth, compliant operation.”
If you would like to receive a full copy of the Betcomply report, please contact Bluem at info@bluem.nl
