
Big Debate: As Lithuania bans all forms of gambling marketing, can a market still thrive if operators can’t advertise?
Gabyns Law Firm founding attorney Andrius Gabnys and BetGames COO Aiste Garneviciene answer this month's burning question


Yes
Andrius Gabnys, founding attorney, Gabnys Law Firm
It’s easier to say no. But I seriously doubt that it is the case. Italy, Spain, Belgium and many other countries have introduced severe advertising bans in recent years (2018-2020). It’s easy to fact check the numbers to realise that this has not stopped the markets from growing. Growing steadily or even booming. So, the short answer to the question is – yes, it can.
There is or could be a debate as to whether the ban of all sorts of gambling marketing, including the incentives (bonuses), benefits the established businesses that may put less effort to innovative and creative ways of attracting players as opposed to the operators that have recently entered the market, or those operators that are in general innovative and creative.
There is or could be a debate whether the ban on advertising benefits less wealthy businesses, who suddenly get into a more equal position to their wealthy competitors. But these are operator-specific topics related to the potential distribution of revenue, while the headline of this particular debate is a market-related debate.
In my view, the primary issue that should be taken into account is keeping the market regulated. The only possibility to keep the market healthy and happy while retaining the incentives and advertising restrictions is to keep the percentage of the black market leakage as low as possible.
As the headline speaks about Lithuania, yes, the restrictions introduced in two stages – first the severe limitation of the advertising and second the ban on incentives that will enter into force on 1 July – are overwhelming and I consider it an overkill.
But it won’t stop the Lithuanian gambling market from growing. And if the gambling authority manages to keep up with getting the black-market numbers down (even with the spectacularly crazy payment restrictions), the market will grow even more.
No
Aiste Garneviciene, COO, BetGames
A complete ban on all marketing activities relating to gambling in Lithuania will have a range of potentially serious consequences, a number of which will be unforeseen by many.
In a country where gambling is a legal and regulated activity, advertising related to that activity should not be prohibited. It’s a simple fact that a ban on advertising and other promotional activities will not stop people gambling.
From a competitive viewpoint, a promotional ban can dramatically alter the operator landscape. Such restrictions would deter new operators from entering the Lithuanian market and, with advertising so important to the establishment and growth of new entrants, a ban could see smaller brands go out of business.
That’s not only bad news for the companies in question but would also see their market share taken over by big players in the sector. Across all industries, less competition usually results in unfavourable conditions for end consumers.
One of the driving forces behind the Lithuanian marketing ban is the need to protect not just the financial wellbeing of players but also their health. While we all agree that those who are underage and those at risk of gambling-related harm must be represented and supported, a blanket ban is not a suitable strategy.
Across regulated gambling markets, we have seen that the way to best safeguard those at risk is to understand and proactively manage their needs, rather than introduce a complete ban that leaves the sector with zero visibility of the vulnerable. Furthermore, it will likely drive players to shady operators in black markets that do not consider the mental or financial health of players at all – instead of playing with responsible local operators and contributing to both market and wider economic growth.
So, no, I don’t believe the Lithuanian market will thrive when such a ban neglects the needs of both the operators and the players. It is a dangerous game that no one can win.