Gambling regulation has long been characterized by a predictable pattern of debates: operators claim that lawmakers create sensationalized legislation, regulators accuse the industry of resisting necessary oversight, and public health specialists assert that commercial motivations undermine player protections.
In Prague, however, an innovative experiment is underway that aims to alter this narrative. Recent statistics reveal that illegal gambling is costing the Czech Republic approximately $15.9 million in lost tax revenues due to players losing around CZK 14.5 billion annually to unlicensed operators.
The Institute for Gambling Regulation (IPRH), which represents approximately 95% of the Czech Republic's regulated gambling sector, is evolving from a conventional industry association into a collaborative platform. Jan Řehola, the institute's director, emphasizes that IPRH is not merely a lobbying group; it seeks to unite operators, addiction experts, behavioral economists, regulators, and government officials to create evidence-based policies.
The success of this collaborative model is yet to be determined, but it aligns with a broader awareness emerging in European gambling regulation: neither governments nor operators alone have the necessary insights to tackle escalating challenges such as illegal gambling, online risks, and cross-border player actions.
The flagship initiative of the IPRH, known as IRIS, embodies this collaborative philosophy.
The objective of IRIS is straightforward: to prioritize the perspective of the player. As modern gamblers often juggle multiple accounts and switch between platforms responding to various promotions, operators typically have only fragments of players' behaviors.
At its core, Řehola notes, "we view gambling through the lens of the player, not the operator." What may seem like normal behavior from a single operator's viewpoint could signify emerging harm when assessed across multiple operators, such as increased stakes or prolonged playing sessions.
IRIS addresses the issue of collective action without establishing a comprehensive database of personal gambling histories, which raises privacy concerns. Instead, it operates on pseudonymized identifiers issued through the Czech state's licensing framework, meaning operators do not need to share personal customer information. The system evaluates behavioral indicators among participating operators, categorizes risk using a standardized methodology, and then communicates only the risk category back to each operator.
While the system has been constructed with careful thought, Řehola acknowledges its limitations, stating, "I would not claim IRIS is a magical solution that works for 100% of cases. Nothing in addiction prevention operates that way." What differentiates IRIS is its capacity for market-level testing; it continuously tracks players' risk scores across all operators, allowing observations of overarching risk trends and behavior adjustments following specific interventions.
Measuring success, he asserts, will not hinge on the volume of messages sent to players but rather on observable changes in player behavior—lower risk scores over time, decreased escalation, more responsible use of limits, and fewer players entering high-risk categories. Additionally, Řehola anticipates adapting the model based on its findings if particular messages fail to influence behavior. "One of IRIS's significant advantages is that interventions can be evaluated almost in real time."
This model raises an important question: can operators genuinely place player protection above their profit margins? Řehola understands the skepticism surrounding this notion. He acknowledges the commercial reality where high-intensity players contribute substantially to revenue, stating, "It would not be believable to suggest that commercial incentives vanish overnight in discussions about responsibility."
The concern remains that if responsible gambling measures are solely implemented by individual operators, it could backfire. An operator might initiate a responsible behavior intervention, only for the player to migrate to a competitor with laxer standards, leading to no real reduction in harm but a loss in revenue for the responsible operator. The IRIS model seeks to change this dynamic by fostering a collective framework where all key operators utilize the same methodology, thereby turning responsible behavior into a shared industry standard instead of a liability.
The long-term value of this approach, he suggests, is that revenue from players who are losing control is unsustainable, inviting regulatory, reputational, and political risks. Thus, nurturing long-term relationships with players who can gamble responsibly may prove more profitable than short-term gains that erode trust.
However, the effectiveness of this approach amid financial pressures remains to be fully ascertained.
A significant concern is the potential for displacement. If players evade IRIS's interventions by moving to offshore or cryptocurrency casinos, they may simply relocate the issue rather than resolve it. Řehola concedes that this is a genuine risk, stating, "If a responsible gambling tool prompts vulnerable players to seek out unregulated casinos, it does not effectively tackle the problem; it merely shifts them to a more perilous environment." He insists that IRIS needs to be viewed as part of a broader strategy, highlighting that over 240,000 individuals are registered in the Register of Excluded Persons in the Czech Republic, suggesting many still engage in illegal gambling.
People, he noted, do not abandon gambling just because their name is on a list. Consequently, IPRH collaborates with the Ministry of Finance and the Customs Administration to form a national taskforce aimed at combating illegal gambling. Protecting players in the regulated market must parallel efforts to enforce against illegal operations, he argues.
IRIS also aims to provide interventions based on risk rather than punitive measures. The objective is not to ban players but to mitigate harmful stimuli—like aggressive marketing and bonuses—particularly for those identified as high-risk while largely allowing normal players to continue without disruption. The ultimate goal, he explains, is to support players in returning to more sustainable gambling levels while remaining within the regulated market.
Determining what constitutes risky gambling poses another challenge. Behavior deemed harmful by a psychologist may simply represent a wealthy customer gambling within their financial limits. Řehola acknowledges that systems like IRIS face limitations, remarking, "There is no simple objective truth that can definitively identify addiction."
IRIS is designed not to act as a decision-making black box; rather, it generates risk signals for appropriate interventions such as reality checks or safer gambling communications. It does not solely consider the frequency of gambling but also evaluates behavioral patterns, allowing for nuanced assessments based on varied spending behaviors. Its methodology draws insights from academic research, international harm standards, and expert opinions from addiction professionals and economists.
Recognizing the imperfection of any system, Řehola states, "Should we flag too many non-risky players as problematic, we must adapt the system. The same goes for if we miss critical signs of harm in players who need help." This ongoing adjustment is vital for maintaining the credibility of the system.
The legal framework supporting IRIS is unique. Instead of building the technology first and seeking legal approval afterward, IPRH sought the reverse approach. Legislative changes effective from October 1, 2025, now explicitly allow licensed Czech gambling operators to share pseudonymized data for player protection under defined conditions. Řehola emphasizes, "This data is strictly for responsible gambling purposes and not for marketing or competitive gain."
This legislative shift received unanimous support in parliament, a rarity for gambling policy, which often falls victim to political divisions.
The broader implications of the Czech experiment suggest a departure from traditional regulatory approaches that can pit commercial interests against meaningful self-regulation or resort to severe restrictions as the sole means of addressing issues in rapidly evolving digital domains.
The Czech methodology emphasizes the need for cooperative relationships among the gambling market, public institutions, and independent experts. Řehola summarizes this philosophy as "smart regulation instead of symbolic regulation." While he refrains from overstating the model’s adaptability to other jurisdictions due to differing legal frameworks, he believes the fundamental tenets—collaboration, data emphasis, and a focus on measurable outcomes—are universally applicable.
Whether IRIS will effectively reduce gambling-related harm is still uncertain, but Řehola is open about this reality. The model will need to evolve should the supporting data dictate necessary changes, hinting at a cautious yet promising approach to gambling regulation.
