1. Benchmark Defined
A self-exclusion register lets a player lock themselves out of gambling for a fixed period, and the design question every regulator has had to answer is whether that lock should cover every channel a player might use, online and land-based together through a single identity check, or whether it is acceptable to run separate systems for separate types of venue. This benchmark applies to both online and land-based gambling, and it is one of the few areas where the honest comparison is not between four broadly similar systems but between three markets that converged on the same cross-channel answer and one, the UK, that did not.
2. Global Comparison
GAMSTOP, the UK’s online self-exclusion scheme, lets a player lock themselves out of every online operator with a single request, and the Gambling Commission is clear that operators must close the account and return any funds still held. Land-based gambling runs on a different logic entirely: rather than one national register, separate multi-operator schemes exist for each type of land-based venue, so a single request excludes a player from that category of premises in their area rather than from land-based gambling as a whole, and none of these land-based schemes are linked to GAMSTOP or to each other by a shared identity check.
Belgium took the opposite path. Its Excluded Persons Information System, EPIS, run by the Gaming Commission, covers casinos, arcades and betting, whether the player accesses them online or in person, checking a player’s surname, first name and date of birth against a single national list before any of those channels can let them play. The system also allows exclusion routes the UK does not offer as standard, including requests from family members, automatic bans for magistrates, notaries, bailiffs and police, and preventive exclusion for people already under provisional financial administration.
Germany’s OASIS register, live since the country’s gambling treaty took effect in August 2021, works the same cross-channel way. Every licensed operator, online or land-based, has to check a customer against OASIS before play begins, and the system had recorded nearly 337,000 registrations by July 2025, with one-year bans the most common choice and roughly 3% of entries coming from a concerned third party rather than the player themselves, each of which triggers a minimum twelve-month exclusion regardless of what the player wants. Germany’s regulator reported more than 100 million verification checks a month across the licensed market in 2024, which gives some sense of how much of the country’s gambling activity now runs through that single check.
The Netherlands built CRUKS on the same principle when its remote gambling market opened in March 2021, requiring a player’s national service number to generate a code checked against both online operators and land-based venues including the state casino group, with the underlying identity data deleted once the code is issued so the regulator holds aggregated exclusion numbers rather than a record of anyone’s play. The Dutch regulator is now proposing to widen that reach further, by linking CRUKS automatically to the separate national register of adults already under financial guardianship, so identified vulnerable groups are excluded without having to opt in themselves.
3. Analysis
Three of these four markets decided a national identity number was the cleanest way to solve this problem, and built one register that every operator, online or in a betting shop or casino, has to check before a customer can play, so a player who excludes themselves in Rotterdam or Brussels or Berlin is excluded everywhere that day, not just on the channel where they asked. The UK took a different route because its self-exclusion schemes grew up channel by channel over a much longer period, GAMSTOP arriving for online only in 2018 long after separate land-based schemes were already running, and unifying them now would mean building the kind of shared national identity check the UK has been reluctant to require for gambling specifically, even as it works well elsewhere in Europe.
It is worth asking what would have happened had the UK built GAMSTOP as a cross-channel register from the outset, the way Belgium and Germany did. A land-based operator would then have had to check every walk-in customer against the same database an online operator checks, which is a meaningfully bigger compliance lift for the retail estate than anything the sector currently carries, and it is not hard to see why an industry already absorbing a new statutory levy and a tightening affordability regime resisted taking on that cost as well. The gap this leaves is real all the same: a customer excluded from every online operator in Britain can still walk into a licensed casino the same afternoon, which is not a gap any of the three continental systems in this comparison would allow.
4. Governance Lessons
A board should not assume self-exclusion coverage is equivalent across markets just because every market it operates in has a scheme, since a UK-style channel-split system and a Belgian or German-style unified register represent genuinely different levels of protection for the same customer.
The direction of regulatory travel, in the Netherlands most explicitly, is toward linking exclusion registers to other data sources rather than leaving them as a standalone opt-in tool, and operators should expect that trend to reach other markets over time.
Where a register is cross-channel, as in Belgium, Germany and the Netherlands, land-based compliance teams carry real exposure they may currently be underweighting, since a failure to check an identity document against the national register is treated the same as an online operator failing to check GAMSTOP.
Third-party and professional exclusion routes, used in both Belgium and Germany, are a meaningful gap in a compliance programme built only around what the player themselves requests, and are worth testing for even in markets where they are not currently mandatory.
5. Boardroom Questions
1. In every market where we hold a land-based licence, do we know whether the self-exclusion register we check is the same one our online operation checks, or a separate system entirely?
2. If the UK moved toward a Belgian or German-style unified register, what would it cost our retail estate to build the identity checking capability our online business already has?
3. Do we have a process for handling third-party exclusion requests, such as from a family member, in every market where that route exists, even if it is not yet a requirement in all of them?
Sources
1. Gambling Commission, Self-exclusion, accessed July 2026, https://www.gamblingcommission.gov.uk/public-and-players/page/self-exclusion
2. Gaming Commission (Belgium), Access ban, accessed July 2026, https://www.gamingcommission.be/en/protection-of-players/access-ban
3. iGaming Business, Germany’s OASIS self-exclusion scheme nears 350,000 sign-ups, accessed July 2026, https://igamingbusiness.com/sustainable-gambling/responsible-gambling/germany-self-exclusion-scheme-sign-ups/
4. iGaming Expert, OASIS self-exclusion proves effective for volatile German gambling market, accessed July 2026, https://igamingexpert.com/regions/europe/oasis-self-exclusion-proves-effective-for-volatile-german-gambling-market/ (Tier 2, cross-referenced against the iGaming Business source above for registration figures)
5. iGaming Business, Netherlands outlines details of Cruks self-exclusion tool, accessed July 2026, https://igamingbusiness.com/tech-innovation/regtech/netherlands-outlines-details-of-cruks-self-exclusion-tool/
6. SBC News, KSA Chairman seeks better financial guardianship of gambling, 8 July 2026, https://sbcnews.co.uk/europe/2026/07/08/ksa-chairman-2026