Four of the six markets below let somebody other than the gambler put that gambler on an exclusion list, and they do not agree on who should hold that power or why. Singapore spreads it across a relative, the National Council on Problem Gambling, an employer and the statute book itself. South Australia gives it to a venue licensee or to a delegate of the Liquor and Gambling Commissioner after a hearing. Pennsylvania gives it to the regulator alone, on grounds that say nothing about protecting the gambler. For an operator licensed in more than one of these places, the practical problem is that each route arrives with its own evidence file, its own identity-matching problem and its own appeal path, even though all of them end in the same blocked account.
Key Takeaways
- Third-party gambling exclusion means a person is barred from gambling on somebody else’s application, or on a regulator’s own initiative, rather than at their own request. Singapore, the Philippines and South Australia run welfare-based versions of it. Pennsylvania runs a conduct-based one, and Estonia and Great Britain leave the decision entirely with the player.
- Singapore has the widest set of routes of any licensed market: a family exclusion order under section 162(1) of the Casino Control Act 2006, a third party exclusion order the National Council on Problem Gambling can make under section 165(1) with nobody applying, exclusion by operation of law under section 165A, and employer applications that cover work permit holders.
- The Philippines approved close to 40,000 exclusion applications in the six months to October 2026, against fewer than 2,000 before, and PAGCOR’s family route is open to a spouse, a parent or an adult child.
- Pennsylvania’s Involuntary Casino Exclusion List is a conduct list rather than a harm list. The test in 4 Pa.C.S. section 1514 reaches career offenders and people whose presence is inimical to the interest of the Commonwealth, and it contains no ground for excluding somebody for their own protection.
What counts as third-party gambling exclusion?
Third-party gambling exclusion is an exclusion applied to a person on another party’s application, or on a regulator’s own motion, rather than at the gambler’s request. Every control built around self-exclusion assumes the excluded person asked for it, and that assumption does more work than it looks. Identity verification is easy when the subject filled in the form themselves. Marketing suppression is easy when the record being suppressed came from the subject in the first place. Reinstatement is the step that really breaks, because the whole design ends with the player asking to come back, and an order a relative obtained does not end that way.
Singapore carries the widest set of routes. Part 10 of the Casino Control Act 2006 holds a family exclusion order under section 162(1), a family visit limit under section 163A(4), a third party exclusion order the National Council on Problem Gambling may make under section 165(1) without anyone applying, exclusion by operation of law under section 165A, self-exclusion under section 165AA and a voluntary visit limit under section 165B. (1) (2) Two of those six begin with the gambler.
The scale is the part that tends to get missed. NCPG figures reported in August 2026 put Singapore’s total exclusions and bans past 450,000, with 154,261 foreigners excluded from the casinos in 2024, roughly 13 per cent of the country’s 1.16 million work permit holders, and employers accounting for about two thirds of the foreign-worker casino exclusions. Exclusions from Singapore Pools online betting rose from about 4,100 in 2022 to about 24,000 in 2024, and jackpot machine room exclusions from about 5,100 to about 28,000 across the same two years. (3) Exclusion by law was extended to all Public Rental Scheme tenants and occupiers on 1 June 2022. (4) Anybody describing Singapore as a self-exclusion market has the dominant route the wrong way round.
Which markets allow third-party gambling exclusion, and who signs the order?
Four of the six markets below allow a non-player to start the process, and no two of them put the decision in the same hands. What changes between the columns is the decision-maker, and once that changes, so does the evidence an operator has to be able to produce.
| Market | Who can start it | Who decides | What it reaches | Duration and exit |
| Singapore | A family member, the NCPG on its own motion, an employer, or operation of law | NCPG and its Committees. A third party exclusion order under s 165(1) needs no application at all | Casinos, jackpot machine rooms and Singapore Pools online betting | Set by the Council. Since 21 September 2026 an order and a visit limit can be swapped immediately under s 166A |
| Philippines | The player, or a spouse, parent or adult child | PAGCOR, recorded in its National Database of Restricted Persons | PAGCOR-licensed casinos, land-based and online | Family route 6 months, 1 year or 3 years. Self route 6 months, 1 year or 5 years, first 6 months irrevocable |
| South Australia | The player, a venue licensee, or a relative, friend or other person with a genuine interest in the player’s welfare | The gambling provider, or a delegate of the Liquor and Gambling Commissioner at a hearing, under s 44(1)(b) | Specified activities, premises or prescribed places under s 43, including in-person and online betting and lotteries | Specified or unlimited period under s 44(4)(c). CBS voluntary minimum up to 12 months, provider minimum up to 3 months |
| Pennsylvania | The Bureau of Investigations and Enforcement or the Office of Enforcement Counsel | The Gaming Control Board, on the 4 Pa.C.S. s 1514 criteria, with a hearing on 30 days’ demand | Land-based casinos, and online accounts through the separate iGaming list | No term set in the statute. Removal is by petition under 58 Pa. Code s 511a.9 |
| Estonia | The player only | Estonian Tax and Customs Board, which holds the register | Games of chance, sports betting and classical lotteries. Instant lotteries cannot be restricted | 6 to 36 months chosen on application, removable only after the term and by a separate application |
| Great Britain | The player only | GAMSTOP, which remote licensees must participate in under SR code 3.5.5(1) | Remote licensed gambling, widened to telephone and email betting on 1 April 2024 | Chosen by the player |
Estonia and Great Britain sit in the table as the control group. Both run a national register, both make participation a condition of licensing, and in both the only person who can put a name on it is the person whose name it is. (15) (16)
Why did the Philippines go from fewer than 2,000 exclusions to nearly 40,000 in six months?
Because the route was promoted rather than merely published. PAGCOR chairman and chief executive Alejandro Tengco told reporters in Boracay on 11 October 2026 that close to 40,000 applications had been approved in the previous six months, against fewer than 2,000 before, and said the programme had been strengthened in June. (5) A national problem gambling helpline opened on 26 May 2026, running around the clock, and operators were directed to carry it in gambling advertising. (5) The exclusion reaches both land-based and online PAGCOR-licensed sites through the National Database of Restricted Persons, so the usual move to the next operator closes with it.
Two consequences follow for anyone licensed there. The first is volume, because a database that grows twentyfold in two quarters puts a different load on account matching than one growing by a few hundred a year, and a failed match on a family-filed exclusion is a harder conversation than a failed match on a self-exclusion, since there is a complainant already waiting. The second is custody. PAGCOR both operates 35 casinos and holds the restricted persons database, and Tengco said on 14 October 2026 that the agency is targeting a sale of its Casino Filipino business in the third or fourth quarter of 2027, with between 20 and 30 billion pesos expected from the privatisation. (6) Nobody has said publicly who will hold and maintain the exclusion database once the regulator stops being an operator.
Why is Pennsylvania’s involuntary casino exclusion list not a harm tool?
Because the statute contains no harm ground. Section 1514(a) of 4 Pa.C.S. reaches persons who are career or professional offenders, and persons whose presence in a licensed facility would, in the Board’s opinion, be inimical to the interest of the Commonwealth or of licensed gaming. (7) Subsection (c) rules out race, colour, creed, national origin, ancestry and sex as grounds. Subsection (g) gives the subject 30 days from service to demand a hearing, at which the bureau carries the burden, and subsection (h) takes a Board order to the Commonwealth Court. Protecting the subject from their own gambling appears nowhere in it.
What the Board has been doing with that power is child-safety enforcement. On 14 October 2026 it placed eight people on the Involuntary Casino Exclusion List, five of them for leaving minors unattended: a woman who left an 11-month-old in a vehicle in the Rivers Casino Philadelphia parking garage for one hour and 52 minutes while playing table games, a man and a woman who left an 11-year-old in the Wind Creek Bethlehem food court for one hour and 14 minutes while playing slot machines, and a man and a woman who left an 11-year-old and two dogs in a vehicle at Live! Philadelphia Casino for 23 minutes. (8) Those actions took the running total across the Board’s involuntary exclusion lists to 1,512.
A January 2025 release gives the comparison point: 26 placements in a single sitting, four for unattended minors, 14 for other offences, and eight on the iGaming list for account fraud, one of which involved chargebacks worth US$6,681, against a cumulative 1,269 on the casino list and 61 on the iGaming list at that date. (9) A compliance function that files all of this under responsible gambling will build the wrong evidence pack, because what the Board wants to see is surveillance footage, incident reports and preserved evidence rather than customer interaction records.
What does the divergence cost an operator licensed in more than one market?
It costs the single exclusion process, and four specific things break in it.
- Identity matching. A self-excluded player handed over their own identifiers. A family-filed exclusion arrives with identifiers supplied by somebody else, and PAGCOR’s family route calls for the respondent’s government photo identification, the applicant’s identification, two photographs of the respondent taken within the last six months, and a birth certificate or marriage contract to prove the relationship. (10) The quality of what you are matching against is outside your control.
- Evidence retention. South Australia’s involuntary route runs on bank statements, late bills and screenshots of messages about gambling or borrowing money, assessed at a hearing the subject may choose not to attend, with an order still available in their absence and a right to ask for reconsideration afterwards. (11) An operator inside that process carries a disclosure exposure it never carries on a self-exclusion.
- Reinstatement. Section 166A now lets Singapore’s Council swap a family exclusion order for a family visit limit, or tighten a visit limit into an exclusion order, immediately rather than over the one to two months the change used to take. (12) Any reinstatement logic keyed to a request from the subject will mishandle both directions of that swap.
- Penalty exposure. South Australia fines a gambling provider or other prescribed person up to A$10,000 for permitting a contravention, and A$10,000 again for failing to notify Consumer and Business Services of a breach, with breaches recorded and forms uploaded within seven days. The barred person’s own penalty is A$2,500 under section 47(1). (13) The bigger number falls on the operator.
Estonia is the market to watch, since it is the one arguing about the move in public. Rainer Osanik, who heads financial information policy at the Ministry of Finance, said in August 2026 that nobody else can currently add a person to the list and that the system should allow it at a relative’s initiative or by court order, with the Gambling Act review due in 2027 and no commencement date yet fixed. (14) The register he was describing held about 21,000 people against 17,203 in 2023, with 20,628 active restrictions on games of chance, 9,767 on sports betting and 5,968 on lottery products, every one of them self-applied for a chosen term of six to 36 months and removable only once that term has run. (14) (15) Officials have also flagged the obvious risk, which is that a compulsory route puts people off the voluntary one.
What should a board ask for before the next licence renewal?
Six things, and all of them are documents rather than intentions.
- A route register, per licence. For every market the business is licensed in, list each lawful route by which a person can arrive on the exclusion list, with the statutory provision beside it. Singapore alone needs six rows.
- A named owner for each route. Say which function receives the order, which verifies identity against it, and which answers an appeal. A family-filed exclusion and a regulator-imposed exclusion rarely belong with the same team.
- An evidence standard the business can actually meet for an exclusion it did not originate. Write down what will be held and for how long, then test it against the disclosure the business would face at a reconsideration hearing.
- Reinstatement rules that tell the applicant apart from the subject. The process should refuse a re-registration request from a subject whose exclusion somebody else applied for, and should handle a substitution between an order and a visit limit without a manual exception.
- A conduct-list workstream kept separate from the harm workstream, with its own evidence requirements, in the control framework and in the audit trail.
- A written answer on custody. Where a state body both operates and regulates, ask who holds the exclusion database after a divestment, and get it in writing before the transaction closes rather than after.
Boardroom Questions
- How many lawful routes onto our exclusion list exist in each market we are licensed in, and could we produce the statutory reference for every one of them today?
- Which of our exclusion controls would fail if the excluded person had never contacted us?
- Who signs off a refusal to act on a family-filed exclusion, and what happens when the relative comes back a second time?
- If a regulator placed one of our customers on a conduct-based exclusion list tomorrow, which team would receive the notice, and how long before the account was blocked across every product?
- What is our maximum penalty exposure for permitting a single contravention in each market, and does our breach-notification timetable meet the shortest deadline we face?
- If Estonia adopts a relative or court route in 2027, what would we have to change, and would we hear about it from the regulator or from a customer complaint?
Sources
(1) Casino Control Act 2006 (Singapore), Part 10, sections 162, 163A, 165, 165A, 165AA, 165B, 165D, 166A and 168, Singapore Statutes Online.
(2) Casino Control (Amendment) Act 2024 (Act 29 of 2024), Singapore, published 3 October 2024, clauses 53, 61 to 78. Subsidiary legislation under the Casino Control Act 2006 was gazetted on 18 September 2026 as No. S 650 of 2026, covering the Council and its Committees.
(3) National Council on Problem Gambling exclusion figures for 2022 and 2024, reported 19 August 2026, with comment from NCPG chairman Sim Gim Guan. These are NCPG’s own figures as reported; NCPG does not publish them in a single downloadable return.
(4) Ministry of Social and Family Development (Singapore), Strengthening Social Safeguards For Gambling, 13 February 2022.
(5) Philippine Star, PAGCOR: Nearly 40K gamblers volunteer for self exclusion, 13 October 2026, quoting PAGCOR chairman and chief executive Alejandro Tengco.
(6) Philippine Star, PAGCOR targets casino exit by 2027, 14 October 2026.
(7) 4 Pa.C.S. section 1514, Regulation requiring exclusion or ejection of certain persons, subsections (a), (c), (g) and (h).
(8) Pennsylvania Gaming Control Board, PA Gaming Control Board Revokes Gambling Privileges from 8 Persons, 14 October 2026.
(9) Pennsylvania Gaming Control Board, PA Gaming Control Board Places 26 Individuals on its Involuntary Exclusion Lists, 15 January 2025.
(10) Philippine Amusement and Gaming Corporation, Self Exclusion and Family Exclusion requirements, pagcor.ph regulatory pages, read 22 October 2026.
(11) Government of South Australia, Request an involuntary barring, and Barrings from gaming machine venues, sa.gov.au, read 22 October 2026.
(12) Ministry of Home Affairs (Singapore), Second tranche of amendments to the Casino Control (Amendment) Act 2024 to take effect on 21 September 2026, 21 September 2026.
(13) Gambling Administration Act 2019 (South Australia), sections 43 to 49, in particular sections 44(1)(b), 44(4)(c), 44(6), 45(1), 46, 47(1), 47(2) and 49.
(14) Estonian Ministry of Finance, comments by Rainer Osanik, head of financial information policy, to Estonian Public Broadcasting, reported 5 August 2026.
(15) Estonian Tax and Customs Board, Setting restrictions on gambling, emta.ee, read 22 October 2026.
(16) Gambling Commission, LCCP social responsibility code provision 3.5.5(1), and consultation response on changes to multi-operator self-exclusion, published 17 October 2023, in force 1 April 2024.