Bingo Project Report Final

THE BINGO
PROJECT
Rethinking gambling regulation

www.kent.ac.uk/thebingoproject 1
TABLE OF CONTENTS
Research Summary 3 3.3.1 The shifting attitudes of lawmakers and the declining
visibility of the non-commercial sector
Introduction 5
3.3.2 The challenge of defining the game: the importance of
i Why bingo? 5
game mechanics and environment
ii Our key questions 7
3.3.3 Risky play and the increasing formalisation of harm
iii Our case studies 7
prevention
iv Our findings and this report 9
3.4 Recommendations 45
v Acknowledgements 10
3.4.1 Involve non-commercial bingo operators more
systematically into debates about gambling regulation
Chapter 1: Bingo regulation in Brazil 11
3.4.2 Consider testing partial self-exclusion in bingo with
1.1 Overview of the case 11
willing operators
1.2 Scale, distribution, and demographics of play 11
3.4.3 Consider formalising social responsibility training
1.3 Regulation of bingo in Brazil 12
and staff accreditation alongside the requirement to
1.4 Key themes 14
intervene, across the gambling sector
1.4.1 A lack of systematic attention to regulatory objectives,
3.5 Table of key cases 48
instruments, and processes contributed to the failure of
Brazil’s bingo market and damaged public confidence
Chapter 4: Regulation on online bingo in the European Union 50
1.4.2 Changing bingo environments in Brazil: From diversity to
4.1 Scale of play 50
clandestine, decapitalised uniformity
4.2 The law and regulation of online bingo 51
1.4.3 A growing, preemptive concern with pathology
4.2.1 European regulation of online bingo
and addiction
4.2.2 National approaches to the regulation of online bingo
4.3 Key themes 53
1.5.1 Legalise bingo along with other games
4.3.1 The social nature of the game
1.5.2 Design a regulatory infrastructure that draws on best
4.3.2 Defining the game
practice from elsewhere
4.3.3 The role of online slots to online bingo
1.5.3 Prioritise crime prevention as a regulatory objective
4.3.4 Lotteries, charities, and online bingo
1.5.4 Consider reforms to the consumer code to better
protect players
4.5.1 Improved representation of bingo at the European level
4.5.2 Greater regulatory recognition of the importance of bingo
for the non-profit sector
Chapter 2: Bingo regulation in Canada (Ontario and
4.5.3 Expanding the concept of fairness within online
British Columbia) 23
gambling regulation
2.1 Current approach to law and regulation 23
2.2 Scale of play and bingo demographics 23
2.3 Key themes 27
Chapter 5: Some lessons from the comparative perspective 61
2.3.1 The shifting debate about the charitable role in bingo
5.1 The value of expanding the concept of ‘responsible 61
2.3.2 Coping with decline: regulating diverse game innovations.
gambling’ to better reflect fairness for players and workers
2.3.3 The key role of other governments
5.2 The need for context-specific consideration of whether 61
2.3.4 Standardisation of bingo using risk-based regulation
non-commercial actors should be privileged as bingo operators
approaches from casinos
by regulators, taking into account how such actors use
proceeds, how they are connected to players as donors, and
2.4.1 Expand the stakeholders involved in debates
how they mobilise volunteers
about regulation
5.3 The need for rules that reflect the distinctiveness of bingo 63
2.4.2 Consider how regulators could better support
as a game, and a playing environment
independently-licensed charitable bingos
5.4 A potential role for gambling regulators in supporting and 63
2.4.3 Improve jurisdictional collaboration at local levels of
preserving everyday, vernacular forms of play like bingo
government
5.5 The need to better support international collaborations across 64
2.4.4 Explore options for better supporting low-tech and
local governments that license low-level forms of gambling
entertainment-focused game innovations
such as bingos
2.4.5 Ensure that bingo operators are included in Ontario’s
5.6 How is gender relevant to the regulation of bingo? 64
current provincial discussions on whether and how to
A diverse answer
relax rules on computerised raffles
2.5 Table of key cases 32 Appendix 1: Research methodology and approach to analysis 69
Chapter 3: Bingo regulation in England and Wales 35 Appendix 2: Sources we have found useful in our research 71
3.1 Current regulation 35 The Research Team 73
3.2 Scale of play and bingo demographics 36
3.3 Key themes 40 The Advisory Group 75
Front cover: Bingo players playing a side game during an interval, Kent.
Image taken by Andrea Shieber.
2 The Bingo Project
RESEARCH SUMMARY
The Bingo Project (www.kent.ac.uk/thebingoproject) has hoped to achieve two key objectives: to better
understand how the game of bingo is regulated in different places around the world, and to relate that
better understanding back to debates in law, politics, and political economy about gambling.
Funded by the Economic and Social Research Council, This report – aimed at non-academics interested in
one of the UK’s main academic research funders, the gambling regulation – summarises what we have learned
three-year project selected four case studies of bingo in so far from our research. It describes how the game is
England and Wales, Canada, Brazil, and online in the regulated, and the scale of play. Each chapter identifies
European Union. We wanted to gain a good overview of some ‘key themes’ that suggest what can be learned more
the diverse ways in which bingo is played (online versus broadly from bingo. These cover topics such as the impact
land-based; in commercial halls versus in charitable of prohibition on players and operators; the shift in political
facilities), and of legal approaches (e.g. criminal attitudes to bingo over time; the regulation of game
prohibition, licensing as charitable activity; licensing as definition; the use of proceeds by charitable bingo
commercial activity). providers; and the social nature of online bingo play.
Each case study chapter also contains substantive
We focused on bingo because it is a globally significant, recommendations, drawn from the research, for those
but under-studied, gambling form. It is a social, community involved in bingo regulation. These range from a set of
activity for many people, and in many places it attracts a recommendations about legalising bingo in Brazil, to a
distinctive demographic of players. In England and Wales suggestion that the focus of European Union level
and Canada bingo is especially popular with older, working discussions of consumer protection in online gambling be
class women. First Nations/Native American players are a expanded beyond problem gambling, underage gambling,
key part of the player base in North America. We hoped and responsible gambling to also encompass the
that bingo would provide us with some insights into how regulation of substantive fairness. In each case study
classed, aged, raced, and gendered gambling cultures chapter we have also included a table of the most
are shaped by regulation. We were also interested in bingo important legal cases on bingo. These cases shed light on
because it is associated with charitable fundraising as how courts in different places have handled disputes over
much as, if not more than, commercial gambling in many which level of government has authority over bingo; how
places. Charities, religious organisations, and non-profit bingo proceeds should be used; how the game’s
groups often operate the gaming themselves, making boundaries should be defined; and how far licensing
bingo a key example of the intersection between playful discretion should extend.
speculation and good works. The ‘vice’ of gambling meets
the ‘virtue’ of local charity, mutual aid, and community head In the final, comparative chapter of the report we develop
on in bingo, and we wanted to know what impact that had some over-arching lessons, using our research from across
on regulatory priorities in different places. the four case studies. In particular, we highlight the
following key points:
Our research for the Bingo Project involved 217 interviews,
with 255 people involved in bingo. They included operators 1 The value of expanding the concept of ‘responsible
(commercial and non-commercial), regulators (across gambling’ to better reflect fairness for players and
many levels of government, from the municipal to the workers.
supra-national), politicians, specialist lawyers, judges, 2 The need for context-specific consideration of whether
employees, volunteers, software designers, and bingo non-commercial actors should be privileged as bingo
equipment manufacturers. We conducted a systematic operators by regulators, taking into account how such
review of relevant case law, legislation, and regulatory actors use proceeds, how they are connected to players
guidance, official records of political debate, consultations, as donors, and how they mobilise volunteers.
and annual reports from bingo regulators and operators. 3 The need for rules that reflect the distinctiveness of
We have a collection of over 1000 relevant legal cases bingo as a game, and a playing environment.
across the four case studies, stretching back to 1845. We 4 A potential role for gambling regulators in supporting
also have thousands of pages of historical political debate and preserving everyday, vernacular forms of play like
about bingo, stretching back to 1936. Finally we conducted bingo.
observations of legal bingo games in three of the four case 5 The need to better support international collaborations
studies (we were unable to find legal games in Brazil), to across local governments that license low-level forms of
see how rules and regulations were implemented in gambling such as bingos.
practice. 6 The uneven effects of the female-dominated nature of
bingo on its regulation.
4 The Bingo Project
THE BINGO PROJECT:

AN INTRODUCTION TO
RETHINKING WHAT COUNTS
“Let’s face it, Las Vegas uses bingo halls as loss leaders. They know they’re going
to bring in the one spouse that likes to play bingo and the other spouse that’s going
to go and really spend the money where it counts.” (female charity bingo hall
manager, Canada).
Why bingo? So, taking gambling seriously in law and political

economy is nothing new.
The Bingo Project (www.kent.ac.uk/
thebingoproject/) was a research project funded However our research project focused on
by the Economic and Social Research Council – everyday practices of bingo rather than
one of the UK’s main academic research funders. spectacles of stockmarkets as giant casinos.
It used four case studies of bingo regulation We chose this focus because bingo is a globally
around the world to explore the governance of significant, but under-studied, gambling form,
risk, welfare, and gambling in law, politics, and played in many countries and increasingly
political economy.
“When (asked) what do you do for a living, I
popular online. It is a lottery-style game where
say I rob old ladies of their pensions. Which

players cross numbers, called randomly, off a
That might seem strange.
usually makes people think that I’m a financial
ticket to form patterns and (they hope) win prizes.
advisor (laughs)” (male, bingo hall manager,

But gambling has long been studied by It is globally salient, and increasingly transnational
England).
researchers in law, politics, and political economy. in operation. Although bingo spread globally
It has been used to think through concepts of through military and missionary circuits in the
“What we established here in Brazil was bingo,

fairness, deserved rewards, worthwhile leisure, early twentieth century (with the Irish courts
bingo as a neighbourhood game, a place for

responsible consumption, and the state’s role in asked to rule on its legality as early as 1916),4
individuals to socialise” (male, industry

harm prevention.1 It also plays a key role in our as the game has spread online new operators
analyst, Rio de Janiero)

discussions about how market economies should are emerging to offer play across borders.
function. For example:
“One of my favourite halls we did – I’ll never
Bingo is interesting in part because it is so
forget these two elderly ladies, they must have

• gambling is so central to debates about diverse, with significant variations in play. Some
been in their 60s, 70s, loving it. They said, ‘we

individual choice and the role of the state countries play with 90 numbers, some with 75,
are loving this. But you know who really loves

that the political philosopher John Stuart Mill and different patterns are required in different
this?’ And I said ‘Who?.’ They said ‘our mom.’”

devoted a long section to it in his 1859 book places to win prizes. During our research players
(male organiser of bingo-based entertainment

On Liberty. told us about winning life changing jackpots in
events in British Columbia, Canada).

• as a popular, playful, entertaining form of commercial bingo halls, playing down the pub
engaging with chance for gain, gambling has with old friends for slabs of meat, buying virtual
“Gambling is at the boundary between personal

to be continuously distinguished in law and cups of tea (with real money) to share with online
freedom and state intervention. On one side of the

policy from its serious, productive, properly- bingo buddies, and getting their handbags
boundary is the reasonable expectation of adults

capitalist others: insurance; stock market searched for illegal winnings during a police raid.
who, within the law, exercise their right to live

speculation; weather derivatives, and so on.2 We met people volunteering to sell tickets at
their lives as they choose. On the other is the role

• when economic crises occur, scholars and bingo so that their child would get access to a
of the state: to recognise human frailty, and in

politicians often use casinos as a metaphor sports programme, and we watched drag queen
particular to respect its duty to protect children

in their critiques of capitalist excesses. Both bingo callers simulate sex acts with players when
and the vulnerable. As a Government and a

UK Prime Minister David Cameron and US particular numbers were drawn.
President Barack Obama spoke of the dangers society, we have three options in that respect:
of ‘casino capitalism’ after the 2008 financial prohibition, a free-for-all or regulation. We have
crisis, echoing those who have used the term no doubt about choosing the regulatory route.
to highlight inadequate control over financial (Tessa Jowell, UK Minister of Culture Media and
markets.3 As gambling researcher Rebecca Sport, in a debate on the Gambling Bill, 1 Nov
Cassidy (2009) points out, the irony here is that 2004, vol. 426, col. 28).
casinos are actually very heavily regulated.
1 See for example Gerda Reith. 2002. The Age of chance: Gambling in Western Culture. London: Routledge.
2 See for example G. Clark. 1999. Betting on Lives. Manchester: Manchester UP; U. Staheli. 2013. Spectacular Speculation: Thrills, the economy
and popular discourse. Stanford: Standford UP; R. Cassidy et al. 2013. Qualitative Research in Gambling. London: Roultedge.
3 See especially Susan Strange (1986), who coined the term ‘casino capitalism’
4 Barrett v Flynn [1916] 2 Ir. R. 1 (KB).
6 The Bingo Project
THE BINGO PROJECT: AN INTRODUCTION

TO RETHINKING WHAT COUNTS
The demographics of bingo are also distinctive, for lotteries, often run by the state or a state-
especially when measured against the popular chosen monopoly provider. However in bingo
images of high-spending, glamorous, risk-taking charities, religious organisations, and non-profit
men associated with casino table games. Bingo is groups have often themselves retained a key role
one of the few forms of gambling that attracts in operating the gaming, making bingo a key
more female than male players: women were over example of the intersection between playful
80% of the players in some of the bingo halls in speculation and good works. The ‘vice’ of
our research. Even online – where there are more gambling meets the ‘virtue’ of local charity, mutual
male bingo players than in land based venues – aid, and community head on in bingo, and
the game tends to attract more female players regulatory priorities are consequently complex
than sports betting, casino games, and online and contested.
poker. In many places bingo is especially popular
with older, working class women. Moreover, First
Nations/Native American players are a key part of What do we mean by regulation?
the player base in North America. When we Bingo may be impacted by a range of laws,
began the research project, we hoped that bingo policies, recommendations, guidance
would provide us with some insights into how documents, codes of practice, standards,
classed, aged, raced, and gendered gambling and street-level enforcement mechanisms.
cultures are shaped by law. Rule-making by lawmakers and courts, at
various levels, is certainly crucial. But it
exists alongside rule-making by sector
Bingo and the casino shadow experts in governmental agencies, and rule-
In political debate, as in academic making by non-government groups such as
research, bingo has long been in the businesses and charities. Regulation is a
shadow of casinos. But interesting things convenient way of talking about these plural
can happen out of the spotlight. In 2012-3 forms of legal and political power. One
Toronto was consumed by a fight over a definition we have found helpful is provided
“De dona-de-casa a dona da Casa!” – from
housewife to homeowner, official poster with an
downtown casino. During this time bingo by Bettina Lange, Fiona Haines, and Dania
old advertisement for the federal lottery, Brazil. businesses worked with the provincial Thomas in their book on Regulatory
regulator, municipalities, and charities to Transformations: Rethinking Economy-
negotiate opening new gaming facilities. As Society Interactions: “both legal and non-
one industry insider put it, with a smile, all legal processes for changing the behaviour
the light was on casinos while “donkey of economic actors according to specific
bingo plods along and gets ahead” (male, standards, backed up by institutions and
Ontario). mechanisms of enforcement.”7
Some academic researchers argue that
Finally, we were interested in bingo because it is prohibition should not really be considered
associated with charitable fundraising as much a form of regulation, since the term implies
as, if not more than, commercial gambling in a preference for less coercive mechanisms
many places. As a result, it raises distinctive and of shaping behavior. For example in her
pressing questions about law and policy within book on regulation of the British Railways,
many jurisdictions. Bridget Hutter argues that “The very use of
the word regulation signals a toleration of
Charitable gaming – in forms such as raffles, the activity subject to control. Regulation is
tombolas, lotteries, and bingos – is the most not an attempt to eradicate risk, crucially it
widely available form of legal gambling. As is an attempt to manage it.”8 Others argue
gambling researcher Sytze Kingma argues, that some states are increasingly relying on
gambling liberalisation is often reliant on the criminal law as a form of regulation, in
“charitable alibi” that the money raised will go to arenas such as anti-social behaviour.9 In this
worthy causes (2008, 448).5 Others refer to the report we include criminal law within our
‘halo’ around charitable gaming that can result in research on regulation.
inadequate regulatory oversight6 (Christensen et
al. 2009). The charitable rationale is of course key
5 Kingma, S. 2008. ‘The liberalization and (re) regulation of Dutch gambling markets: National consequences of the
changing European context.’ Regulation & Governance 2(4): 448.
6 Christensen, R. et al. 2009. ‘Light and Dark Sides of Nonprofit Activities and the Rules to Manage Them: The Case
of Charitable Bingo.’ Administration and Society 41 (2): 213–34.
7 p 7. (Hart, Oxford 2015).
Our key questions 2 To make a contribution to academic research in that in Brazil (as elsewhere) evokes family
law and political economy by advancing holidays, charitable fundraising and older
The Bingo Project aimed to do two things: better
knowledge of a neglected site in global women’s sociality – acquired such menacing
understand how the game was regulated in
gambling liberalisation debates. In particular, connotations during its brief period of
different places, and relate that better
we aimed to explore how the governance of commercialisation, and to identify whether and
understanding back to debates in law, politics,
risk and speculation are gendered, and related how trust can be re-built.
and political economy about gambling.
to concerns about charity. Key questions 2 Canada (Ontario and British Columbia, land-
Specifically the objectives were:
included: based). In many parts of Canada bingo is a
1 To provide the first systematic account of how 2.1 How, and to what extent, does it matter to source of fundraising for charities, service
bingo is regulated, with the aim of identifying regulators that bingo is part of a clubs, and religious institutions, with games run
the key legal and policy challenges involved in gendered gambling culture? Does the by volunteers (sometimes in partnership with
regulating bingo as experienced by a variety of female-dominated nature of the game private gaming service providers). More
stakeholders, and making recommendations to affect its regulation? recently provinces have begun to operate
policymakers, the gambling industry, third 2.2 Which charities and community projects is bingos, sometimes leading to disputes with
sector stakeholders, and academics. Key bingo money used to fund? What charities over bingo revenues. The right to
questions included: relationship do those projects have to autonomously operate and regulate bingo has
1.1 How, and to what end, is bingo regulated bingo players? also been an important legal issue in some
in each jurisdiction? What is the role of 2.3 What strategies, if any, are being First Nations communities. In Canada and the
charity, criminal, and commercial law? undertaken by policymakers to support USA attempts by First Nations/Native American
Where is enforcement power located, in bingo, and how do these strategies groups to operate and regulate bingo have a
law and practice? position the players? Is the current long connection with struggles for control over
1.2 Are laws governing bingo being relaxed demographic breakdown of the players economic development and cultural life on
as part of trends towards global gambling perceived to be an obstacle to the reservation territories. Although many
liberalisation, or is the game being development of the industry, an researchers have explored ‘tribal gaming’
subjected to increasing regulation? Is play advantage, or something else? debates, they typically do so from the
being standardised, converging towards a 2. 4 What does the regulation of bingo in perspective of casinos rather than bingo.10
global norm? different contexts tell us about how
We chose Ontario and BC as sites for in-depth
1.3 Which rules are most important to various governments perceive the role of profit-
exploration of these dynamics because they
stakeholders, and why? Which are making within broader community welfare
are both crucial provinces in the history of
ignored, and why? Whose priorities projects?
bingo in Canada. Ontario is the biggest market,
appear to be reflected in new legislation and BC was the site for lengthy legal struggles
and case law? Our case studies around charitable and provincial involvement in
1.4 What are the key regulatory challenges bingo in the 1990s and 2000s. Kate had
To answer these questions we undertook four in-
and disputes about? How do various previously done small scale pilot studies
depth case studies of bingo regulation, each the
actors understand those challenges, and looking at bingo regulation in Alberta, and
subject of a chapter in this report.
seek to resolve them? Ontario.
1.5 How, if at all, are responsible gambling 1 Brazil: Until 1993, bingo was included within 3 England and Wales (land-based). In England
concerns evident in relation to bingo Brazil’s 50 year old prohibition against non- and Wales bingo occurs in range of venues,
regulation? state suppliers of popular gambling from commercially-run bingo halls, holiday
1.6 What similarities and differences emerge experiences and products. In 1993 the federal parks, and amusement arcades, to non-
between and within cases, regarding the government exempted bingo from prohibition, commercial members’ clubs and miners’
regulatory principles; the key to provide an income-generating opportunity welfare institutes and churches. Operators
stakeholders; the challenges; etc, and for sports organisations. However the new have been grappling with declining
what do these add to current knowledge? Brazilian bingo industry and its regulators were attendance, especially since the smoking ban
repeatedly ensnared in corruption, organised in 2007. Resulting innovations in where, and
crime, and money laundering scandals. Just how, the game can be played have prompted
seven years after opening the licensed bingo interesting regulatory debates about what
market the federal government attempted to defines bingo. We chose four regions for in-
close it. By 2007 prohibition had been, in depth exploration of these dynamics: South
effect, reinstated as Brazil’s regulatory Wales, North East England (Newcastle and
instrument for governing bingo, and the game around); the seaside North West of England
had been driven largely underground. Our (Blackpool and around); and Greater London.
case study aims to learn the lessons from that Kate had previously done a pilot project looking
period. It tries understand why bingo – a game at bingo regulation in seaside towns in Kent.
8 Regulation and Risk: Occupational Health and Safety on the Railways. (Oxford University Press, Oxford 2001, p 4).
9 See for example Adam Crawford. 2009. Governing Through Anti-Social Behaviour: Regulatory Challenges to Criminal Justice. British Journal of Criminology. 49 (6): 810-831.
10 See for example Belanger, Y. (ed.). 2011. First Nations Gaming in Canada. Winnipeg: University of Manitoba Press.
8 The Bingo Project

4 On-line bingo in the European Union (EU) state-approved monopoly providers, or

Why only England and Wales? Online bingo is not equally popular across all charities have also been examined in the light
A case study of UK bingo regulation would of the EU’s 28 Member States, but in some – of EU and national level regulation, again bingo
be, in our view, unwise, because Northern such as the UK, Spain, Italy, Denmark, Portugal has largely been kept out of the research and
Ireland’s gambling law is very distinct from and Sweden – it is a significant sector. In such policy spotlight.12
the rest of the country and needs in-depth places, EU-level and national-level laws on
exploration in its own right. In Scotland, local gambling interact. The European Commission These four case studies were selected to give us
level licensing procedures for gambling decided in 1992 that it would not seek to a good overview of the diverse ways in which
premises are different to those in England submit formal proposals for harmonised bingo is played (online versus land-based; in
and Wales. Since local licensing was a key gambling rules, leaving EU Member States with commercial halls versus in charitable facilities),
aspect of our research we wished to hold considerable discretion over regulating online and of legal approaches (criminal prohibition,
that element of this case study steady to gambling. However many pieces of EU licensing as charitable activity; licensing as
legislation impact on online gambling. These commercial activity; etc).
allow for valid comparisons between regions
include measures to regulate misleading and
that are covered by the same rules and A key priority of the project was to explore the
aggressive marketing practices, money
procedures. However some commercial diverse laws, policies, and practices that govern
laundering, online dispute resolution, the
bingo operators that we interviewed in bingo. Hence we explored ‘high’ politics and law,
fairness of consumer contracts, and data
England and Wales also operate in Scotland. protection. Furthermore, the Court of Justice of as expressed in legislation, official records of
We also reviewed Scottish cases in our the European Union has held that the provision political debate, and recorded court cases. We
analysis of case law on bingo. As a result we of online gambling services falls within the also collected and analysed codes of practice,
hope that the research has some scope of EU rules relating to the free annual reports from regulators, and high-level
applicability there. movement of services and the freedom of national reports in which bingo was examined.
establishment. Previous research and policy If relevant we explored lower-level political
debates have largely explored the impact of debate and regulations, such as those crafted
EU law in relation to sports betting, slot by municipal governments, along with licensing
machines, casino games or online gambling in guidelines, inspections check lists, and
general.11 While lotteries operated by states, compliance forms.
THE 10 COMMANDMENTS OF BINGO

1 Thou shall not sit in thy neighbours lucky seat.
2 Thou shall not stare at thy neighbours card.
3 Thou shall not take the Callers name in vain.
4 Thou shall not call false “Bingo”.
5 Thou shall not wish bad luck on thy neighbour.
6 Thou shall not harass or threaten to kill ‘the “Caller”.
7 Thou shall not steal thy husband’s money for Bingo.
8 Thou shall not brag about how much thou hast won.
9 Thou shall not whine about how much thou hast lost.
10 Thou shall not covet thy neighbours winnings.
A bingo acquaintance met during fieldwork in A list of ‘bingo commandments’ on a pinboard at a community centre for elderly people in British Columbia, Canada,
Canada, 2015. positioned next to the official ‘rules of play’ that are required to be displayed by provincial regulations.
11 See eg D. Doukas and J Anderson. 2014. ‘Commercial Gambling without Frontiers: When the ECJ Throws, the Dice is Loaded’ 27 Yearbook of European law (2008) 237-276;
S. Planzer. 2014. Empirical views on European Gambling Law and Addiction (Springer)
12 See eg S. Kingma and T. van Lier. 2006. The Leeway of lotteries in the European Union: A Pilot Study on the Liberalisation of Gambling Markets in the EU (Dutch University Press).
Because our research was interested in the rules Our findings and this report This report is a key part of our on-going work to
‘on the ground’ as well as those ‘on the books’, share our results with gambling experts who are
We are using many outlets to share our
we also sought to understand how different not academics. It is intended both for those who
research findings, including our website
groups of people experienced the regulations. have an interest in bingo already and want to
(www.kent.ac.uk/thebingoproject/), our twitter
Hence in each case study we conducted semi- know more about its regulation in different places,
feed (@bingo_project), our presentations at
structured interviews with representatives from and those who work in related gambling fields
conferences, our academic and non-academic
key groups involved in debates about bingo and want to know what our research on bingo
publications, and our involvement in initiatives that
regulation. The interviews were anonymous and can add to their existing perspectives. It is
seek to draw together different stakeholders in
confidential. In total we conducted 217 such focused more explicitly on the first objective (the
bingo. For example in October 2015 we hosted a
interviews, with 255 respondents. systematic account of how bingo is regulated)
public debate on the key challenges and future
than the second (the re-framing of academic
Finally, in the three case studies where bingo can directions in bingo regulation in England and
debates about the governance of risk and
currently be lawfully played we participated in Wales, involving representatives from the national
speculation). However in the chapters
games in order to learn more about how rules gambling regulator, local government, the
summarising the four case studies we have
and regulations were applied in practice, and to Working Men's Club and Institute Union,
selected some ‘key themes’ that, we hope, show
talk informally with staff and players. We funded commercial bingo operators, and academic
what can be learned more broadly from bingo.
this ourselves: at no point was any ESRC money researchers. In May 2016 the Brazil research
These cover topics such as the impact of
used for gambling. team gave presentations on their findings to a
prohibition on players and operators; the shift
conference of Brazilian consumer law experts,
over time in political attitudes to bingo; the
More information on our research methods, the and to the 2nd Brazilian Gaming Congress
regulation of game definition; the use of
data we collected, and our approach to analysis attended by gambling industry specialists from
proceeds by charitable bingo providers; and the
is contained in appendix 1. around the world. They presented three papers,
social nature of online bingo play. Each case
including “Bingos no Brasil: fardo ou
study chapter also contains substantive
legado? Reflexões críticas e contribuições para a
recommendations, drawn from the research, for
regulação dos jogos na atualidade” (Bingos in
those involved in bingo regulation. These range
Brazil: burden or legacy? Critical reflections and
from a set of recommendations about legalising
contributions to the regulation of contemporary
bingo in Brazil, to a suggestion that the focus of
gaming”), and “Responsible Gambling in Brazil:
European Union level discussions on consumer
Lessons from the Bingo project”.
Professor Toni Williams, presenting the Bingo Project's Findings to Brazilian consumer law specialists.
10 The Bingo Project

protection in online gambling be expanded Acknowledgments The Project also benefited greatly from the
beyond problem gambling, underage gambling, support of an international advisory group of
The Bingo Project was a collaborative initiative,
and responsible gambling to also encompass the experts. Chaired by Professor Gerda Reith (a
involving a team of researchers: Kate Bedford
regulation of substantive fairness. gambling researcher based in Glasgow), this
(Principal Investigator), Oscar Alvarez-Macotela,
included experts drawn from the commercial
In each case study chapter we have also Donal Casey, Maria Luiza Kurban Jobim, and Toni
bingo industry, government, legal practice, and
included a table of the most important legal Williams. You can find out more about us and our
academic life. All of our 16 members served
cases on bingo. These are not intended to give research interests at the end of this report.
voluntarily, and some had to take holiday from
technical legal summaries of the cases for use their paid work to attend our meetings. Some also
We would like to thank the ESRC for funding the
by lawyers. Rather they aim to explain the basic had to travel considerable distances. We have
research, and Kent Law School for facilitating our
background of the issue, and the decision, in relied on them especially extensively for guidance
fieldwork and writing up time. In particular, Sarah
terms that a non-lawyer interested in bingo, or on data collection, and for feedback on research
Slowe, Sarah Gilkes, and Cathy Norman (the
gambling in general, can understand. In each plans and preliminary findings. We could not have
research administration team), Mark Dean (IT
chapter we selected the cases that were key to completed the project without their help, and we
specialist), Andrea Shieber (communications
the development of bingo in that jurisdiction, and thank them sincerely for their generous support
specialist), and Jill Holiday (the school’s
that illuminate some of the core themes in our over the last three years. You can find out more
administration manager) supported us with
report. They shed light on how courts in different the members of the advisory group at the end of
unfailing good humour. Our project was a
places have handled disputes over which level of this report.
challenge in terms of technology and
government has authority over bingo; how bingo
administrative arrangements. They kept us on
proceeds should be used; how the game’s Finally, we wish to thank the people who agreed
the road, and in front of functioning software,
boundaries should be defined; and how far to speak with us and share their insights into
so that we could do our work.
licensing discretion should extend. bingo. In the course of our travels we have met
Linda Pitt has been transcribing our English- hundreds of people involved in the sector in
In the concluding chapter we develop some over- various ways. They generously shared their time
language interviews on bingo since the first pilot
arching lessons, using our research from across and perspectives, and in doing so they helped us
project in 2010. She has overcome every auditory
the four case studies. In particular, we highlight make the case that bingo was worth taking
hurdle she has so far encountered, including
the following key points. seriously in terms of research. The analysis and
those caused by our habit of recording during
live bingo games. Joao Araujo Monteiro Neto recommendations we provide in this report are
1 The value of expanding the concept of ours, but we have striven to include as many of
‘responsible gambling’ to better reflect fairness transcribed our Brazilian interviews, and did an
excellent job of translating our website into their voices as we were able. Indeed they are the
for players and workers. reason why this report is 80 pages (rather than
2 The need for context-specific consideration of Portuguese.
50 as was planned four years ago when we
whether non-commercial actors should be submitted out research grant). Luckily for us,
privileged as bingo operators by regulators, people had a lot to say about bingo regulation!
taking into account how such actors use
proceeds, how they are connected to players Kate, Oscar, Donal, Luiza, and Toni.
as donors, and how they mobilise volunteers.
3 The need for rules that reflect the
distinctiveness of bingo as a game, and a
playing environment.
4 A potential role for gambling regulators in
supporting and preserving everyday,
vernacular forms of play like bingo.
5 The need to better support international
collaborations across local governments that
license low-level forms of gambling such as
bingos.
6 The uneven effects of the female-dominated
nature of bingo on its regulation.
Kate Bedford (Bingo Project), Miles Baron (Bingo Association), and Gerda Reith (University of Glasgow),
presenting at the Public Debate on Bingo, October 2015.
CHAPTER 1: THE REGULATION

OF BINGO IN BRAZIL
Figure 1: Regional distribution of bingos in

Brazil, 2005.
Overview of the case
Until 1993, bingo was included within Brazil’s 50-year-old prohibition against non-state
suppliers of popular gambling experiences and products. Prohibition had been established
during the 1940s under two Criminal Contravention Acts that consolidated piecemeal bans on
specific games into a default rule of illegality for all forms of gambling that were not specifically
exempted. This stance was in part justified by lawmakers as being in accordance with
widespread anti-gambling values in the international arena. Bingo was played on a small scale
by religious organisations for fundraising purposes in some parts of Brazil, but these activities –
although widely tolerated – do not appear to have been subjected to formal state oversight.
However, in 1993 Brazil exempted bingo from prohibition. The federal government created the
exemption to raise funds for the democratisation of sports, an obligation that the Brazilian state
had assumed under the 1988 post-dictatorship constitution. The legalisation of bingo was
intended to provide an income-generating opportunity for sports organisations. Lacking the
required expertise and investment capacity, however, such organisations partnered with
commercial operators. Large and profitable bingo halls were established in many cities,
particularly in Brazil’s prosperous South and South East regions. Bingo businesses grew
rapidly, creating lots of jobs and generating sustained revenue streams for municipal, state, and
federal governments. But the Brazilian bingo industry and its regulators also were repeatedly
ensnared in corruption, organised crime, and money laundering scandals. Just seven years
Source: data reported in the CPI dos Bingos
after opening the licensed bingo market the federal government attempted to close it. Closure
2006, p.112-3.
was resisted through political processes, legal actions and defiance – unlicensed bingo is
played illegally to this day – but by 2007 prohibition had been, in effect, reinstated as Brazil’s
regulatory instrument for governing bingo, and the game had been driven largely underground.
It is important to learn the lessons from that failure, to understand why bingo – a game that in
Brazil (as elsewhere) evokes family holidays, charitable fundraising and older women’s sociality
– acquired such menacing connotations during its brief period of commercialisation.
To understand the rise and fall of licensed bingo in Brazil this case study examined the
regulatory systems, processes and requirements established to govern the game. We also
interviewed 24 key informants with relevant experience of the game and its regulation. We did
not directly observe or participate in any games because bingo halls were unlawful at the time
of the study. However, we sought to access the experience of bingo play as reported by key
informants and through media accounts and contemporaneous reports.
Scale, distribution, and demographics A more comprehensive survey, conducted by the

of play Parliamentary Commission of Inquiry on Bingos
in 2005 (after the ostensible closure of the
Licensed bingo businesses were established in
market), identified 1547 operating bingos and
every one of Brazil’s 27 states during the
confirmed the pattern of uneven development.
legalisation era but their distribution across the
Just 3 percent of bingo businesses were located
country was highly uneven. Half (468) of the 924
in the North while the rich South and South East
bingo businesses known to the federal licensing
regions together hosted 80 percent of the sector.
authority, the Caixa Econômica Federal (CAIXA)
Rio Grande do Sul’s 224 businesses gave it the
in the early 2000s were located in São Paulo,
same 15 percent market share in this larger
Brazil’s most populous and richest state, and
sample as in the CAIXA data. São Paulo state, by
another 15 percent (140 businesses) were
contrast, was less dominant in this study, with its
located in Rio Grande do Sul, Brazil’s fourth
595 bingos amounting to about 40 percent of the
richest state. No other state hosted more than
total number. This difference reflects the extent to
7 percent of the total licensed businesses, and
which the later study found
seven states clustered in the North (Brazil’s
a higher proportion of bingo businesses in other
poorest region) together hosted only 2 percent
states in the South and South East.
of all licensed bingo businesses.1
1 Comissão Parlamentar de Inquérito (CPI dos Bingos), created according to Requerimento 245/2004, Senado Federal,
2006, Relatório Final, Brasília, DF, available at: www.senado.gov.br/comissoes/CPI/Bingos/RelFinalBingos.pdf

OF BINGO IN BRAZIL
Generally, licensed bingo halls were large, well- Current regulation of bingo in Brazil and employee taxes. However the Decreto made
staffed establishments, with the capacity to seat no provision to finance the states that, until 1998,
Bingo was exempted from Brazil’s criminal
hundreds of players. Many offered electronic formally had primary responsibility to regulate
prohibition against gambling under Article 57 of
games as well as card-based play. One player bingo. Those states that did regulate bingo had
Lei “Zico” (Lei nº 8.672/93) – a law named after
recalled “a huge bingo on two floors. It gave us the capacity to levy taxes for regulatory services.
a popular former footballer who subsequently
dinner, afternoon coffee… everything. … One The result was variation across the country in the
became the federal government’s minister for
floor was only slot machines, another floor was funding of regulators as well as in their regulatory
sports. Lei Zico was primarily concerned with the
only card bingo” (Female, Player, Rio Grande do practices.
democratisation and financing of sport, not with
We can differentiate between states where there
Sul). Some 15 percent of Brazilians played the
gambling.
were state lotteries and the others. The state
game, about a quarter of the number who play
lotteries embraced the cause of bingo. They had

the lottery (CPI dos Bingos 2006, p.121). Players
the attitude, so here’s the bingo game, we’ll take

were an eclectic, albeit class-stratified, The rationale for legalisation
care of anything about the game, we’re going to

population, according to the CPI dos Bingos. Art. 57: Sports clubs and Olympic sports
regulate the game here…. In Rio Grande do Sul
Their experience of the play would to a significant federations able to demonstrate active
the ‘bingueiros’ were happy. There it was the
extent depend on their class, gender and age: participation in Olympic sports may be
Bingo customers vary according to the location, LOTERGS [the lottery of the State of Rio Grande
authorised by the Treasuries of their
size and the types of play offered. Seniors are do Sul], that would take care [of regulation], while
respective states to hold events intended to
faithful customers of these establishments. here in São Paulo the LOTESP [lottery of the state
raise money for sports development by
However, this was more obvious at card-based of São Paulo] just existed on paper drawn up by
means of sweepstakes called Bingo, or
bingos. The majority of those playing electronic the Secretary of the Treasury… It never worked…
similar.
bingo are aged between 30 and 50 years old. Here in São Paulo the state put two retired ladies
[Lei Zico] creates conditions for the
Card and electronic bingos also attract different in charge of regulation without an adequate
beginning of a new era of sport, with an
clienteles with men more frequently opting for regulatory infrastructure. They would receive
enhanced role for the private sector and the
electronic machines and women for card-based applications for authorisation and process them
reduction of state interference in sporting
games. (CPI dos Bingos 2006, p.121) by the deadline but they would never monitor
activities … with the goal of implementing a
them as required by the law. Entrepreneurs soon
sporting democracy. (Dossiê Lei Zico,
realised that what they did would not be
p.260).
monitored and that’s what started the fragile
[Lei Zico aims to] (a) expel from sporting
relationship between bingos and the public
Although the game is no longer licensed, bingo
legislation any authoritarian philosophy,
authorities.” (Male, former bingo owner, São
is still played in Brazil. Portuguese language
which is disciplinary, controlling,
Paulo emphasis added).
websites hosted outside the country target
centralised, restrictive, elitist and protective
Brazilians for online play; sporadic land-based
of personal and group interests; … and (c)
bingo games are held to raise money for
enact, in the sports field, the predominance Brazil experimented with different systems for
charitable purposes; and according to the
of a ‘destatisation’ philosophy … eliminating allocating regulatory licensing and supervisory
Instituto Jogo Legal, an industry think-tank,
state interference in the internal business of powers during the legal bingo era. However, it
some 463 criminal actions were taken against
sport clubs (Dossiê Lei Zico, p.392) never settled on a model that could maintain
clandestine establishments and players in 2013.
public confidence in the resilience of the bingo
market against corruption and criminality. Initially
Substantive rules on bingo governance and regulatory authority over bingo businesses,
regulation, first enacted in November 1993, including licensing authority, was dispersed to
defined bingo as a lottery played as a 90 number State Treasury departments, except in the state of
game, and set out detailed accreditation Rio de Janeiro which gave the responsibility to its
requirements for marketing and supplying the well-established state lottery agency (LOTERJ). In
game (Decreto nº 2.573/98 Art.74). These rules 1998, in the wake of corruption scandals in five
covered the minimum occupancy standards for states with significant commercial bingo markets,
bingo halls, accreditation of sports bodies to the federal government enacted Lei Pelé (Lei nº
enter the bingo market, renewable licensing of 9.615/98), which transferred regulatory authority,
permanent bingo businesses as well as event- including licensing, to a federal organisation, the
based authorisation of occasional bingos, returns Instituto Nacional do Desenvolvimento do
to players and remittance of revenue from entry Desporto (National Institute for the Development
fees for sports development and to finance the of Sports – INDESP). INDESP was a small
regulator, reporting and accountability agency that never developed the capacity to
requirements, and extensive certification of regulate the bingo industry effectively. It therefore
equipment, premises, the licensee’s financial contracted with larger states that had the most
standing, and security and labour and consumer active bingo industries – 13 out of 27 states – to
practices. Municipalities were authorised to tax continue the regulatory arrangements that they
bingo businesses as local services and the had created under Lei Zico.
Sign advertising a church bingo on the highway linking federal government drew revenues from business
Porto Alegre, the capital of Rio Grande do Sul, to the
coast, 11/04/2016. Taken by Maria Luiza Kurban Jobim.
A third model gradually emerged after 2000, the A conjuncture of three key events during 2006-7
year in which the federal government first tried finally brought about closure of Brazil’s formal Organised crime and corruption in Brazilian
closing the bingo market. It took this initiative in bingo market: bingo: Findings from the Parliamentary
the wake of a corruption scandal involving its Commission of Inquiry (2006)
regulator, INDESP. Lei Maguito (Lei nº 9.981/2000) • A special investigation by the Federal Police Organised crime and gambling are
withdrew INDESP's authority to grant new bingo and Prosecution Services (Operation “conjoined twins”. There is strong evidence
licences, put existing bingo halls on notice that Hurricane) confirmed corrupt practices in worldwide that casinos and similar
their annual licences would not be renewed upon some courts that had been extending bingo businesses mask the real, illegal business
expiry, and transferred responsibility for licensing, licences through judicial order, undermining that actually control them.
supervision and compliance (until the licences public confidence in the integrity of courts.
expired) from INDESP to the CAIXA, which ran • Brazil’s Constitutional Supreme Court affirmed Since the beginning of their activities in
the successful federal lotteries. This attempted the federal government’s exclusive control over 1993, the bingo halls have rendered a
closure of the market was contested at the state gambling regulation.4 This ruling established disservice to the nation… [S]ome of these
level through measures to maintain state authority that Brazil’s state governments lacked the entities have been used to launder money
over the bingo market. Some state courts were competence or power to enact legislation to coming from illegal activities.
willing to issue judicial orders extending expired permit bingo businesses to operate.
bingo authorisations.2 • A Parliamentary Commission of Inquiry (the As stakeholders bingo has – sometimes
CPI dos Bingos) reported that businesses hidden – individuals notably related to
Another attempt to close the market in 2004 representing the interests of organised crime – crimes and misdemeanours, who
(Medida Provisória nº 168/2004), this time through both domestic and international – had captured sometimes represent the interests of an
a Presidential decree issued in the wake of a much of the Brazilian bingo market. The report international organised mafia (CPI dos
major corruption scandal centred on campaign found that criminals were using bingo halls to Bingos 2006 pp.7-8)
financing payments to the governing Partido dos launder money and that proceeds were
Trabalhadores (PT), also failed. Courts in some The weak regulatory structure governing
diverted to corrupt government officials, from
states, notably São Paulo and Rio Grande do Sul, bingo in Brazil allowed the sector to be
federal to municipal levels (CPI dos Bingos,
continued well-established practices of issuing exploited for other purposes. Proceeds
pp. 12, 134, 122-149).
discretionary injunctions to extend bingo were used to finance and corrupt election
authorisations3. There was little consistency in the campaigns and to help launder money from
Despite finding that the enabling regulation
exercise of this judicial power, however, so it was crimes (CPI dos Bingos 2006, p.455).
enacted during the 1990s had not adequately
difficult for business owners, players, regulators protected legitimate bingo businesses and
and enforcement authorities to understand what Brazilian public administration against the
was legally and constitutionally acceptable. activities of criminal organisations, the Inquiry
Moreover, the lucrative nature of the businesses recommended re-opening the bingo market with
affected and the substantial losses occasioned stronger and more effective regulation. Several
by closure aroused suspicion that courts – as well legalisation bills have been proposed since 2007,
as political processes and the executive – were and in 2015 two Special Parliamentary
being corrupted to secure the continuation of the Commissions were created to work on reform.
bingo industry. However, no measures have as yet come through
There were judges who allowed Bingo Halls to

the legislative process successfully.
operate normally….And there was speculation

that these injunctions would cost R$1 million, 2
millions, 5 millions. …[T]he ones who got these
decisions felt like they had won the lottery. When
these suspicious about “judicial decisions’ for sale”
were strengthened by Operation Hurricane, the
Supreme Court had to act in order to bring
judicial uniformity. (Male, politician, Rio Grande
do Sul)
2 Agravo de Instrumento Nº 70005784434, Primeira Câmara Especial Cível, Tribunal de Justiça do RS, Relator: Angelo Maraninchi Giannakos, Julgado em
28/04/2003.
3 Mandado de Segurança Nº 4730320000 Relator(a): Linneu Rodrigues de Carvalho S; Comarca: Poá; Órgão julgador: 7º Câmara; Data do julgamento: 27/05/2004;
Data de registro: 16/06/2004); Mandado de Segurança Nº 70005921507, Quarta Câmara Cível, Tribunal de Justiça do RS, Relator: Araken de Assis, Julgado em
28/05/2003)
4 See Supremo Tribunal Federal, Sumula Vinculante nº 2 DJe nº 31 de 06/06/2007, p. 1. DJ de 06/06/2007, p. 1. DOU de 06/06/2007, p. 1.

OF BINGO IN BRAZIL
Key themes By contrast the regulatory framework developed operators willing to invest in bingo. In turn this
in a slow, piecemeal fashion. It relied from the demand for capital created significant new
1 A lack of systematic attention to
outset on heroic, unrealistic assumptions about opportunities for owners of jogo do bicho
regulatory objectives, instruments, and
the ability of sports organisations to diversify into franchises to diversify, to deploy their expertise in
processes contributed to the failure of
Brazil’s bingo market and damaged public the provision of gambling services such as bingo, developing the bingo market and to launder
confidence and about the capacity of new and inexperienced proceeds from their other illicit businesses.
“For more than 51% of the people, bingos are
institutions to regulate the country’s only formal
related to criminal practices such as money
market for non-state provision of mass-market Likewise, suitability tests were applied as part of
laundering, tax evasion, and increasing violence.

gambling. the accreditation process for sports organisations
To 43%, the bingo halls have no positive features.”

that fronted bingo businesses on the basis that
(CPI dos Bingos 2006, p.120)

Three specific features of the regulatory regime they were ultimately responsible for the
combined to undermine public confidence in the commercial investors and operators who ran the
licensed bingo market. First, the legalisation of bingos. The purpose of the regulation may have
Brazil’s bingo exemption was a side effect of the
bingo as the only mass-participation game been to ensure that persons responsible for
democratisation of sports administration rather
provided by non-state actors made the game bingos were honest and reputable. It is unclear,
than the result of a carefully considered policy
attractive to criminal organisations that owned however, that the suitability certifications required,
decision to open up a legal gambling market. This
and operated the country’s popular illegal which focused on the identity of the licensee, its
inauspicious beginning meant that the regulatory
numbers game, the jogo do bicho. If markets for status as a registered business in the formal
framework for the game lacked a robust
products such as casinos had been opened up economy and good standing with various public
articulation of objectives, instruments, and
at the same time then bingo may have been authorities, provided useful information to
methods. One informant told us that the idea of
sheltered from the pressure to develop quasi- regulators or players about a bingo provider’s
legalising bingo in Brazil had stemmed from news
casino spaces and thus been less vulnerable to suitability, probity, integrity, or market conduct.
of the UK bingo sector’s sponsorship of elite
capture by bicheiros, the entrepreneurs of the Requirements that do not respond effectively to
sports, with little consideration of how it could
jogo do bicho franchises. risks potentially undermine rather than strengthen
be transplanted to the Brazilian context.
public confidence because they suggest that
“A working group was established to evaluate how the regulator is unable to carry out its basic
to bring resources to [sports development], and
“There was a problem once the bicheiro responsibility of controlling entry to the market.
someone said we will do bingo because bingo was
entered the bingo business to launder
The system they approved was not a good fit for
reputed to be strong sponsor of competitive sailing
money. I am against bingo regulation
the plan because there were so many certification
in England. The model was imported without
without a serious oversight” (Male, former
requirements … I wanted to set up a bingo with
consultation. No one had operated bingo or had
bingo owner, Rio Grande do Sul).
Corinthians [a large São Paulo sports club known
any previous experience of this model in Brazil. It
for its football team] but it is so big that no one
simply did not exist here. Then along came the
“We've always had clandestine casinos and
could afford to obtain all of the required
legislator with Lei Zico and the model was
when the bingos were legalised, many of
certificates and pay any outstanding tax
approved.” (Male, former bingo owner, São
these people from clandestine casinos
liabilities. But I could pay for the certification
Paulo).
migrated to bingo. (Male, former treatment
provider, Rio Grande do Sul). and the unpaid taxes of [a small Brazilian sports
federation] because it had just two or three
employees and a president. So after I paid for the
Nonetheless, a bingo industry developed swiftly
certificate and the back taxes I was able to develop

and the game grew, particularly in Brazil’s
a bingo on behalf of this small sports federation.

prosperous South and South East. Secondly, the misdirected focus of the licensing
And this is what happened all the time. Licences

standards contributed to a loss of public
were obtained in partnership with small sports

confidence in the licensed bingo market. The
rather than the big sports clubs that the

“Within four months, seven bingo halls scale of the certification requirements tended to
legislators had envisaged. (São Paulo, male,

began to work regularly in Porto Alegre have the unintended and perverse effect of
former bingo owner).

center, there are another 10 applications for precluding entry into the market of the very
authorisation for establishments of this kind providers that the regulation had been intended
in the capital and many plans for the interior. to promote, and which the public might have
“It became a craze,” says Rildo Machado considered more resilient against the risk of Thirdly, under-investment in effective regulatory
da Silva, Bingo Beach Street supervisor. capture by organised crime. Businesses were set structures contributed to lack of confidence in the
“Competition is getting stronger.” Zero Hora up in large spaces to meet the equipment and system’s capacity to keep the bingo market free
12 November 1994. minimum occupancy standards enshrined in the of crime. This weakness is linked to the problems
regulations. Such investment was beyond the of multi-level regulation that bedevilled the era of
capacity of the sports organisations that entered lawful bingo. State and federal institutions
the bingo business to generate income for sports competed with each other instead of working
development. Those organisations that wished to collaboratively to regulate the bingo market, and
take advantage of the opportunity opened up by municipalities which had regulatory powers to
Lei Zico therefore had to partner with commercial approve bingo locations5 do not appear to have
5 Lei Pelé Decreto Regulamentador 2.574/98. In addition the state of Rio de Janeiro allowed the bingo regulator to authorise municipalities to offer bingos to raise revenues under
Art. 14 of Decreto Estadual nº 25.723/1999.
Bingo Imperatriz in São Paulo, taken from p.1250 of the

CPI dos Bingos, 2006.
Image of an authorisation issued by the CAIXA authorising the Gaucha Table Tennis federation to run a bingo in Bingo Pamplona in São Paulo, taken from pp.1254 of
collaboration with a private operator. Source: Apelação Cível Nº 70006541205, Quarta Câmara Cível, Tribunal de the CPI dos Bingos, 2006.
Justiça do RS, Relator: João Carlos Branco Cardoso, Julgado em 11/07/2007.
featured prominently in policy discussions – levels of government, and the variation across the
although we have found some cases on the country, made it difficult for people to know which
exercise of these municipal powers.6 Tensions agency was responsible for the bingo market.
“The [regulator] INDESP was a tiny organisation

between federal and state level regulation came
– 50 or 60 employees to take care of all bingos in
to a head at the end of the 1990s after INDESP, as
Brazil. Of course it did not.” (Male, former Bingo
the national regulator, issued orders claiming for
owner, São Paulo).
itself the exclusive competence to regulate the
lucrative electronic bingo market across the
country including in states that already had made
These three factors – failure to consider the
provision for state level regulation.7 INDESP was
impact of partial legalisation in the light of Brazil’s
subsequently exposed as having been corrupted
existing gambling environment; poorly designed
to support expansion of electronic gaming in
standards that created perverse incentives; and
bingo halls8. Most of its regulatory functions were
under-investment in regulation – combined to
then transferred to the CAIXA, the federal bank
reduce public confidence in the integrity of bingo
responsible for lotteries, which simply ignored the
operations and the capacity of Brazilian
arrangements established in larger states for
regulators to control the market.
regulating bingo. In 2001 INDESP was completely
closed down.9 The frequent changes in the
location of regulatory authority between different
6 eg Agravo de Instrumento Nº 70005784434, Primeira Câmara Especial Cível, Tribunal de Justiça do RS, Relator: Angelo Maraninchi Giannakos, Julgado em 28/04/2003;
Agravo de Instrumento Nº 70006051601, Vigésima Primeira Câmara Cível, Tribunal de Justiça do RS, Relator: Genaro José Baroni Borges, Julgado em 03/09/2003; Agravo
de Instrumento Nº 70006521009, Quarta Câmara Cível, Tribunal de Justiça do RS, Relator: Wellington Pacheco Barros, Julgado em 08/10/2003.
7 Portaria INDESP n. 104/98; Portaria INDESP n. 23/99.
8 Boudens, E. 2000. Bingo: usos e abusos. Consultoria Legislativa. Câmara dos Deputados. Centro de Documentação e Informação. Coordenação de Públicações. Brasília.
9 Medida Provisoria n. 2216-37/2001

OF BINGO IN BRAZIL
2 Changing bingo environments in Brazil: machines and slot machines were central. Many Some bingo halls catered to a range of players,
From diversity to clandestine, decapitalised blame the problems associated with the bingo using time as the basis for dividing up the use of
uniformity industry on the spread of machines. space. One former São Paulo bingo owner told us
Licensed bingos were diverse. Some bingo that he had organised his business to attract
businesses targeted the mass market, charging elderly people looking to socialise with friends
low prices, outfitting their interiors simply, and Slot machines in bingo halls: Some views during the daytime, and local workers wanting to
opening in locations such as shopping malls from interviewees avoid the city’s notorious traffic congestion in the
that were already heavily used by the public. “Typical players were the archetypal middle early evening. Later at night the bingo catered to
aged couple who didn’t want to do anything business people or couples looking to extend
“Central Bingo with its plastic tables and chairs wrong. After legalisation of bingo they their evening after dinner. Finally, during the early
and reusable cards mostly attracts the lower began to play the little machines.” (Male, hours of the morning he targeted night workers
and middle classes… the public who really former problem treatment provider, Rio such as security guards, and restaurant and bar
understands bingo” (female bingo manager Grande do Sul) managers who needed time to chill out after their
quoted in Zero Hora November 12, 1998, p.5). shifts.
“What I like most is the slot machine, but
“Our clients are ordinary people”, said the owner when bingo started in Porto Alegre there
of the Royal Bingo, which recently opened with its
Since the end of the legalisation period it is the
were no slot machines. I started with card
plain fittings and the lowest prices in the city.
smaller, less glamorous, and less visible spaces
bingo, then they brought in the slot
(Zero Hora November 12, 1998 p.5).
that have survived as clandestine bingos. In
machines based on the bingo cards. When particular, our research shows that
they legalised they started slowly bringing impoverishment of the bingo hall environment,
Other bingo businesses targeted affluent men the slot machines into the bingo halls. Then through confiscation of fixtures and fittings, has
as their customers, marketing bingo as a they started to make lots of money with slot been used as a deliberate law enforcement
sophisticated leisure option and the bingo hall as machines and began to expand, began to strategy.
a conducive environment for both relaxation and make rooms only for slot machines and to
“At one point we had about ten illegal bingo halls
business networking. These places benefited expand the space for them.” (Female,
that were working simultaneously in Porto Alegre.
from considerable investments in playing player, Rio Grande do Sul)
environments that conveyed opulence, glamour, So I went there and closed them and the next day
they were open again. I tried as a strategy to seek
“Slot machines are very harmful. Card-
luxury and excess.
to “de-capitalise” these offenders, seizing all the
based bingo I think is social. If the person is
“Bingo X was famous for being one of the most
material that would include all the furniture, ie
with others it is not harmful. But the slot
luxurious places in the city ... the first time I went
tables, chairs, everything that they used to operate
machine, it is individual, it individualises
it was a beautiful place with lovely chairs and
the bingo. We sometimes took 300 or 400 chairs,
you, and, it’s you against the machine, and
tables made of marble.” (Male, Public Official,
armchairs, tables. Even doing this, some bingos
you want to challenge it… You know the
Rio Grande do Sul)
were still very fast to reopen the establishment,
hours pass quickly. It’s all hallucinogen,
which shows that they really had a lot of capital

those numbers, those challenges. My
“There are some very sumptuous establishments,
to finance the reopening of these locations.” (Male,
husband had no idea about the extent of
such as the Emperor and Empress Bingos, located
Public Prosecutor, Rio Grande do Sul).
my compulsion. Then he started watching
in the city of São Paulo. The magnificence of these me. He would call at a certain time and ask
bingos is evident from the outside. Their luxurious what are you doing? I would tell him I am in
interiors are designed to impress”. (CPI dos the store. It was such a lie… I was at bingo.” Confiscation of the fittings of an illegal bingo hall
Bingos p.116). (Female, service provider and former player, did not necessarily prevent the business from
reopening, outfitted with replacement furniture,
“A little over a year ago, the image of a bingo
Rio Grande do Sul).
but over time even a well-capitalised business
hall used to be a common room with long tables, “I was always against the slot-machine, might have difficulty repeatedly raising the funds
dining chairs, straw and underpaid workers why? Because I think the slot-machine will required to refit a well-appointed bingo hall to its
trying to have fun or earn some money without destroy bingos” (Male, Former bingo owner, former standards. A public prosecutor illustrated
spending a lot. Today a bingo is a carpeted Rio Grande do Sul.) this point with the example of a once luxurious
environment filled with mirrors, full of electronic bingo facility in Porto Alegre, which:
equipment and waiters in ties serving imported
“In bingo halls in São Paulo, electronic
whisky. …The old bingo has became a chic leisure

gaming machines represent 80% of the …[s]uffered a series of raids from both the
option.” (Zero Hora 1998).
profit from gambling houses, sometimes public prosecutor and the Police that aimed
reaching 90%, which detracts somewhat at de-capitalising the business. So in
“We bring together people representing 90% of
from the idea that these places should be subsequent re-openings the comfortable
the Gaúcho [Rio Grande do Sul] GDP.” (Male,
considered bingos and makes them seem armchairs were replaced with plastic chairs,
Director of a large bingo in Porto Alegre, Rio
more like casinos” (CPI dos Bingos, p.115). the granite tables were replaced with folding
Grande do Sul, quoted in Zero Hora November tables and the large screen was never
12, 1998).
“Bingo is the gateway to the casino” (Male,
Mayor of a city in Rio Grande do Sul, restored.” (Male, Public Prosecutor, Rio
quoted in Zero Hora, 12 November 1994) Grande do Sul)
In particular, some bingo businesses invested
heavily in the creation of casino-like environments
to attract players, where electronic bingo
A new form of clandestine operation has 3 A continuing concern with pathology and Another key concern was that the slot machines
developed since closure of the market: the pop- addiction found in many bingo halls during the legalisation
up bingo. This is set up with very little investment Although some treatment providers who spoke to era were designed to stimulate repetitive play.
and can be taken down quickly in the event of a us still treat gambling addictions on a small scale, This respondent, for example, identified elements
police raid. An industry expert described a gambling addiction did not feature heavily in our of machine gaming, including its isolation,
typical scenario as one in which: interviews as a significant current problem in display designs and the positioning of the slot
“a Bingo manager who worked ten years in Brazil. This is unsurprising given the lack of receptacles for tokens or coins, as contributing to
that place turns to his boss and says ‘sell me widespread legal gambling opportunities (other compulsive play.
The slot machine is the most harmful. I consider

this structure.’ He then mounts a clandestine than lotteries). However, fears about pathological
the slot very harmful. They put the coin slot up

Bingo as an itinerant bingo. He sets up in a gambling cropped up frequently, with some
here at the level of your eyes, if they put it down

shed here today, tomorrow he moves it, two respondents drawing on experience of the bingo
there at the level of your pocket, you will think

weeks later he changes the Bingo legalisation era.
“At first the game had more men than women. about it, because if you take your money out of
somewhere else again, and then the police
As the availability of bingo and video-bingo your pocket you will think. But it’s up here
will be there and close the business. He
increased so too did the ratio of women to men. instead. (So) you’re putting coins in, you’re
moves, two weeks later he’s in a different
So in the beginning it was 3 to 1 and then it putting coins in, you’re happy. The hours pass
place. We have come to the conclusion by
became 2 men to 1 woman. It depends on the quickly, it’s hallucinogenic, all those numbers,
analysing data from newspaper reports and
type of game, too, so you can’t really talk about those challenges. (Female, service provider and
conversations with players that Brazil has on
gambling in general… The lottery is very former player, Rio Grande do Sul).
average between 200 and 250 clandestine
different from bingo, which is different from

Bingos” (Male, Industry expert, Rio de
betting, which is different from poker, video poker.

Janeiro). Such concerns about pathology, compulsiveness,
What the studies show is that these little games and over-consumption of gambling services,
are far more serious than the others, because they
Clandestine bingos indicate that there remains especially in machine form, are not unique to
are more addictive, because it is so much faster.
considerable interest in play, but these places Brazil. They are central to debates about
You play there in the machine, you lose track of
may expose both players and staff to risks of gambling policy across the world. However, the
time and space quickly then, it’s like the
violence and prosecution.10 While Brazilian law persistence of these concerns – long after the
comparison between cocaine and crack.” (Male,
extends some protection to consumers by end of Brazil’s lawful market for bingo – indicates
problem gambling researcher, São Paulo)
refusing to uphold the debts incurred by a how deeply experiences of pathology marked
“pathological” player on grounds of her that era and contributed to popular
vulnerability11, the hidden nature of clandestine understandings of the effects of legalising bingo.
Some regarded bingo as a ‘gateway’ to harder
bingo limits players’ access to the extensive rights
and more intensive forms of play and suggested
and powerful remedies of Brazil’s Consumer
that the transition could happen very smoothly,
Protection Code.12
despite the difference between the highly social
nature of traditional bingo and the more
“I’ve had the police came several times individualised play on the machines.
“The typical profile of our patients at the time that

[while playing at a clandestine bingo]. They
the Bingos operated more openly was a person, it

wave a gun, ask you to raise your hand.
could be a man or a woman, around 47 years old

They open your bag, examine you, take
and the problem started like this: he began to

things, money, if there’s enough money in
enter the Bingo playing one or two cards games

the bag they take it thinking it’s from the
for a while, then when he got bored he went over

bingo.” (Female, bingo player, Rio Grande
to the computer. “ (Male, Researcher and

do Sul)
treatment provider, São Paulo)
10 Recurso Crime Nº 71005227848, Turma Recursal Criminal, Turmas Recursais, Relator: Madgeli Frantz Machado, Julgado em 11/05/2015.
11 REsp 1406487/SP, Rel. Ministro PAULO DE TARSO SANSEVERINO, TERCEIRA TURMA, julgado em 04/08/2015, DJe 13/08/2015.
12 Lei nº: 8.078/1990 – Código de Defesa do Consumidor (CDC).

OF BINGO IN BRAZIL
Recommendations We think a good case can be made that the a The definition of the game: Because a
Today there is no plausible justification for
benefits of lawful bingo – to the communities of blurring of the lines between bingo and
gambling to remain illegal. (Male, industry
players and workers as well as to the state – casinos contributed to the downfall of the
analyst, Rio de Janeiro)
outweigh the risk of harms. For bingo to play a legalised bingo market we consider that it is
role in Brazil’s future, however, it must be provided desirable clearly to differentiate bingo as a
Almost half of the population is against the in a way that marks a clean break with the past. specific form of gaming distinct from slot-
legalisation of bingo halls…Consequently, the We consider it implausible that Brazil at this machines and casino games in order to start
regulation issue is not just about legalisation but moment can create a trusted licensed bingo the process of rebuilding trust in the bingo
also about capacity to remove the strong stigma of market populated by private sector businesses sector. We recommend the creation of a
criminality from bingo halls… Generally people without robust, effective and well-funded comprehensive definition to cover land,
prefer a well-known formula: State intervention. regulation. online and mobile bingo. The rationale for a
Fifty percent of the interviewees prefer the comprehensive definition is to encourage
“Government” to administer the bingo halls. In In view of our findings, we therefore recommend: regulators to think about what kinds of play
the opinion of 78%, the bingos should operated in should be licensed as bingo games across
designated areas. In sum the hand of the State
1 That bingo be legalised as part of an
the different modalities, and to help reinforce
should not be invisible”. (CPI dos Bingos 2006,
integrated set of reforms to legalise gambling
the distinctive character of the game. To
p.119-120)
in Brazil. Although other forms of gambling are
carry out this definitional work effectively – in
outside the scope of this research, inclusion
particular to reduce the risks of land-based
of bingo legalisation within a more general
It is difficult to see the benefits to Brazil of its bingo once again being conflated with
legalisation programme will help to avoid the
current approach to bingo. The lack of a casinos and to demarcate clearly the
problems that occurred when the game was
regulatory model for legal bingo may reduce boundaries of online and mobile bingo –
legalised as an exception to the general norm
access to the game but it does not stop those bingo regulators will require training to
of prohibition.
who want to play. Illegality generates costs of develop expertise in bingo operations.
enforcement, corruption and foregone jobs and b The sites of regulatory authority and
2 That legalised bingo in Brazil should
taxable revenues. Illegality also tends to drive institutions: It is imperative that Brazil settles
encompass online and mobile bingo as well
gambling problems, including the exploitation of upon a viable structure of regulatory
as the terrestrial form. This broad scope will
vulnerabilities and fraud, further underground. For institutions for legal bingo and then invests
allow Brazil to capture some of the revenues
reasons such as these there is considerable sufficient resources for them to function
currently flowing to Portuguese language bingo
support within Congress to legalise gambling, effectively. The first and most critical choice
sites outside the country that are marketed to
particularly to realise the fiscal and economic is the locus of regulatory authority in light of
Brazilians and create a foundation for Brazil to
benefits that liberalisation is expected to create. the perennial conflicts between federal and
respond effectively to growth in online and
state power. We recommend the placing of
mobile forms of bingo.
We consider, however, that the legacy of the licensing, inspection, revenue distribution,
criminality, corruption, and ensuing loss of consumer protection and enforcement
3 That bingo be legalised through a regulatory
confidence in regulatory capacity that ultimately powers at the state level as is done in other
system that is comprehensive, integrated,
destroyed Brazil’s retail bingo market, together federal jurisdictions and we think that Brazil
responsive to the distinctive nature of bingo,
with concerns about consumer vulnerability that would benefit significantly from a formal
well-staffed and properly funded to develop
are found in the case law as well as the views of means to share and sometimes to
staff expertise and conduct effective
treatment providers, pose serious obstacles to coordinate regulatory practice across
inspections. Regulation of bingo in Brazil also
successful legalisation.13 Furthermore, at the time different states. We therefore recommend
must be tailored to the country’s distinctive
of writing, Brazil is enduring political turmoil that Brazilian policy makers introduce a
history, cultures, legal institutions and political
triggered by the largest and most extensive network model of regulation through which
arrangements. While we believe that Brazil
corruption scandals in its history, which “epistemic communities” of state regulators
should not simply transplant a regulatory model
potentially will exacerbate opposition to the idea work to achieve uniformity without
from elsewhere to govern its bingo market, we
of re-opening a bingo market. For reasons such centralisation.14
think it is useful to consider best practice from
as these it is doubtful whether the legalisation of c Player protection: In addition to conventional
other jurisdictions. We recommend further that
bingo is sustainable without a deliberate strategy forms of regulating market entry, inspection
bingo regulation in Brazil should address, inter
to rebuild trust and public confidence that the and supervision, which have historically
alia, the following four concerns:
sector will be less corrupt and be better been used for land-based bingo, it is
protected against capture by organised crime important for Brazil to create systematic and
than it was during the 1990s. effective conduct of business regulation to
govern relationships between providers and
players.
13 Superior Tribunal de Justiça: REsp 1509923/SP, Rel. Ministro HUMBERTO MARTINS, SEGUNDA TURMA, julgado em 06/10/2015, DJe 22/10/2015.
14 The idea of governance through regulatory networks has been developed most systematically in fields such as competition policy and financial regulation where the
domestication of international standards may play a significant role in national regulation. The idea of a loose confederation of “epistemic communities” at state levels, sharing
practice through activities coordinated by the Union government could potentially be adapted to the Brazilian context. For a useful summary and discussion of regulatory
networks see: Ramsay, Iain. “Consumer law, regulatory capitalism and the new learning in regulation.” Sydney L. Rev. 28 (2006): 9.
i Regulation of these relationships should d Crime prevention: Regulation in Brazil must

be based on the principles of “Know Your respond proactively to the public mistrust
Customer” (KYC) and “Know Your caused by the levels of criminality
Provider” (KYP). The KYC principle is associated with the country’s previous
usually associated with crime control and experience of lawful bingo. In addition to
security, particularly in relation to account articulating a regulatory objective to prevent
based play online. But we consider that crime (as is done elsewhere), requiring
the principle is important also for player providers to comply with Anti-Money
protection and as such should influence Laundering provisions (as is done
regulation of the risks that providers may elsewhere), and researching best practice in
exploit vulnerable consumers. The KYP other jurisdictions we consider it advisable
principle reflects the idea that players are for Brazil to impose on bingo providers a
entitled to feel confident that products and duty to prevent crime, including fraud,
services are safe, of good quality and money laundering, bribery and corruption.
delivered on fair non-abusive terms. The regulation should articulate the
ii One option for giving effect to KYC and outcomes that compliance with this duty
KYP principles is to treat bingo players as should deliver, require providers to develop a
consumers under Brazil’s Código de compliance strategy to achieve the specified
Defesa do Consumidor (Consumer outcomes and require regular reporting of
Protection Code) and create a regulatory the measures that providers take to achieve
duty on bingo providers to demonstrate the outcomes and the success of their
how they “treat consumers fairly”. This measures. Providers’ reports would be
duty would require bingo providers to subject to audit during regulatory inspection
report to the regulator and the public on and supervision processes and be made
the measures they take to ensure that publicly available. While there are good
bingo is provided in ways that uphold the reasons for the regulation to be drafted as
consumer’s rights under the Brazilian universally applicable, consideration should
Consumer Code. These rights are based be given to exemptions from more onerous
on the Code’s general understanding of requirements for small-scale, non-profit and
a consumer’s vulnerability as the weaker charitable providers of bingo.
party in transactions and more specifically
rights to protection against harmful 4 We make two further recommendations for
products and services, rights to fair institutional practices that Brazil could adopt to
dealing, including protection against help develop a strong and generally accepted
misleading and abusive advertising, licensed bingo sector:
coercive or unfair business methods and a First we consider that regulatory capacity
abusive practices, and rights to disclosure would be enhanced if a portion of the
and education, quality products and revenues from legalised bingo were used to
accessible dispute resolution. fund specialist NGOs to develop expertise in
iii Reporting of bingo providers’ compliance gambling regulation, data analysis, and
with the duty to treat consumers fairly communications. The role of these “Bingo
would require providers to document their Watch” organisations would be to strengthen
strategy to achieve the specified the capacity of civil society, independently
outcomes, report regularly on the of the regulator, to assess and where
measures taken to achieve the outcomes necessary critique the performances of
and their success. These reports would bingo providers against their regulatory
be subject to audit as part of regulatory duties to treat consumers fairly and prevent
inspection and supervision and be made crime.
publicly available. b Second, recognising the contributions of
players and workers to the value that bingo
creates, we recommend that a portion of
bingo revenues be ring-fenced to support
local services and causes and that staff and
players be given a voice in the distribution of
these bingo revenues.

OF BINGO IN BRAZIL
Top 20 bingo cases

A note about Brazilian cases: Usually cases in Brazil bind only the parties. They do not usually function as binding precedents for subsequent decisions.
We have selected the following cases as examples of the types of questions that judges have confronted in relation to bingo. We have focused in particular
on cases about the legality of bingo licences and games to illustrate varying views on this question.
Decisions about an Action on Constitutional Rights (Ação Direta de Inconstitucionalidade/Constitucionalidade) are binding and the last case on the list was
taken to the Supreme Constitutional Court on this basis.
On specific occasions a Brazilian Supreme Court will decide to issue a decision to promote uniformity of court decisions in a context where there are a lot
of cases with different results on an important issue. This type of case – a Súmula Vinculante – does function as a binding precedent. In 2007 Brazil’s
Federal Supreme Court (STF) issued a Súmula Vinculante in relation to bingos, holding that Brazil’s states lacked the competence to legislate about bingo
and so could not pass laws creating licensing and other regulatory powers for bingo businesses within their jurisdictions.
Our table includes cases from the following courts: Tribunal de Justiça do Rio Grande do Sul (TJRS; Court of Appeals of the State of Rio Grande do Sul);
Tribunal de Justiça de São Paulo (TJSP, Court of Appeals of the State of São Paulo); Superior Tribunal de Justiça (STJ, Superior Court of Justice); and
Supremo Tribunal Federal (STF, Federal Supreme Court).
Full citation Summary
Tribunal de Justiça do Rio Grande do Sul – TJRS
Apelação e Reexame Necessário Nº 598267391, Whether “Toto bola”, a form of tele-bingo developed and widely sold in Rio Grande do Sul until the state shut it down
Vigésima Primeira Câmara Cível, Tribunal de Justiça because of corruption, could be lawfully marketed. The applicant had obtained a bingo licence under Lei Zico (nº
do RS, Relator: Pedro Luiz Rodrigues Bossle, Julgado 8.672/93) and its implementing Decree (Decreto Regulamentador (nº 981/93), which had permitted states to authorise
em 11/04/2001 the development of “similar games” to bingo. This provision had been revoked before expiry of the applicant’s licence.
The court confirmed that the applicant’s state licence to market Toto bola remained valid despite the Federal
government’s withdrawal of authority to issue licences on this basis.
Agravo de Instrumento Nº 70003960085, Terceira An action brought by an operator who had been denied permission to install electronic gaming machines in a bingo
Câmara Cível, Tribunal de Justiça do RS, Relator: Luiz hall. The court denied the application holding that Electronic Gaming Machines are not legal in a bingo hall since the
Ari Azambuja Ramos, Julgado em 11/04/2002 legislation only authorised the licensing of traditional bingo.
Apelação Cível Nº 70004871380, Primeira Câmara A bingo operator brought the case to challenge a charge that the State of Rio Grande do Sul had imposed on bingo
Cível, Tribunal de Justiça do RS, Relator: Henrique businesses. The operator argued the charge was an illegal tax because operators received no services in return for
Osvaldo Poeta Roenick, Julgado em 16/10/2002 payment and that if the State had simply wanted to raise revenues from bingo it should have created a special tax
called an imposto. The court held that the charge was legal because the funds it raised paid for inspection and
surveillance actitivities required by the licensing activity. The situation in this case is similar to the case below
(Apelação Cível Nº 70005068325), decided three weeks later, but the two cases (decided by different judges) have
conflicting outcomes.
Apelação Cível Nº 70005068325, Primeira Câmara (see above).

Cível, Tribunal de Justiça do RS, Relator: Roque In this case the fee was considered illegal because no surveillance, inspections or oversight were conducted in bingo
Joaquim Volkweiss, Julgado em 06/11/2002) halls.
Agravo de Instrumento Nº 70005784434, Primeira The case was brought by a commercial operator, after his bingo licence (issued by the CAIXA) expired and the bingo
Câmara Especial Cível, Tribunal de Justiça do RS, market was closed under Lei Maguito. Because there was no longer a regulatory agency available to deal with
Relator: Angelo Maraninchi Giannakos, Julgado em renewal of bingo licences the applicant asked the court to renew his licence.
28/04/2003 The court decided that the law was in a state of “unacceptable juridical uncertainty” and the operator could have the
licence renewed through a judicial injunction.
Mandado de Segurança Nº 70005921507, Quarta The case was brought by a commercial operator, after his bingo licence (issued by the CAIXA) expired and the bingo
Câmara Cível, Tribunal de Justiça do RS, Relator: market was closed under Lei Maguito. Because there was no longer a regulatory agency available to deal with
Araken de Assis, Julgado em 28/05/2003 renewal of bingo licences the applicant asked the court to renew his licence.
This decision went further than the previous case, which granted the licence because of the uncertainty about the
applicant’s rights that the law had created. In this case the court held that commercial bingo is legal and that the
absence of a regulatory frameowork could not transform it into an illegal activity. It therefore granted the operator a
licence to run bingo.
Agravo de Instrumento Nº 70005784434, Primeira A local authority had refused to issue a permit (alvara) to allow a buiding to be used for bingo, since the licence to
Câmara Especial Cível, Tribunal de Justiça do RS, operate bingo issued by the federal agency (the CAIXA) had already expired and would not be renewed after the
Relator: Angelo Maraninchi Giannakos, Julgado em enactment of Lei Maguito. The court held that the degree of legal uncertainty surrounding the regulation of bingo met
28/04/2003 the threshold for unreasonableness and as such the company was entitled to continue its bingo activities. This meant
that denial of the local authority permit was not a valid exercise of local authority discretion and the application should
be granted.
Tribunal de Justiça do Rio Grande do Sul – TJRS
Apelação Cível Nº 70005845771, Terceira Câmara The applicant in this case was concerned about the many contemporaneous media stories on the closure of bingo
Cível, Tribunal de Justiça do RS, Relator: Augusto halls. It therefore sought an order to protect it against any future closure action. The claim was dismissed because the
Otávio Stern, Julgado em 26/06/2003 company was not facing a specific threat or action from a public authority. The court ruled that in the absence of such
a specific threat or action the applicant could not assume that it would suffer the same fate as other businesses and
that media stories or the facts of other cases could not be used to secure an order from the court in the applicant’s
case.
Apelação Cível Nº 70002112969, Segunda Câmara This case was brought by a bingo operator who sought to enforce a debt incurred by a player who paid with a cheque
Especial Cível, Tribunal de Justiça do RS, Relator: that bounced. The court held that a commercial bingo operator could enforce the debt against the player because the
Ícaro Carvalho de Bem Osório, Julgado em debt had been incurred when bingo had been licensed and therefore legal.
30/06/2003
Agravo de Instrumento Nº 70006051601, Vigésima A bingo owner brought this case to challenge the zoning / separation requirements on licensed bingos imposed by a
Primeira Câmara Cível, Tribunal de Justiça do RS, municipality. The court denied the application, holding that it is not for a court to decide whether minimal separation
Relator: Genaro José Baroni Borges, Julgado em requirements established by municipalities for sanitary, safety, security or other reasons within municipal authority, are
03/09/2003 legal or not. It is instead within the discretion of the municipality to decide.
This case was appealed to the Supreme Court. However, the court did not decide on the merits of the issue because
the Súmula Vinculante decision had been released. As noted below, this special precedent decision upheld the
federal government’s exclusive competence to legislate in the field of bingo. Consequently, the enactment (by the
federal government) of Lei Maguito to close the bingo market made questions about the authority of a municipality to
establish zoning and separation requirements between premises irrelevant (STF – RE: 524501 RS, Relator: Min. EROS
GRAU, Data de Julgamento: 13/06/2008, Data de Publicação: DJe-118 DIVULG 27/06/2008 PUBLIC 30/06/2008).
Agravo de Instrumento Nº 70006521009, Quarta The City of Bage denied a commercial operator a permit (alvara) because it did not hold a federal-level CAIXA
Câmara Cível, Tribunal de Justiça do RS, Relator: authorisation (a precondition for the permit). Held that this was outside the municipality’s powers. Given that there was
Wellington Pacheco Barros, Julgado em 08/10/2003 no legal certainty regarding the level of government, or agency, to which bingo operators should apply for
authorisation, municipalities had no right to deny permits (alvaras).
Apelação Cível Nº 70008269813, Décima Nona This action was brought by a comercial bingo operator against a debtor for repayment of money the debtor had
Câmara Cível, Tribunal de Justiça do RS, Relator: borrowed to play bingo. The judge held that although bingo was operated lawfully the lending of money to enable
José Francisco Pellegrini, Julgado em 14/12/2004 someone to play compulsively to the point of over-indebtedness would not be condoned by law. The debt therefore
was unenforceable.
RECURSO CRIME Nº 71005227848, TURMA The Ministério Publico (a type of public prosecutor) brought a criminal action under Art. 50 of the 1941 Lei de
RECURSAL CRIMINAL, TURMAS RECURSAIS, Contravenções Penais (Criminal Contravention Act) against an employee of a bingo hall alleging that the employee
RELATOR: MADGELI FRANTZ MACHADO, JULGADO was illegally offering games of chance. The court held that bingo staff cannot be prosecuted under Brazil’s Criminal
EM 11/05/2015. Contravention Act because they do not benefit personally from the profits of bingo activities.
Tribunal de Justiça de São Paulo – TJSP
Mandado de Segurança Nº 4730320000 Relator(a): This case was brought by a commercial operator, after his bingo licence (issued by the CAIXA) expired and the bingo
Linneu Rodrigues de Carvalho S; Comarca: Poá; market was closed under Lei Maguito. Because there was no longer a regulatory agency available to deal with
Órgão julgador: 7º Câmara; Data do julgamento: renewal of bingo licences the applicant asked the court to renew his licence.
27/05/2004; Data de registro: 16/06/2004 The court held that commercial bingo is legal and it granted the operator the requested licence. The court considered
that the 1993 exemption of bingo from the s.50 of the Lei de Contravenções Penais (Criminal Contravention Act)
effectively revoked prohibition as it applied to bingo and that once a law is revoked it cannot be revived. Since bingo is
legal it would be unfair to deny the operator a licence to run it.
Apelação Cível nº 004720-44.2011.8.26.0642. D.J.: This case was brought after a charitable bingo run by a commercial operator failed to deliver the prize to the winner.
18/08/2015, Desa. Lucila Toledo The winner took action against the charitable institution but the charity blamed the operator for non-delivery of the
prize and also argued that the judge had no authority to issue an order for it to award the prize. The court held that the
charity was responsible because the bingo had been marketed in its name and that the judge was entitled to order the
charity to deliver the prize because the bingo had been held on the basis of a judicial order authorising the event.
Embargos de Declaração 0.129.718- This case concerned a challenge to the legitimacy of the fees that the State of São Paulo charged bingo halls,
13.2008.8.26.0053/50001 ostensibly to cover the costs of regulatory services. São Paulo, unlike Rio Grande do Sul, funded its bingo regulation
work though a general “fee on diverse services” rather than a specific tax. The Court rejected the bingo owner’s
challenge, holding that the legitimacy of the fee was justified merely on grounds of the police power [which in many
systems of law is the power to regulate behaviour on the basis of health, safety, morals, and general welfare].

OF BINGO IN BRAZIL
Superior Tribunal de Justiça (STJ)
REsp 1406487/SP, Rel. Ministro PAULO DE TARSO This case concerns the unenforceability of a debt owed by a problem gambler to a bingo establishment. The debt
SANSEVERINO, TERCEIRA TURMA, julgado em was incurred while bingo was lawful although the case was decided afer the restoration of prohibition. The Court held
04/08/2015, DJe 13/08/2015. that the debt was unenforceable based on the Brazilian Consumer Code’s protection of the vulnerable consumer.
REsp 1509923/SP, Rel. Ministro HUMBERTO This case was initiated by the public prosecutor’s office in São Paulo together with the Federal Public Prosecutor. It
MARTINS, SEGUNDA TURMA, julgado em sought damages from the operators of illegal bingos. The court held that the illegal operation of bingo houses per se
06/10/2015, DJe 22/10/2015. is an economic activity that harms consumer and collective interests so the Public Prosecutor did not have to prove
pain, suffering or psychological damage from the illegal economic activity to claim collective moral damage to
consumer interests. The bingo halls were ordered to compensate society for collective moral damages and to pay a
daily penalty of R$ 20,000 [approximately £4000] for holding bingo games and R$ 2000 [approximately £400] per
slot-machine.
Superior Tribunal Federal
Súmula Vinculante 2 Building on previous decisions, this binding precedent makes a statement about competence to regulate bingo,
lotteries and other games. It holds that the exclusive competence to legislate in this field lies with the Union (federal)
Data de Aprovação government. States may not legislate to license bingo or in anyway regulate it unless there is a general federal law
Sessão Plenária de 30/05/2007 authorising them to do so. The consequence of this decision is that state laws and regulations on bingo and lotteries
Fonte de Publicação have no effect without an enabling federal law. Because this case is decided specifically as a binding precedent it
DJe nº 31 de 06/06/2007, p. 1. means that any future claims about the operation of bingos at the state level must be decided consistently with this
DJ de 06/06/2007, p. 1. Supreme Court precedent. Thus until a new federal law is enacted, states cannot authorise the development of
DOU de 06/06/2007, p. 1. commercial bingo in Brazil and state courts cannot hold that commercial bingo is allowed.
MI 766-AgR, This case concerns a challenge to the previous decision that bingos could not be run because of a lack of federal
Rel. Min. Joaquim Barbosa, julgamento em 21-10- authorisation. Claiming a constitutional right to run a bingo business, the applicant asked the court to issue an order to
2009, Plenário, DJE de 13-11-2009. compel the State (Union) to pass enabling legislation for bingos. The court agreed that in principle this type of order
STF – AgRg 765 – j. 30/11/2011 – rel. Dias Toffoli can be used to oblige the Union to fill a legislative omission that prevents full enforcement of rights or liberties. It held
in this case, however, that the remedy could not be used to force the state to legislate and regulate gambling activities
because there is no constitutional right to run a gambling business.
CHAPTER 2: BINGO REGULATION

IN CANADA (ONTARIO AND
BRITISH COLUMBIA)
Current approach to law and Court of Canada has held that there is no
regulation Aboriginal right to operate or regulate gambling in
the Canadian constitution. Bingo was central to
The federal legal framework for Canadian
the development of case law in this area.1
gambling is set out in part VII of the Criminal
Provincial jurisdiction over bingo operations
Code, a part otherwise preoccupied with
remains contested by many First Nations
prostitution, bawdy houses, and acts of
governments and bingo operators, some of
indecency. This criminalises those found
whom continue to assert rights to operate and
gambling and betting, alongside those who offer
regulate gambling for both economic
gambling, promote or advertise gambling, or
development and cultural reasons.
supply gambling devices. Penalties are up to two
years imprisonment. Under s 207 (1) (a) of the Criminal Code, the
provinces of BC and Ontario conduct bingos
Bingo is considered a game of mixed chance
through hybrid, quasi-autonomous agencies. In
and skill in Canadian law, meaning that it must fit
BC provincial gambling is conducted and
within specified exemptions from gambling
managed by the Crown Corporation2 charged
prohibitions to be conducted legally. The key
with managing gambling, the British Columbia
exemptions are as follows:
Lottery Corporation (BCLC). In Ontario, Ontario
s.207 (1) Notwithstanding any of the Lottery and Gaming (OLG) operates gaming
provisions of this Part relating to gaming and services on behalf of the province.
betting, it is lawful
In British Columbia charitable and provincial
(a) for the government of a province, either
bingo is regulated by the Gaming Policy and
alone or in conjunction with the government
Enforcement Branch of the Ministry of Finance.
of another province, to conduct and manage Revenue report used in BC by charitable, religious,
This directs policies, legislation, standards, and
a lottery scheme in that province, or in that and non-profit organisations running bingos.
responsible gambling strategies, licenses
and the other province, in accordance with
charitable bingo events, registers gambling
any law enacted by the legislature of that
service providers, certifies supplies and
province;
equipment, distributes the proceeds generated
(b) for a charitable or religious organisation,
from provincially-operated gaming in grants to
pursuant to a licence issued by the
applicant organisations, and conducts audits and
Lieutenant Governor in Council of a province
compliance investigations. The BCLC sets
or by such other person or authority in the
standards and policies for bingo facilities
province as may be specified by the
operated under its brand.
Lieutenant Governor in Council thereof, to
conduct and manage a lottery scheme in In Ontario bingo is regulated by the provincial-
that province if the proceeds from the lottery level Alcohol and Gaming Commission of Ontario
scheme are used for a charitable or religious (AGCO), and by municipalities. The AGCO
object or purpose. licenses larger charitable bingo events (with a
prize board over $5500), and certain kinds of
Businesses can only assist the provincial higher prize games (eg jackpot games that allow
governments and charities allowed to conduct a prize to be accumulated). It also registers
and manage legal games: the latter groups must gaming suppliers and gaming employees, and
retain the overall responsibility and control of the approves rules for games conducted and
gaming. In an important further limitation on managed by OLG. Municipal actors issue
charitable gambling activity, s. 207 (4) (c) of the licences for organisations running charitable
Criminal Code reserves to provinces the authority bingos with a prize board of under $5500. OLG
to run a game “operated on or through a also sets standards and policies for facilities
computer, video device or slot machine.” This operated under its brand.
prohibits charities from conducting and managing
forms of bingo that are computer-reliant (such as
electronic bingo, and many types of linked
Scale of play and bingo
game). Such games have to be run by the demographics
province, under s.207 (1) (a). In Canada participation in bingo appears to vary
significantly by province, although participation
Some First Nations governments in Canada have data has been collected at varying times so it is
claimed a constitutional right to operate and not possible to get definitive national figures. As in
regulate gambling on their territory. The Supreme the UK, bingo is popular with older, working class
1 See for example R. v. Pamajewon, [1996] 2 SCR 821, 1996 CanLII 161 (SCC);
2 Crown Corporations are wholly owned by the state but they operate at arm’s length from government. They have public policy goals, but operate as businesses.
CHAPTER 2: BINGO REGULATION IN CANADA

(ONTARIO AND BRITISH COLUMBIA)
women. In 2001 Statistics Canada found that churches to Buddhist temples. Children’s sports
while 9% of households participated in bingo and recreation clubs are a key sector in both
overall, participation was 13% for one person provinces. These rely heavily on the mobilisation
households headed by women over 65. Bingo of family members (usually parents or
participation was far higher among households grandparents) as volunteers to run the bingo.
with an income of less than CAN $20,000 after
tax (11%) than households with an income of When bingo boomed in Canada in the 1980s
CAN $80,000 or more (5%). Bingo is also and 1990s it was via charities and religious
especially popular with First Nations players, organisations acting in alliance with private
on and off-reserve. businesses. Profit-making organisations (who
charged rent for facilities, and fees for support
Bingo has been in decline in both Ontario and services) often sought out charities as partners,
British Columbia, due largely to the effects of since they could not legally conduct bingos on
smoking bans and competition from the their own. Many non-profit organisations that had
expansion of other forms of gaming (especially run games in their own premises moved to
casinos). Bingo revenue in British Columbia has running bingos in privately-owned facilities,
declined on average 13 per cent per year over the involving associations of licensed charities
past four years. Hall numbers and attendances where the bingo ran full-time.
have also fallen significantly: for example in
Ontario there are now 61 bingo halls, down from Of the 61 bingo halls remaining in Ontario, 30
Detail from an old slide bingo card, used in pub 230 in 2000. Most operators we interviewed are operated by associations of charities (the rest
games in BC. Card acquired by Kate Bedford predict further hollowing out of the sector in the are operated by the province). In 2014/5 3723
during fieldwork; image by Andrea Shieber. next 5 years. licences were issued to charities and religious
organisations by the AGCO for bingo fundraising,
Charitable operations out of a total of 4143 licences issued for all forms
of charitable gaming. In 2013-4 Ontario charities
Bingo funds a wide-range of charitable and raised $33 million from conducting bingo
religious organisations, from violence against operations.
women services to right to life groups, from
Diverse experiences of smoking bans

Ontario implemented a province-wide smoking bans in bingo. Based on a 32 hall sample, a 2008 report found an average reduction in profitability of
34% between 2006 and 2007, and a 25% reduction in profits for charities.
One Ontario manager recalled that the provincial smoking ban “took about 45% of our business away overnight. “ (male, charitable bingo hall
manager, Ontario). A manager in BC (where a provincial smoking ban was implemented in 2008) estimated a 60% drop.
Some self-organised bingos on First Nations land, in BC and Ontario, allow smoking. Players can travel some distance to frequent such places.
However some First Nations health organisations and family service organisations in Ontario expressed concern about the health impacts on First
Nations workers and volunteers of allowing smoking.
During fieldwork for the Bingo Project, in spring 2015, new smoking regulations were introduced in Vancouver Island (BC) increasing the distance that
smokers had to keep away from doorways from 3m to 7m (Clean Air Bylaw 3962). One popular bingo hall in a poor district of a small city was facing
the prospect of chivvying its mostly elderly customers away from the paved pedestrian area (where they currently clustered to smoke) into the busy car
park. The manager feared they would be run over.
“They said, ‘oh no, you’ll grow and people will come. Non-bingo players will now come because it’s non-smoking.’ That hall was making almost 5 million
a year for charity….By July I had it down to four days a week, because we were losing money…Then by the fall it was down to three. Revenues for the
charities went from 5 million dollars to 946,000 dollars. But ‘non-smoking will not have an impact on you’ (snorts).” (male bingo operator, on his
experience of a municipal smoking ban).
“See, I smoked. So being in that smoky bingo hall meant nothing to me. But when the by-law was coming, I had to quit smoking, because I don’t smoke
outside. I can’t, I never did. My mother always told me only hussies smoked outside. So I grew up thinking that was a bad thing to do.” (female,
charitable bingo hall manager, Ontario).
“When the smoking ban was brought into the province, when a lot of consolidation happened, AGCO got together with the operators, implemented an
interim revenue model to allow us to survive and weather the storm.” (male, commercial bingo operator, recalling the origins of a shift in revenue model
giving a higher share of proceeds to businesses in Ontario).
“When non-smoking came in, the decision was made that the slots were being successful and bingo had just been decimated at that point. And so we
lost about three hundred (bingo) seats. And those three hundred seats were lost to slots.” (male, BC commercial operator).
10 CRG Consulting. 2008. Market Study for Proposed Bingo Facility: Rideau Carleton Raceway. Ottawa.
Table 1: Gambling participation rates (%) in various gambling forms across Canada
Source: Canadian Gambling Digest 2013/14
British Alberta Saskatchewan Manitoba Ontario Quebec New Nova Prince Edward Newfoundland
Columbia Brunswick Scotia Island and Labrador
Year of survey 2014 2009 2001 2006 2011 2012 2009 2007 2005 2009
Bingo 5.7 4.8 8.4 12.9 4.6 4.2 7.5 11.6 6.9 8.7
Casino slots 28 15.4 20.3 23.9 20.5 13.5 7.6 15.5 6.1 4.8
Casino table games 7.0 7.3 6.4 5.9 3.6 3.7
Online Gambling 3.7 3.1 0.2 1.5 1.9 1.5 0.9 0.2 0.7 0.4
Speculative investment 7.7 8.6 8.4 4.6 1.6 1.2
Table 2: Charity/religiously-operated and government operated bingo In Ontario (ON) and British Columbia (BC)
Source: Canadian Gambling Digest (2013-4)
Charitable Operations BC ON
Total charity-operated bingo revenue (CAN $) after prizes paid, before expenses deducted 3,313,000 115,658,000
Total charity-operated gambling revenue (CAN $) after prizes paid before expenses deducted 77,478,000 381,898,000
Distributions to charity from government-operated gambling (CAN $) 135,000,000 128,300,000
Net Gaming Revenue to charitable organisations from their gaming operations (CAN $) after prizes and expenses paid
Net revenue from bingo 1,989,000 32,962,000
Net revenue from all gambling forms 34,129,000 155,298,000
Government-operated gaming revenue after prizes paid before expenses deducted
Total Bingo revenue 249,735,000 53,738,000
Revenue from slots or VLTs at bingo facilities 236,127,000 0
Total government operated gambling revenue (CAN $) after prizes paid before expenses deducted 2,129,614,000 4,682,322,000
Net Gaming revenue (CAN $) after prizes and expenses paid 1,174,600,000 1,923,149,000
Table 3: Money raised by independent bingos in British Columbia Table 4: Highest and Lowest Revenues from Independent Bingos,
2001/02 to 2014/15 BC (2014-5)
Source: Gaming Policy and Enforcement Branch reports Source: Gaming Policy and Enforcement Branch reports
Earned (CAD$)
Top 5
8,000,000.00
7,000,000.00 City Organisation name Revenue from
6,000,000.00 independent bingo (CAN $)
5,000,000.00 Burnaby St. Helens Parish $85,454.41
4,000,000.00
3,000,000.00 Vancouver Italian Cultural Centre Society $123,653.00
2,000,000.00 Vancouver United Croats of Canada –
1,000,000.00 King Tomislav Branch $145,437.21
0.00
Vancouver St Mary’s Parish $157,975.48
Cumberland Royal Canadian Legion Branch
#28 Cumberland $206,514.43
Year Bottom 5
City Organisation name Revenue from
independent bingo (CAN $)
Coquitlam Eager Beaver Bingo Club –
Community Fundraising Group $48.05
North Vancouver Silver Harbour Centre Auxiliary $49.23
Victoria Cedar Hill New Horizons Seniors Club $198.00
Sayward Royal Canadian Legion #147 Sayward $231.16
Kaslo J V Humphries School PAC $252.02

Charity-run association bingo halls have been Provincial operations

replaced by provincial operations in BC (see In the 1990s, a scandal over misuse of bingo
below). However independent charitable bingo proceeds in BC encouraged the provincial
operations continue. Independent bingos are government in tighter control of charitable
usually run weekly, in premises owned by a gaming. Some charities fought a long, bitter,
charity, religious organisation, or service club and unsuccessful legal battle to retain their
(such as a church, community centre, legion, independent role in conducting and managing
or elderly care facility). In 2013/4 133 licensed gaming in association bingo halls. In 2002
charities raised $2 million from such bingos in association bingo halls were taken over by the
BC. This is a significant fall from the CAN$ 7 crown corporation. Many were re-positioned as
million raised by the 255 charities licensed for community gaming centres (CGCs), which offer
independent bingos in 2001/2. However the slot machines alongside bingo. Currently the
number of licensees, and the amount raised, has BCLC operates 7 commercial bingo halls and 18
stabilised since 2010. In 2014/5 147 licences CGCs in the province. Charities can apply to the
were issued by BC’s Gaming Policy and province for grants from the money raised in
Enforcement branch for such independent bingos BCLC’s venues. However there is no link between
and they raised CAN $ 2.1 million in revenue. bingo facilities and local organisations, and
charities are not required to take any role in the
Some of these bingos are tiny in scale. One gaming to get the grants.
community fundraising group in the lower
mainland raised CAN $48.05 through its licensed In Ontario, as bingo has declined in popularity
bingo in 2014/5. However for some organisations, associations of charities and commercial
in some places, independent bingo provides operators have pressured the provincial
significant funds. One game we attended in BC – government for support. In 2005 the AGCO
with an accumulated jackpot of over CAN$50,000 launched a Modernization of Charitable Gaming
– attracted over 300 players to a community hall initiative, part of which involved piloting electronic
one sunny afternoon, requiring seats to be set bingo (e-bingo) in 6 sites. To comply with the
up in the hallways to accommodate people. Criminal Code, which prohibits charities from
Charities that run these bingos tend to have close running bingo games that require a computer, the
connections to players, and extensive expertise in OLG assumed responsibility for conducting and
operating the game. managing gambling in the e-bingo sites. In 2012
Table 5: Revenue and income from government operated gambling, Table 6: Revenue and profits from government-operated gambling, Ontario
BC (millions $) Source: AGCO Annual Report 2014-5
Source: BCLC 2014-5 Annual Service Plan Report.
Revenue 2010/11 2011/12 2012/13 2013/14 2014/15 Revenue (thousands of dollars) 2012-13 2013-14
Slot machines 1126.6 1140.7 1140.1 1135.3 1149.4 Lottery 3,287,469 3,387,571
Table Games 357.1 380.9 390.2 452.1 555.1 Bingo 39,876 73,817
Poker 22.5 22.1 21.3 20.7 21.1 Resort casinos 1,297,145 1,244,946
Bingo 110.1 96.3 86.5 76.7 75.3 OLG slots and casinos 2,008,081 1,964,044
Total 1616.3 1640.0 1638.1 1684.8 1800.9 Total 6,632,571 6,670,378
minus Awarded Revenue by gambling type, Ontario
Prizes 70.8 61.1 55.4 49.9 49 Revenue by gambling type, Ontario 201
Revenue by gambling type, Ontario
Net revenue 1545.5 1578.9 1582.7 1634.9 1751.9 Source: AGCO Annual Report 2014-5
2012-13 2013-14
2012-13 2013-14
Lottery Bingo Resort casinos OLG slots and casinos

the pilot was approved for a province-wide rollout, Figure 1: Stakerholders in Canada bingo: The usual suspects
whereby bingo facilities would be turned into c-
gaming sites (the ‘c’ stands for charitable). 31 of
Ontario’s 61 bingo halls are now run as c-gaming
sites.
Provincial government
Charities (as licensed
(as regulator and, via
Provincial revenue generation is a key priority of
operators or partners with

Crown Corporations, as
both the BCLC and OLG. In 2014-5, BCLC
Crown Corporations)
achieved its highest net income for the province
to date, of $1.25 billion. Since 1985 it has raised operator)
over $18 billion. In 2014-5 the OLG generated $2
billion, making gambling the greatest source of
non-tax revenue for the province. Since 1975 it
has generated nearly $40 billion. However in both
cases casinos and lotteries provide most of this
Gaming service providers

income. In BC in 2014/5 bingo provided $62
(as partners with charities or

million of the £1.8 billion in total revenue
governments)
generated by casino and community gaming
operations. In Ontario OLG made $74,000 in total
revenue from its bingo operations, but after prizes,
expenses, and payments to charities it made a
net loss of $46,000.
Key themes
1 The shifting debate about the charitable
role in bingo
severing the link between bingo operations and of the USA) rests on volunteer labour. To receive
Ontario Charitable Gambling Association, local charities in the aftermath of the provincial a licence for bingo fundraising in most provinces
Private Sector and Government Work bingo scandal. However others felt that facilities charities must use their own volunteers to conduct
Together to Deliver Technology were better run and easier to manage without the and manage the gaming. Volunteers in bingo are
Opportunities for Charitable Bingo. reliance on charity volunteers. often beneficiaries or users of a charity, working
bingos in part to get access to its services. This is
This is the most exciting news that the In Ontario, the tripartite understanding of bingo especially true of parents and grandparents who
charitable bingo industry has had in years! interests has been somewhat overcome, since are volunteering for children’s sports clubs. In one
(OCGA website, charities, businesses, and government are example raised in a divorce case4 a father in
www.charitablegaming.com/Public/AboutO increasingly partnering up to promote c-gaming Alberta was ‘volunteering’16 bingos a year, of 5-7
CGA) halls. Unlike in BC, charities retain a role in hours each, to keep his daughter in a swimming
provincially-operated bingo in Ontario. For club. If he missed one of those bingos, he was
example member charities retain a share of fined $100. Parents of children in sports clubs in
The limited law and policy attention that has been proceeds in return for sending volunteers to help Ontario spoke to us of fines of $200 if they
given to bingo in Canada has focused mainly on at the c-gaming facility. The Ontario Charitable missed working a bingo. Low-income parents
a tripartite relationship of stakeholders (see fig 1), Gambling Association has also taken a leading found such conditions especially onerous.
and in particular on the perceived clash between role in drafting standards that apply to the
provincial governments and charities. Provinces charities fundraising in the c-gaming centres.
have been accused by some observers of “Everyone is a volunteer. Every worker on
cannibalising charity fundraising, by expanding Ontario’s experience of partnership suggests a the floor. And, volunteer is a dicey word for
their own gambling operations and reducing the need to think beyond a presumed clash between some of them.…If they don’t show up for
charitable role in bingo.3 charities, provinces, and private businesses, by what they’ve been assigned they do get
considering other stakeholders with interests in fined. Seventy five bucks and hundred and
Our research suggests that the tripartite model charitable bingo. Key here is the question of how fifty bucks in the summer” (male organiser
of stakeholder relations remains helpful in well volunteer interests are represented in of an independent charity bingo in BC in
understanding disputes about bingo regulation, debates about bingo regulation. Licensed which most of the bingo volunteers were
especially in BC. Some BC interviewees, charitable bingo in much of Canada (and much Filipina mothers).
representing both charities and gaming service
providers, remained critical of the government for
3 See for example Campbell, Colin, Timothy Hartnagel, and Garry Smith. 2005. The Legalization of Gambling in Canada. Ottawa.
4 MJF v. JMF, [2006] ABQB 189. See also R. v. Weitzel, 2005 CanLII 378 (ABPC), involving prosecution of a charitable bingo coordinator for paying bingo volunteers.

2 Coping with decline: Regulating diverse are auto-dabbed. In accordance with the Criminal
game innovations Code electronic bingo requires provincial
In the face of declining attendance, many involvement, since the play is run through a
attempts have been made to refresh or revitalise computer. It also requires new rules on equipment
bingo in Canada. Four types of product standards and authorised providers, the
innovation have been particularly significant. procedure for winning (especially whether a
physical shout is required after a machine notifies
Firstly, games were introduced that ran alongside a player of a win), and the maximum number of
main stage play rather than in the breaks, in part tickets that may be loaded onto a device. The
so that additional revenue could be extracted latter is required both for responsible gambling
from side games while allowing players to go concerns, and to reassure paper players that they
outside to smoke. Key here were ‘balls tickets’, still have a chance to win.
a form of pull tab (an early form of scratch card)
with guaranteed winners in every box. Some
pull tabs reveal numbered bingo balls which Flashboards in an electronic age: Out of date
the player then has to cross off in a live game technology or player engagement tool?
to win an additional prize, sometimes of several In line with its move to electronic bingo the
thousand dollars. They are fun to sell: many balls BCLC has taken away display flashboards
Standards for charities participating in OLG's c-gaming tickets have ribald names, called out with a smile that show the numbers called. These are
halls, Ontario. unnecessary with e-bingo and expensive to
by floor workers (‘Hot balls! Great balls!’). They
were a low-tech add-on to the existing product maintain, in part because the light bulbs are
offering, requiring authorisation from the constantly blowing. One regulator
provincial gambling regulator and a set of rules described them as “old technology that we
about how to play (especially around the fact that can’t support anymore, it’s analogue in a
all tickets in a box had to be sold once it was digital world.” (male regulator, BC) Another,
opened) but no shift in conduct and management however, felt that the boards had
authority. They became the survival route for successfully engaged players: “if we could
association halls faced with declining attendance put those damn boards back we would
in Alberta, and then in Ontario. An agreement to have some happy people.” (female
introduce them in BC is being negotiated now. regulator, BC
“In all honesty, if we wouldn’t have brought the

balls in, we probably wouldn’t have a hall. In this
area, people are crazy for the ball cards.” (female,
Finally, slot or slot-variant machines are regarded
charitable bingo hall manager, Alberta).

by some operators as the way forward for bingo
facilities. In BC the decline in the industry – in part
caused by the provincial smoking ban –
Secondly, some providers have tried to prompted changes in the floor space devoted to
reinvigorate bingo’s appeal by introducing more bingo versus slot machine play. One community
entertainment via innovations such as disco gaming centre (CGC) that is notable for its
bingo, late night bingo, drag bingo, naughty determination to retain and promote bingo went
Canadian bonanza ticket.
bingo, and dirty bingo. These can require from 800 bingo seats to under 400. The number
extensive regulatory negotiations, including of slots – originally 50 – grew to over 300. In
around whether guest entertainers can call out 2014-5 there were 2508 slot machines in CGCs
bingo numbers and whether rude prizes such as in BC (up from 1850 in 2010-11).
vibrators can be given away in provincially-run
facilities. Spontaneity can be difficult to Although OLG is constrained by provincial
accommodate. For example when a guest caller – regulation from introducing slot machines in its
Santa – generously added to the prize board in a c-gaming facilities, it has introduced electronic
Newfoundland hall in 2004, the hall initially had its break open ticket machines. These were originally
licence suspended because it had exceeded the designed in the US for those Native American
prize board regulations.5 gaming facilities that are not permitted to have
slot machines. Technically they are not slot
Thirdly, electronic bingo has been embraced by machines because they do not rely on random
some providers as the solution to declining number generation for their outcomes. However,
revenues, in part because it allows existing bingo as several interviewees noted, the machines
players to play more tickets and in part because – appear to many players to be slot machines. Their
it is hoped – it will attract younger people. Tickets introduction in Ontario has raised concerns from
5 Community Fundraising Corp. v. Newfoundland and Labrador (Department of Government Services and Lands), [2004] NLTD 236.
some local government officials and responsible organised bingos can also be used to help Local governmentrole
gambling advocates about harder gambling individuals, such as via assisting a family afflicted There is no local government role in licensing
forms being introduced to bingo environments.6 by an illness or accident, or providing resources bingo in BC. The provincial gambling regulator
for a young person going away to college. The (the Gaming Policy and Enforcement Branch)
3 Role of other governments use of proceeds in self-organised bingos is determines eligibility, monitors use of proceeds,
Although the provincial government role in bingo reliant on strong links to players as donors, in approves rule changes to games, etc. However
regulation is central to the Canadian case study, keeping with the mutual-aid style nature of the host local governments must approve the location
our research has also illuminated the role of other activity. of a community gaming facility. On several
governments. occasions local councils have refused to do so,
Provincial involvement with licensing bingos on out of concern about the proliferation of slot
First Nations governments reserve territory varies, although in both BC and machines.
Self-organised bingos, run without a licence from Ontario provincial jurisdiction over bingo remains
the province as mutual aid activities on reserve contested by many First Nations governments. In In Ontario, the AGCO and municipalities share
territory, have long existed in Canada. In fact BC First Nations with provincially-recognised roles and responsibilities in licensing charitable
some of the key legal cases on the Aboriginal jurisdiction over land use planning can become bingos. Municipal actors issue licences for
right to operate and regulate gambling included a host local government to a gaming facility organisations running lower prize games.
testimony from First Nations leaders about the conducted and managed by BCLC, receiving a Municipalities can attach terms and conditions
historical regulatory role of First Nations portion of gaming revenue in this capacity. Two on licensees: the most common are that the
governments and communities in bingo.7 Many First Nations host community gaming facilities on organisation has to deliver services within the
organisers of on-reserve bingos have been their land. Ontario’s provincial government has municipality.
prosecuted, typically for keeping a common pursued some gaming partnerships with First
gaming house. In two Ontario cases, decided Nations governments. For example the Rama First Municipalities have taken diverse approaches
in 2004, the prosecution relied on the local and Nation runs a casino and a c-gaming facility. The to their licensing role. Some simply respond to
regional police having conducted extensive First Nations lottery licensing framework applications from charities and religious
surveillance of on-reserve bingo play.8 The delegates authority comparable to that of organisations. Others are more heavily involved
women who had key organising roles were both municipalities to some First Nations, providing in charitable bingo, scheduling charities for their
convicted of keeping a common gaming house. them with the authority to issue licences to eligible slots in an association hall for example, or
religious and charitable organisations to conduct creating arms-length bodies make decisions
Self-organised bingos are often run in community lottery schemes. 39 First Nations communities about eligibility in order to maximise local
facilities, and part of the proceeds are typically have been designated this authority (AGCO interests.
used for good causes. Many causes are similar to Annual Report 2014-5, p. 66). Otherwise, the
those off-reserve, such as supporting a local AGCO is the licensing authority for lottery This variation notwithstanding, municipalities often
school sports team, and sometimes the schemes in ‘unorganised’ territories. understand themselves as having a key role in
individuals who are raising money for the activity protecting charity interests in association bingo
will volunteer to help run the game. However self- halls (eg by enforcing prize board limits so that
Table 7: Slots and slot-variant machines in bingo facilities, British Columbia (BC) and Ontario (ON)
Canadian Gambling Digest 2013/4
Table 7: Slots and slot-variant machines in bingo facilities, British Columbia (BC) and Ontario (ON)
BC ON
Canadian Gambling Digest 2013/4
2013/14 2014/15 2013/14
Electonic Break Open ticket/Pull-tab units BC ON
Terminals 0 2013/14 2014/15 470 2013/14
Total Electonic Break Open ticket/Pull-tab units 0 470
Terminals 0 470
TotalBingo units
Electonic 0 470
Terminals 4069 3450
Total Electonic Bingo units 4069 3450
Terminals 4069 3450
Total Gaming Machines (EGMs)
Electronic 4069 3450
Slots or VLTs at Bingo Facilities 2803 2508 0
Electronic
Slots at casinos Gaming Machines (EGMs) 9907 9797 11974
Slots
Slots or or at
VLTs VLTs at Bingo Facilities
Racetracks 0 2803 2508 102240
Slots
VLTs at at casinos etc.
bars/lounges 0 9907 9797 0 11974
Total Slots or VLTs at Racetracks 127100 12305 2219810224
VLTs at bars/lounges etc. 0 0
Total 12710 12305 22198
6 See, for example, Harrigan, Kevin, Vance MacLaren, and Ryan Huckle. 2013. The Modernization of Bingo in Ontario: Recommendations for Responsible Gambling. Report to
the Ontario Problem Gambling Research Centre.
7 See for example R. v. Bear Claw Casino Ltd et al., 1994 CanLII 4710 (SKPC); R. v. Victor Jim, 1995 CanLII 1522 (BCCA); [1996] 3 WWR 30
8 See R. v. Gardner, 2004 CarswellOnt 2308, 2004 ONCJ 69, 62 W.C.B. (2d) 232; and R. v. Shabaquay, 2004 CanLII 68 (ONCJ).

charities receive a fair portion of funds). However reduced enforcement role. Some licensing
they tend to balance this with an eye on the officers advised local councils against signing the lines of business. Under the Standards-
charities themselves. They are especially focused contract to convert the halls, in part because they Based Approach, the regulatory focus shifts
on monitoring eligibility of the organisation, and were concerned about the products that may be from requiring gaming registrants to comply
use of proceeds. introduced (including slots-variant machines), with a prescriptive set of rules and
and in part because municipalities might lose regulations – a “command and control”
Local licensing officers in Ontario reported that links to local charities. Those links were seen by regulatory approach – to providing
they had been pressured, on occasion, by local some municipal regulators as about offering standards that must be achieved. This is
elected representatives to accept organisations or support and guidance, and by others as about a fundamental change that delivers a
uses of proceeds that did not, in their view, meet providing oversight. modernized approach to gaming regulation
eligibility criteria. This was most likely to happen and allows the AGCO to focus its resources
with service clubs whose interests are especially 4 Standardisation of bingo using risk- on key risks and maintaining game integrity,
well-represented on local councils (and in based regulation approaches from while providing a degree of business
courts9). Licensing officers were usually able to casinos flexibility and efficiencies for the industry.
resist such pressure, acting – as they saw it – to (AGCO Annual Report 2014-5, p. 18)
uphold the rules fairly in the broader public The AGCO is continuing its ongoing
interest. transition towards risk-based, outcomes-
based, and compliance-focused regulation. Finally, provincially-run bingo is impacted by the
The municipal role, including as a regulator of The AGCO will develop a framework to rollout of standardised responsible gambling
charities, has been significantly changed under guide the consistent use of risk-based policies initially designed with casinos in mind.
Ontario’s move to c-gaming. Municipalities issue methodologies and approaches across all These policies include self-exclusion in BC (where
permits (not licences) for charities to get a place players who consider themselves to have a
at an OLG-run c-gaming facility, and they have a gambling problem can ask to be excluded from
Standardisation of rules using a risk-based regulation model derived from casinos: BC’s experience with ‘Dusting Off’
‘Dusting off’ rules originated in casinos, to regulate how gambling employees touched cash and chips. Employees are forbidden from accepting cash
or chips hand to hand from a customer, and they are required to open their hands, and/or wipe them together, and show their palms to a camera, to
demonstrate that they are not hiding money or chips. 'Dusting off' is so familiar to casino employees that some apparently do it automatically outside of
work, ‘dusting off’ after touching cash while shopping at the supermarket for example. As one BC interviewee noted, “You get casino employees that
will go shopping and (taps hands together, in a gesture of dusting off). [Laughs]. It’s just become so natural, right.”
When BCLC took over bingos in BC, they essentially cut and pasted the regulatory framework used for casinos. Hence dusting off was applied to
bingo staff.
“You can’t do hand to hand contact for any cash. It must be laid on the counter and then we take it and count it out on the counter and then put it in the
till and then we have to dust off to show that we don’t have any cash in our hands. And we also have to dust off to show nothing is in our hands when
we leave the cash area as well. It was a bit of a struggle when I first started working here, everyone would do hand to hand.” (female, BC bingo hall
manager).
When asked what the provincial regulator would be looking for when they inspected, one bingo hall manager said first:
“cash handling, they’ll literally, going in and view random days on our CCTV to make sure all the staff are following proper cash handling.
Kate: I saw you rub your hands there?
Dust off, yeah. Literally. That’s one of the things they check.” (female, BC bingo hall manager).
“They say ‘Why do we have to do it like this?’ I walked in one time for an audit and the cashier looked at me and went like this (loud, obvious dusting off
with hands). Coz he thought, ‘I am going to show you!’(Laughs)” (male, BC bingo auditor).
“We have so many regulations about how we touch cash. We can’t cup cash. It has to be very visible and it’s under camera. What it did do from our
point of view as operators, it cost us more money, because you have got to install cameras. So systems cost money. But at the end of the day, it also
brought a tremendous amount of credibility and peace of mind to owners and to government in the fact that at least the cash was being handled
properly. With the owner group here, they were very happy about a lot of the controls, because they said, any time we can have something that shows
clearly that our staff are doing proper procedures and at the end of the day, this is a legitimate business, the stronger we all get.” (female, BC bingo
manager)
One hall manager stated that although employees had now learned to comply with dusting off rules, customers still tried to initiate hand to hand
contact when using cash, and they had to be reminded. I did the same the first time I purchased tickets in a BC bingo facility, trying to place money in
the cashier’s hand. He backed away and told me to put it on the counter. I felt rather affronted, since close physical contact with staff, and trust, are key
features of bingo. Over the subsequent weeks of fieldwork I saw the same thing happen again and again with other customers, in other locations.
Employees backed away from the player’s hands, glanced up at the camera, and told the player to place their cash on the counter. The customer did
so, but often left looking affronted. These interactions took place over 10 years after the ‘dusting off’ rules had first been imposed on bingo facilities.
9 See, for example, the generous judicial treatment given to the Kinsmen club’s illegal bingo in R. v. Kinsmen Club of Windsor, [1963] CarswellOnt 305, [1964] 1 C.C.C. 144
the facility for a period of time); special invited to share their expertise with other 4 Local and provincial level regulators could
educational weeks giving information about game groups; funding for inter-organisational explore options for better supporting low-tech
odds and resources on problem gambling in both learning; or a designated section on and entertainment-focused game innovations,
provinces; posters about gambling treatment independent bingos in annual regulator such as drag bingo, disco bingo, dirty bingo,
services being displayed in toilets; and so on. The reports, with targets for action to be discussed and so on. These often enjoy more local
OLG requires responsible gambling training for all with existing operators. Interviewees from the support than the expansion of automated
staff in c-gaming sites. Many clinicians and Gaming Policy and Enforcement Branch (BC), gaming, and they do not require control of the
counsellors who work in the field of responsible the Alcohol and Gambling Commission of gaming (and distribution of proceeds) to be
gaming – and who in the past have typically Ontario, and local municipalities in Ontario all transferred to the province. To support
worked in casinos – are being exposed to bingos spoke of their commitment to helping small innovative live game formats greater flexibility
for the first time. Plans are also underway to organisations operate within charitable gaming may be required around rules on non-cash
extend self-exclusion to the c-gaming facilities. rules, so in our view there is a strong desire prizes; guest callers; and prize board limits.
from staff on the ground to provide such 5 As a result of a recent amendment to s. 207 (4)
In Ontario in 2013/4 self-service interactive support. of the Criminal Code, passed in late 2014,
responsible gambling terminals (giving 3 While provincial governments have taken provinces may now authorise charities and
automated information about gambling myths, measures to share expertise on gambling religious organisations to directly run
game odds, etc) and on-site support centres regulation amongst themselves, and via computerised raffles. Ontario’s AGCO is
(offering leaflet information and occasionally international collaborations with other gaming working with large charities (who wish to run
frequented by responsible gambling staff) were in regulators, jurisdictional collaboration is weaker such raffles during major sports events) to
place in 12 c-gaming facilities. In BC they were at other levels of government in Canada. explore new regulations. Our research has
available in 19 bingo facilities. Opportunities for provincial government shown that bingo operators are still subject to
regulators to learn from the bingo-related strict constraints on games involving a
Some respondents – representing both charitable expertise of First Nations regulators seem computer derived from s. 207 (4) of the
and commercial interests – felt that a greater especially constrained, in the absence of a Criminal Code; indeed these constraints have
emphasis on responsible gambling was required broader shift in federal and provincial approach in part driven the creation of the province's
once slot machines or electronic break open to First Nations jurisdiction over mutual aid c-gaming strategy, where electronic bingo is
ticket machines had been introduced into bingo gambling activity. Attention could, however, be operated by the OLG. Hence in fairness bingo
facilities. However in Ontario the roll out of these fruitfully devoted to improving collaboration at operators should be included in provincial
responsible gambling measures into c-gaming the local government level, within and across discussions of whether and how to relax rules
has been resisted by those who do not see bingo provinces. A first step could be to invite local on raffles, in order that any concessions
as a significant site for problem gambling, or who gambling licensing experts to present at events granted to large charities running electronic
regarded the initiatives as a top-down, casino- such as those organised by the Federation of raffles are assessed for their impact on other
based imposition, reflecting a lack of Canadian Municipalities; the Association of sectors of charitable gaming.
understanding of the bingo sector and a lack of Municipalities (Ontario); and the Association of
interest in its own dynamics. Self-service Municipal Managers, Clerks and Treasurers of
terminals giving automated information about Ontario.
responsible gambling have on occasion been
mysteriously unplugged, and responsible
gambling staff have had to travel to c-gaming Figure 2: Revised stakeholders in Canadian bingo: Some additional suspects
facilities to plug them back in.
Provincial
Recommendations specific to the
Canada case study government
Licensees
First Nations of independent
1 Notwithstanding the importance of charities, governments charitable
provinces, and commercial operators, the and operators bingos
views of other stakeholders – especially
volunteers, local governments, and First
Nations bingo regulators and operators – need Gaming
to be included in policy debates. An expanded Volunteers G service
model of stakeholder interests should be providers
considered (fig 2).
2 The association model of full time charitable
bingo halls is becoming harder to sustain, but
57
charity-run bingo may be viable on a smaller, Charities Paid
more occasional scale. Hence regulators staff
concerned with charitable bingo, especially in
BC, might consider how independently Municipal
licensed charitable bingos could be better Players governments
supported. Support could involve ‘how to’
workshops where successful charities are

Top 25 bingo cases

Case Brief summary
R v. McGee, [1942] 2 A dance hall owner in Manitoba let out the hall 5 evenings and 2 afternoons a week for charitable organisations running bingo; was paid a flat
W.W.R. 206, 50 Man. R. rental fee plus a fee per person admitted if admissions exceeded 400 (which they frequently did). Was charged with keeping common gaming
152, 77 C.C.C. 302 house. Claims that bingo is not a game (relying on an Irish case, Barrett v. Flynn [1916] 2 Ir. 1, that had held ‘housey’ – a synonymous with bingo –
to be a lottery involving no skill), and hence that the charge of running a common gaming house does not apply. Manitoba Court of Appeal held
that bingo is a game of chance; the dance hall was a common gaming house; the accused was liable as a keeper thereof. The exemption granted
to charitable or religious organisations allowing premises to be used “occasionally” for the playing of games for charitable or religious objects did
not apply: “instead of permitting his hall to be used occasionally for the playing of games for such objects without any gain or profit to himself, he
made the keeping of his premises for the playing of games of chance a regular revenue-producing business for his own benefit”. Convicted.
R. v. Cosmopolitan Club, Prize bingo played at a carnival in Edmonton (Alberta) to raise money for charity; club charged with keeping a common gaming house and
1948 CarswellAlta 10, conducting a lottery. Alberta Supreme Court hold bingo not to be a lottery, and can benefit from exemptions applied to raffles and games played at
[1948] 1 W.W.R. 290, 5 bazaars and premises where the proceeds are used for charitable or religious objects. Court directed an acquittal.
C.R. 100, 90 C.C.C. 358
R. v. Kerim, [1962] CanLII Bingo played in premises in Ontario four nights a week for religious or charitable purposes. Religious or charitable organisations supplied
32 (ONCA) equipment and bingo staff, and paid a rental fee (not dependent on the number of people playing) to the Kerim brothers as president and
manager of the facility. Whether brothers are keeping a common gaming house – an offence liable for up to 2 years imprisonment – or knowingly
permitting a place to be used for the purposes of a common gaming house (a lesser offence). Court allows appeal against the charge of keeping
a common gaming house. ‘Keeping’ involves “some act of participation in the wrongful use” (Laidlaw at para. 6). Crown appeal dismissed in R. v.
Kerim, [1963] SCR 124
R. v. Kinsmen Club of Club organisers, who ran a newspaper bingo in Windsor (Ontario), charged with keeping a common gaming house and conducting or managing a
Windsor, [1963] lottery scheme. Identical schemes, running since 1959, had raised over $81,000 for local charities. Ontario magistrate holds that they can’t be
CarswellOnt 305, [1964] convicted of keeping a common gaming house because there was no place for gaming. But newspaper bingo is a lottery, not a game. Although
1 C.C.C. 144 the club believed it was operating within the law, and consisted of “reputable and public-minded people motivated by a high ideal of public
service” (Jasperson at para. 37), the Court must draw the line since “there is considerable public opinion inclined to the view that all things done in
the name of Bingo are legal if the object of the game is for charitable or religious purposes. This, of course, as a broad statement of the law is not
correct.” (at para. 38)
R. v. MacDonald and Mount Pleasant War Memorial Community Cooperative Association, a branch of the Canadian Legion, was operating bingo games afternoons and
Mount Pleasant (British evenings 6 days a week, with daily attendance estimated at 1800 people. Bingo was open to the public on payment of an entrance fee. Legion
Columbia No. 177) claims exemption from gambling prohibitions on the grounds that a place is not a common gaming house if used by a bona fide social club. Court
Branch of the Royal rules that the premises were not being used as a bona fide social club; convictions for illegal gaming restored. “It was a place open to the public
Canadian Legion, [1966] without discrimination and in daily use as a centre of public gambling…The use of these premises for bingo on such a widespread scale
SCR 3 contradicts any possible inference of the use as a bona fide social club” (Judson at page 6). Note that the facility – in Vancouver – is still in use
today as a bingo hall.
Keystone Bingo Centre Association of charities (with licences to conduct and manage bingos) agree with business owner to conduct games at his premises. Association
Inc. v. Manitoba Lotteries pays rent plus a cut of the proceeds plus most of the concessions income. Government changes its lottery policy, requiring charities to conduct
Foundation, [1990] bingos on their own premises, on publically owned premises, or facilities owned by other charities, due to concern over role of private businesses
Carswell Man. 243 (C.A.) in bingo operations. Keystone demand compensation from provincial government and Lotteries Foundation. Dismissed, on grounds that the
business was illegal in the first place; the business owner was conducting and managing lottery scheme and using proceeds for other-than
charitable or religious purposes.
R. v. Furtney, [1991] 3 Operators of a bingo business in Ontario charged after repeatedly counselling charitable bingo licensees to violate terms and conditions of their
SCR 89 licences by breaking rules set by regulators on maximum percentages of the revenues that can go to management costs. Business claims that
Parliament exceeded its powers of delegation in permitting exemptions from criminality for provincially-licensed charitable or religious
organisations operating lotteries, since criminal law is reserved for the federal government. Held that there is no improper delegation, and that
provinces can act to regulate gaming activities under the Canadian constitution. Provincial licensing and regulation of gaming activities is not per
se legislation in relation to criminal law: it can also relate to provincial powers to maintain charitable institutions.
Tumaitis v. Tumaitis, 1992 Husband claims wife wasted significant assets during their marriage through regular bingo playing (3-5 times a week, playing up to 14 cards at a
CanLII 689 (BCSC) time) and occasional trips to Vegas. Judge holds “there is not sufficient evidence to justify the drawing of an inference that she was somehow a
compulsive gambler and even less to suggest that she somehow suffered substantial losses in her activities.”
R. v. Bear Claw Casino Claim of Aboriginal right to operate and regulate gambling as part of constitutional right to engage in cultural and economic activities. Case is
Ltd et al., 1994 CanLII triggered by Royal Canadian Mounted Police (RCMP) action against a casino on the White Bear First Nation reserve in Saskatchewan, but bingo is
4710 (SKPC) referred to prominently in testimony on customary law. eg Edward Harvey Lloyd Littlechief – a councilor at White Bear First Nation – claimed that
on-reserve bingos were well-known by the RCMP, which had never – in at least 25 years – acted against bingo; and that the bingo had been
regulated (including via a licence) through the Chief and Band Council until regulation moved to the newly-established White Bear First Nation
Gaming Commission. This evidence was key to the court’s decision that the accused’s belief that the Criminal Code’s gaming provisions did not
apply to their on-reserve gaming activities was reasonable, and hence that there was sufficient doubt of guilty intention to convict. (NB: appeal
occurs in Bear Claw Casino Ltd and others v. R. ,1995 CanLII 3914 (SKCA), but case is adjourned after enactment of an operating agreement
between the Province and the Federation of Saskatchewan Indian Nations which results in the opening of the casino. It does not offer bingo).
Case Brief summary
Mount Pearl (City) v. Local Newfoundland and Labrador Court of Appeal upholds City council’s discretion to refuse a permit for a new bingo hall on the grounds of
Board of Appeal (Mount concerns from non-profit organisations that the new bingo could harm existing bingos run for the purpose of community fund raising.
Pearl), 1995 CanLII 9858
(NL CA).
R. v. Victor Jim, 1995 Victor Jim and Jack Sebastian assert an Aboriginal right to engage in and organise gaming activities subject only to regulation by Gitksan and
CanLII 1522 (BCCA); Wet’suwet’en law. Charged in 1988 in connection with organising an on-reserve bingo in BC without a provincial licence. Argue that the Criminal
[1996] 3 WWR 30 Code’s gaming provisions are not applicable as a result of ss.35(1) and ss.52 of the Constitution Act 1982, on Aboriginal rights to engage in
cultural and economic activities. Evidence given by two elders (both Wet’suwet’en Chiefs, one estimated at 100 years old) that bingo was widely
played and a crucial source of funds for community and charitable purposes. But bingo found to be not of profound Aboriginal cultural
significance. Held that there is no Aboriginal right in the constitution to operate or regulate gaming.
R. v. Bragdon, 1996 Charges brought against 6 people for keeping a common gaming house after police investigation of a bingo hall on Tobique Indian Reserve in
CanLII 4706 (NBCA); 183 New Brunswick. All 6 were employed in the hall. Held that the premises were controlled by the Tobique Indian Band (which was not charged),
NBR (2d) 329 and that the 6 lacked sufficient control over/management of the bingo hall to be deemed keepers.
R. v. Pamajewon, [1996] 2 Members of the Shawanaga First Nation and Eagle Lake First Nation convicted of keeping a common gaming house and conducting a lottery
SCR 821, 1996 CanLII scheme for their role in organising bingos and other gambling on reserve land.
161 (SCC)
The Shawanaga First Nation asserted an inherent right to self-government. The Eagle Lake First Nation asserted the right to be
self-regulating in its economic activities.
Court holds that evidence presented did not demonstrate that gambling, or the regulation thereof, was an integral part of the distinctive cultures
of the Shawanaga or Eagle Lake First Nations at the time of contact; nor that gambling played an important role in the cultures of the Shawanaga
and Eagle Lake First Nations.
Nanaimo Community As part of its introduction of electronic bingo, the BC government introduced a regulation dividing bingo proceeds between charities, for-profit
Bingo Assn. v. British bingo providers, and the province. Judge rules that BC’s Gaming Act did not authorise this regulation diverting charitable funds to the
Columbia (Attorney government, and that the Criminal Code prevents the government diverting the proceeds of charitable gaming authorised under s. 207 (1) (b) of
General, 1998 CanLII the Criminal Code to for-profit management companies. Declares the regulation invalid, and declares “that the Province of British Columbia
1192 (BCSC), 1998 cannot receive, or authorise or require “for-profit” companies to receive, the proceeds of gaming that is managed and conducted by charitable
CarswellBC 266 52 and religious organisations in British Columbia” (Owen-Flood at para 3). The government successfully appeal against the latter declaration (see
B.C.L.R. (3d) 284, [1999] Nanaimo Bingo v. British Columbia (Attorney General), [2000] BCCA 166)
2 W.W.R. 428
Nanaimo Immigrant A group of charitable and religious organisations seek a declaration that the licensing fees they paid to operate bingos in BC were invalid. 1987
Settlement Society v. changes to the gaming fees, and the expansion in gaming, meant that the revenues grew such that the share going to government far exceeded
British Columbia, 2004 the costs of the regulatory scheme. Charities wanted the fees repaid (with interest) on the basis of unjust enrichment, including on the grounds
CanLII 410 (BCCA). that the fees were illegal taxes imposed by regulation (any bill imposing a tax must originate in Parliament or the provincial legislature). Decisions
culminate in a ruling that the fees were legal taxes.
R. v. Gardner, 2004 Nancy Gardner and Harriet Shabaquay charged with unlawfully keeping a common gaming house and participating in a lottery scheme by
CarswellOnt 2308, 2004 means of a game of bingo at the First Nations Territory of Eagle Lake (Gardner) and First Nations Territory of Wabigoon Lake (Shabaquay).
ONCJ 69, 62 W.C.B. (2d) Evidence of 6 witnesses detailing extensive surveillance of both First Nations bingos by provincial and regional police, including via plain clothes
232 police observations and participation in bingos. Court confirms that bingo is a game of mixed skill and chance (not a lottery), but that the two
women “had some degree of control over the premises” (at para 37). They gave out prize money and sold tickets, were identified by others as in
AND
charge of the bingo, and Gardner was a keyholder to the cafeteria. Both women convicted of keeping a common gaming house.
R. v. Shabaquay, 2004
CanLII 68 (ONCJ)
Community Fundraising Lottery regulations in Newfoundland and Labrador permit a maximum $3,000 prize board to be won in any given bingo event. In Dec. 2003 Santa
Corp. v. Newfoundland Claus called two games of bingo – attended by c275 players – and spontaneously increased the prizes of two games (by $100, and $75), hereby
and Labrador exceeding the maximum. Provincial regulator concluded that the excess payout breached the regulations and was likely to reflect unfavourably
(Department of upon the integrity of the lotteries program. The Corporation’s bingo licence was suspended for one week, leading to a loss of gross revenue in
Government Services excess of $60,000. Judge holds that regulation wasn’t intended to apply to isolated breaches involving a small excess of prize money
and Lands), [2004] NLTD precipitated by a guest rogue caller. It was unreasonable for the regulator to believe that the violation triggered an application of the rule. Appeal
236 allowed.
Bingo City Games Inc. et Final case in a set of proceedings begun in 2003 by a company that owned a bingo facility used by a charitable association in Prince George
al v. B.C. Lottery Corp. et (BC). Business fails, in part because BCLC take over running the bingo in January 2002. The business is offered worse terms by the BCLC than
al, [2005] BCSC 25. the charity association had agreed to and a rival hall (also run by the BCLC) is allowed to extend its hours, increasing competition. Damages
claimed against both the provincial government and the BCLC. Court rejects all claims. Once it took over bingos BCLC owed no duty of care to
keep them open. Its new policy was to increase revenues, which entailed that it “weed out failing halls and inefficient bingo operators” (Rogers at
para. 223).

Case Brief summary
R. v. Weitzel, 2005 CanLII Lewis Weitzel (President of ALS Society of Alberta) convicted of paying bingo workers on behalf of the Society (contrary to the rules of Alberta’s
378 (ABPC) Gaming and Liquor Commission), by forging invoices showing inflated expenses for equipment used by the charity’s beneficiaries. The excess
was used to pay members of sports teams to work the ALS’ bingo slots. Testified that “there were always problems finding volunteers… the
efforts and resources of the family members of someone diagnosed with ALS were more preoccupied with the health of that family member, than
working a bingo” (para 32). The idea of paying for volunteers came from hockey and baseball teams also raising money via bingo. Practice was
widespread and others in the society knew of the scheme. Conditional sentence imposed
MJF v. JMF, [2006] ABQB Divorce case. Father worked at least 16 bingos a year (of 5-7 hours each) to keep daughter in swimming programme; was fined $100 for missing
189 a session.
Abbotsford Families City of Abbotsford (BC) pass zoning amendment bylaw in 2007 allowing a bingo hall to operate 125 slot machines and 192 personal play bingo
United v. Abbotsford machines. Challenged by a not-for-profit cooperation (with 1 member) established to defend and promote family values. Claims non-disclosure of
(City), 2009 CanLII 463 key information. The public debate about the zoning amendment was premised on an assumption that the hall owner would close the hall if slots
(BCSC) were not allowed, causing a loss of revenue to the city and local charities. City failed to disclosure letters from Solicitor General and his Assistant
Deputy Minister that there was no longer any direct relationship between the revenue that government earnt, via BCLC, at a bingo hall and the
grants given to hall affiliates. Held that City’s failure to disclose the letters did not constitute failure in its duty of procedural fairness: the petitioner
did not ask for them specifically, and the city is not obliged to disclose all information it receives.
2031012 Ontario Ltd. v. Corporation with exclusive rights to import and distribute a US-produced electronic game intends to install machines in bingo halls across
Canada, 2010 CanLII Canada; seeks a declaration that the game is legal in Ontario as a game of skill). If the game involves an element of chance it falls within the
2834 (ONSC) gambling prohibitions of the Criminal Code and would be illegal. Application is held to be premature and speculative; “this court should not be
placed in the position of determining in advance whether the game ‘Match em up’ would be legal in every conceivable circumstance” (at para.
12). But evidence suggests it is a game of mixed chance and skill.
Dow v. Dow, [2013] New Brunswick case. Distribution of assets of a 9 year marriage; wife gambled throughout, on Video Lottery Terminals and bingo. She says it was
NBQB 106, FDSJ-635- recreational. Husband says it was an addiction which wasted the family resources and was the eventual cause of the marriage breakup. Court
2012 finds that the wife “dissipated” (wasted, involving an element of bad faith or neglect) the family’s resources because of gambling addiction, to
such an extent that there should be an unequal division of the home.
Amyotrophic Lateral Proceedings initiated in 2008 by a group of charities (including a minor hockey association and a country dance troupe) against cities of Windsor
Sclerosis Society of and Tecumseh, in Ontario, to get a certification of class action claiming that charitable lottery licensing and administration fees collected by the
Essex v. Windsor (City), municipalities were direct taxes and therefore outside the powers of the city because the revenues far exceeded the costs of administration. In
[2015] ONCA 572 this specific case, the cities objected to the time scale of the class action (going back to 1990). Judges amend the class action certification to
use a 15 year ultimate limitation period. Proceedings are on-going.
Merpaw v. Hyde, [2015] Significance of bingo play to a claim regarding a woman who alleges inability to work, and seeks damages, following a fall. Ontario court orders
ONSC 1053 the disclosure of the contents of her casino card for the Akwesasne Mohawk Casino (located in a First Nations reservation in New York state,
USA), where she says she plays mainly bingo, and authorises the Akwesasne Casino to disclose all records of her visits, and money spent and
won, between 2004 and 2014. Ability to stay focused during play “may indicate workplace capacity in the form of focus, concentration, reason
and ability to stay on task” (Leroy at para. 59).
CHAPTER 3: REGULATION OF LAND-

BASED BINGO IN ENGLAND AND WALES
Teresa, Pauline, and Mary, regular bingo players in a Kent bingo hall. Photograph taken by Andrea Shieber.
operators had more freedom to decide how they Non-profit making bingo operators include ex-
Kate: What was bingo like when you first could best comply with standards laid down by services clubs, miners’ welfare institutes,
started working in it? the new national regulator, the Gambling politically-affiliated clubs; working men’s clubs;
Commission. non-profit making sports and social clubs; village
Interviewee: Amazing. Absolutely amazing.
halls; community centres; and churches.
I would have worked for nothing. I
The licensing principles of the Act are threefold: Proceeds are donated or used for the benefit of
absolutely loved it. It just opened your eyes
members. When bingo was first legally enabled in
to a whole new life. (male, commercial 1 preventing gambling from being a source of Great Britain, in 1934 via the Betting and Gaming
bingo hall manager, Wales) crime or disorder, being associated with crime Act and then more explicitly in 1956 via the Small
or disorder, or being used to support crime, Lotteries and Gaming Act, legislators intended to
2 ensuring that gambling is conducted in a fair support these sorts of activities.
and open way, and
Part 1: Current regulation 3 protecting children and other vulnerable Bingo can be run – without a licence – to raise
Gambling regulation in Great Britain is driven by persons from being harmed or exploited by money for a good cause, so long as the players
gambling. are informed where the money is going and all
the Gambling Act 2005 (the Act). This aimed to
modernise gambling regulation, reflecting a New the money raised is donated to the good cause
The Act covers both commercial and non- (minus reasonable costs for organising the event).
Labour desire to encourage the leisure sector as
commercial bingo operations. If played for cash prizes (to a maximum of £600
a crucial part of the UK economy. It replaced a
in any event), participation fees of up to £8 can
law and policy approach characterised by a Commercial bingo operators include traditional be charged. They must be donated.
reluctant tolerance of gambling. The 1968 Betting bingo halls, seaside bingo arcades, holiday
and Gaming Act, which reflected that earlier parks, commercial sports and social clubs, and
approach, employed a prescriptive, ‘command adult gaming centres. These require an operating
and control’-style of regulation in which operators licence for the company and a personal licence
had little flexibility in interpreting rules and for key staff, both issued by the Gambling
procedures. The 2005 Gambling Act aimed to Commission. They also require a premises
move to a more self-regulatory approach, where licence from the relevant local authority.
CHAPTER 3: REGULATION OF LAND-BASED

BINGO IN ENGLAND AND WALES
Bingo stakes and participation fees Scale of play and bingo

Under the 2005 Act, all operators (commercial demographics
and non-commercial) offering bingo with
aggregate stakes or prizes of over £2,000 in any “The one thing I would dispel is the idea that
seven day period must hold an operating licence it is a dead product: there are still 2.5 million
from the Gambling Commission. Bingo games regular bingo players in the UK and they
are allowed in pubs, members’ clubs, miners’ deserve our support.” (Neil Goulden, Gala
welfare institutes and commercial clubs (where Bingo, testifying to the Parliamentary
proceeds can be taken as profit) without an committee investigating the impact of the
operating licence, so long as they do not exceed Gambling Act (2005), 25 Oct 2011).
the £2000 threshold or involve links with other
premises. Members’ clubs (commercial and non- “The foundations of the Legion is bingo, no
commercial) and miners’ welfare institutes can matter where you go” (male bingo organiser,
charge limited participation fees of £1 per person North of England).
per day. Pubs can not charge participation fees.
To charge higher participation fees, of up to £3

per person per day, members’ clubs and miners’ Land-based bingo in England and Wales is
welfare institutes require a local authority permit. especially popular with older, working class
To qualify for a club gaming permit, members’ women. The 2001 Budd report on gambling, a
clubs must be genuine members’ clubs, with consultation that laid the groundwork for the legal
participation in gaming restricted to members reforms in the 2005 Act, found that “of all the
and their bona fide guests but open to them all. gambling types surveyed, playing bingo was
The rules around this are extensive. The Act lays most closely related to social class, ranging from
out minimum numbers of members required to 3% in Social Class I to 20% in Social Class V.”2
establish a members’ club and waiting periods to According to the most recent comprehensive
play, and the Gambling Commission has offered Gambling Prevalence Survey, in 2010:
guidance to local authorities on determining • 9% of people played bingo in the past 12
whether a club is a genuine members’ club, and months, 12% of women and 6% of men.
whether there is ‘’substantial evidence of Although this includes bingo played ‘in club’
activities other than gaming.” 1 Clubs can only be (land-based) and online, the prevalence for
established for gaming if established for whist or playing bingo online was then very low, at
bridge, a long-standing class-based distinction under 1%.
that continues to impact bingo. • Participation was highest in Scotland (12%),
the North East of England, and Wales (both
10%), and lowest in London (5%).
By law all the stakes in cash bingo must be • The percentage of people who had played in-
returned to players as prizes, since as an club bingo in the last 12 months has remained
equal chance game bingo cannot involve steady over the last 3 gambling prevalence
staking against the house. Players’ surveys (7% in 1999 and 2007, and 8% in
payments must be divided transparently 2010). But the percentage of people who had
between stakes (all of which are returned in played in the last week was down: 4% in 1999;
prizes), or participation fees. Prize bingo 3% in 2007; 2% in 2010. In 2010 54% of bingo
(involving goods such as kitchen utensils, players played once a month or more.
toys, or vouchers) involves no stakes, since • Prevalence was highest among the oldest
the prize is not determined by the number (75+) (11%) and youngest age groups (16-24)
of people playing or the amount paid for the (10%).
game. • “Bingo was the only activity where participation
was highest among those who were widowed.
13% of those who were widowed had played
bingo in the past year compared with 8% of
those who were single.” [Prevalence Survey
2010, 39]
1 Gambling Commission. 2012. Guidance to Licensing Authorities, 138.

2 The Gambling Review report. 2001, 41.
Number of Licensed Bingo Premises in Great Britain (1970

- 2015)
Source: Gambing
Table 1: Number of licensed bingo premises Board and Gambling Commission annual reports
Source: Gaming Board and Gambling Commission annual reports
Number
2000
1800
1600
1400
1200
1000
800
600
400
200
0
Money staked on licensed

Year bingo (1976 to 2015)
Table 2: Money staked on licensed bingo (amount in £million) £ million
Source: Gaming Board and HMRC reports
Money Staked (£m)
2000
1800
1600
1400
1200
1000
800
600
400
200
0
77
79
81
83
85
87
89
91
93
95
97
99
01
03
05
07
09
11
76
78
80
82
84
86
88
90
92
94
96
98
00
02
04
06
08
10
12
13
14
15
19
19
19
19
19
19
19
19
19
19
19
19
19
19
19
19
19
19
19
19
19
19
19
19
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
Year
Bingo Duty
HMRCPaid (1976 - 2015)
Table 3: Bingo duty paid
Sources: Gaming Board (1969-1985) and (1986-2015) reports
Duty Paid (£mn)

140
120
100
80
60
40
20
0
19 6
19 7
19 1
19 2
19 6
19 7
19 1
19 2
19 6
19 7
20 1
20 2
20 6
20 7
20 1
20 2
19 8
19 9
19 0
19 3
19 4
19 5
19 8
19 9
19 0
19 3
19 4
19 5
98
20 9
20 0
20 3
20 4
20 5
20 8
20 9
20 0
20 3
20 4
15
7
7
8
8
8
8
0
0
7
7
8
8
8
8
8
8
9
9
9
9
9
9
9
0
0
9
0
1
1
0
0
0
0
1
1
1
19
19
Calendar Year

A 2014 report, using 2012 health survey data, the main stage bingo game ticket price, or from 52 non-commercial operators (out of 200
confirmed that land-based bingo remains sides games and machines played in intervals. operators in total) hold an active operating
distinctive in its popularity among working class From October 2014 to September 2015 gaming licence from the Gambling Commission, enabling
women: “Men tended to be more likely than machine revenue accounted for 46% of gross them to offer bingo with aggregate stakes or
women to take part in most activities and to have gaming yield in licensed bingo facilities. prizes over £2,000 in any seven day period. They
a larger gambling activity repertoire than women. include groups such as the Boldon Colliery and
The exceptions to this are bingo, with men being There is poor data on the scale of non- North Road Social Club and Institute; Skegness
less likely to participate than women (3% and commercial bingo in the UK. Most bingo Working Men’s Club & Institute, Leicester
7% respectively); and scratchcards and other fundraising does not require a licence, and most Railwaymen’s Club; Morfa Social & Athletic Club,
lotteries, with men and women being equally likely providers of bingo in members’ clubs require Yardley Ex Servicemen’s Club, Nottingham
to participate.”3 2% of those whose highest neither an operating licence nor a local authority Imperial Order Of Oddfellows Club & Institute,
educational qualification was a degree or higher permit. However our research shows that non- and the Pennywell Comrades Social Club &
played land-based bingo compared with 8% of commercial bingo is in decline, with falling Institute.
those with no qualifications.4 attendance and loss of institutional memory
about how to organise games. The number of Although participation fees can be charged to
There are currently 615 licensed bingo premises new club gaming permits issued by local play, money is rarely made from bingo in
in the UK, the overwhelming majority of which are authorities – required for higher participation fees members’ clubs like these. Sometimes operators
profit-making businesses. However commercial to be charged for bingo games – is at a 5 year benefit in additional food or drink sales, or
bingo has been in decline in Great Britain when low. In one part of South Wales visited for separate admission fees to see a performer in
measured by the number of licensed clubs, the fieldwork there had been 400 working men’s the interval between games. But frequently the
duty paid to government, and the money staked. clubs attached to the regional branch in the surplus generated is described in non-monetary
The smoking ban, implemented in 2007, had a 1980s. Most of those were thought by local terms. As one male volunteer in an ex-services
particularly significant impact on attendance. experts to have offered bingo. In May 2014 there club in the North West of England put it:
‘we’re just having a laugh, really. It’s a bit of fun.

were 116 clubs left, and many of those were in
Given that all stakes in cash bingo have to be
It’s providing a service. It is not like big bingo
danger of closing. Most still offered bingo.
returned to players as prizes, commercial bingo
halls make money from participation fees built into halls. It’s about meeting friends, comradeship,
friendship.’
Control panel used by bingo callers, Kent. Image taken by Andrea Shieber.
3 Wardle et al. 2014. Gambling Behavior in England and Scotland, (Gambling Commission), p 2, emphasis added.
4 Ibid. p 23.
Gross Gaming Yield for Bingo Games and

Gaming Machines in Bingo Premises as a
percentage of revenue
Table 4: Gross Gaming Yield (GGY) for bingo games and gaming machines in licensed bingo premises
Sources: Gaming Board (1969-1985) and HMRC (1986-2015) reports
Percentage
100%
80%
60%
40%
20%
0%
2008/09 2009/10 2010/11 2011/12 2012/13 2013/14 2014/15
Year
Main Stage Bingo Mechanised Bingo Prize Bingo Gaming Machines
Table 5: Number of new club gaming permits

issued by local authorities, 2010-15.
Source: Licensing Authority Statistics 2010-15, Gambling
Commission.
Year Club Gaming Permit

2009-10 179
2010-11 265
2011-12 190
2012-13 100
2013-14 64
2014-15 44
Table 6: Average Number of Gaming Permits/Notices
issued by Local Licensing Authorities submitting
returns.
Table 6: Average number of gaming permits/notices issued by local licensing authorities submitting returns.
Source: Licensing Authority Statistics 2010-15, Gambling Commission.
Average number issued

40
35
30
25
20
15
10
5
0
Apr 2010-Mar Apr 2011-Mar Apr 2012-Mar Apr 2013-Mar Apr 2014-Mar
2011 2012 2013 2014 2015
Year

Key themes When bingo was first mentioned in parliament in Commercial operators at that time included
1936, it was by an MP seeking to liberalise hours showmen who offered bingo in travelling fairs,
Theme 1: The shifting attitudes of for working men’s clubs. In the 1950s, when and the holiday camp pioneer Billy Butlin. They
lawmakers and the declining visibility of concentrated attention was paid in parliament to appear in the parliamentary record mostly as part
the non-commercial sector bingo for the first time, lawmakers regarded the of complaints by advocates of working men’s
game positively due to its connection to the clubs about the unfairness of police toleration for
Bingo has always had great cross party support, military (where it was widely played by soldiers commercial play when contrasted with occasional
which is partly why I think the duty change was and sailors), political parties (where it was used raids on members’ club spaces.
successful. (male commecial bingo operator, to fundraise), and working men’s clubs (where it
England) supported member activities and good works Commercial bingo subsequently exploded in
within the community, such as taking children on Great Britain under a loophole in the 1960 Betting
holiday). Lawmakers from both parties were keen and Gaming Act allowing profit-making clubs to
to show their support for working men’s clubs in conduct equal chance gaming and to charge for
particular, since the club movement had links to entry. It provoked a backlash. Commercial bingo
many MPs. survived the subsequent crackdown on gambling
enshrined in the 1968 Betting and Gaming Act
Changing atitudes to bingo (1936-1995): Extracts from the Hansard Record

NB: in these examples housey is a synonym for bingo.
Commander Bower, speaking in favour of a “Is the Home Secretary aware that the game is “By limiting the amount of the prize to such an
measure to amend licensing hours for working a traditional pastime of the British Army, that absurdly low sum the Home Secretary is taking
men’s clubs: “The bona fide clubs… are a very under the name of tombola it is played in the “go” out of bingo. He is taking a lot of
great asset in the social life of the country. (An certain seaside holiday camps whose excitement and zip out of it….When the linked
MP opposed to the reform) could come to my brochures advertise it..., and that under the game comes up there is an intensification of the
constituency and visit one or two of the name of either tombola or bingo it is played in atmosphere, an excitement which I do not
working men’s clubs in which I spend a good the most fashionable London clubs? Why consider harmful…. I have seen old people
deal of my time. He could have a game of should there be discrimination against enjoying themselves, and I wonder what they
billiards or darts, or backgammon, listen to the Lancashire clubs? Is it not time the law was would be doing if they were not in a bingo hall
wireless or read the newspapers, or he might amended to legalise this innocent pastime? with other people. They would probably be at
even indulge in a surreptitious game of (HC Deb 14 July 1955, vol 543, col. 2101-1). home before their television sets, perhaps fast
“Housey-Housey”. The drinking is moderate asleep and utterly lonely…They are enjoying
and quite ancillary to the ordinary activities of “We have all broken the law. For example, themselves there in a social atmosphere and I do
the club …(Clubs) are a great boon to the “housey-housey” is played on every troopship not see that that is a great evil.” (Mr Buck HC Deb
unemployed man... There are many of these leaving this country and coming back. It is 11 June 1968, vol 766, col. 138-9).
men in my constituency, and it is pathetic to played in my constituency at fetes organised
see the shifts they will employ in order to be by ex-Service men who probably learnt the “Bingo is – or should be – a relatively harmless
able to pay their club subscription, and be able game while in the Army.” (Major H Legge- form of gaming of a sociable and neighbourly
to go along to these social centres and feel Bourke HC Deb 25th Nov 1955, vol 546, col. kind…Provided it is kept within proper bounds we
themselves on terms of equality with their more 1858). have no wish to harass it unduly” (Lord Stonham
fortunate brethren who are working.” (HC Deb HL Deb 29 June 1968, vol 293, col. 854-5).
6 March 1936, vol 309, col. 1710.). “Bingo, in its modern form, is a highly
commercialised and greatly exploited type of “(Linked bingo) is the negation of what bingo was
Mr Boardman asked how many people had gaming….It is becoming another form of drug originally conceived to be, which is a friendly,
been prosecuted in Lancashire during 1955 for addiction… In one form or another bingo is modest, intimate neighbourly game. You cannot
playing housey-housey in social clubs. The being played all the time. One cannot have a call it a game when there are perhaps 5 million
answer was 115. sandwich or drink without some form of bingo people up and down the country just drawing a
being on top of one. If one goes for a tour in number. That is not a game.” (Lord Stonham HL
the country, bingo is played on the train. It is all Deb 29 June 1968, vol 293, col. 901-902).
a commercial operation run to make profit” (Mr
Blenkinsop HC Deb 11 June 1968, vol 766, col.
63).
(unlike most casinos), but only within strict limits. The sense that bingo provides a safe, respectable “Bingo is a brilliant way to bring people together
For example there were to be no linked games, outlet for elderly working class women’s leisure – for a bit of old fashioned community fun. Why
and almost no advertising. a framing seen since bingo was first explicitly can’t we encourage more bingo nights on our high
debated in the 1950s – remains. Now bingo halls streets?” (Mary Portas, The Portas Review: An
Whereas commercial bingo survived in the 1960s are contrasted with betting shops, pay day independent review into the future of our high
on the grounds that it was seen by most lenders, and pawn shops as sites of sociality, streets p.46)
lawmakers to be a social, family game, offering community, and harmless fun. The Mary Portas
harmless fun and entertainment, in the 1980s the review on high street regeneration actively The positive attitudes held by lawmakers towards
perceived benefits of commercial bingo became promotes them. In 2014 the Chancellor commercial bingo are in part the result of
also economic: tax revenue; employment; well-run announced a 10% duty cut on commercial bingo effective lobbying. Industry involvement in
businesses; and sites that attract tourists in – double what the industry had requested. debates about land-based regulation is well-
seaside towns. By the mid 1990s, commercial institutionalised. The Bingo Association, the trade
bingo was seen positively by politicians of all association for land-based commercial operations
parties, both for economic and social reasons, in Great Britain, takes a proactive role in lobbying
and it was regarded as a favourable site for around taxation, and regulatory reform.
deregulation.
Changing atitudes to bingo (1936-1995): Extracts from the Hansard Record (continued)
“It always amazes me when I hear people talking “People who go to bingo halls are working- “The bingo industry is declining. There is no
about spending family allowances on beer and class men and women and old-age cause or call for the Government to support it.
bingo, because it is a lot of nonsense. It may be pensioners. One does not have to hire a top However, by the same token there is no reason
true that a father and mother will have a drink of hat or tails to go to bingo halls, or wear for its survival to be impeded by unnecessary
beer and may even play bingo. But is it floppy hats as women do at some of the restrictions” (Viscount Montgomery of
suggested that the father and mother of a family racecourses, such as Ascot. Those who Alamein HL Deb 25 March 1991, vol. 527, col.
in receipt of family allowances should not be play bingo are miners’ wives, not 918).
entitled to have a drink of beer or play bingo? It millionaires’ wives; shipbuilders’ wives, not
really is a nonsense” (Mr Loughlin HC Dec 2 April shipowners’ wives.” (Mr Dixon speaking John Whittingdale, then a new MP, speaking
1968, vol. 762, col. 147). against an increase in bingo duty, HC Deb of his visit to a new-build bingo club:
6 July 1981, vol. 8, col. 187-8). “A bingo club now is not only a gambling hall;
“Are we acting wisely in encouraging a kind of it is a leisure centre where people can meet,
“Unless the changed circumstances of today,
Bingo, lounge bar society—the kind of society in talk, enjoy a drink, have a meal and generally
compared with 1968, are taken into account the
which people feel that they can get things without have a fun and sociable afternoon or evening
survival of this form of recreation is truly in peril.
making substantial contributions?” (Lord Taylor of of activity. In addition, clubs often fulfil a more
The word “peril” may seem an emotional and
Gryfe HL Deb 18 February 1970, vol. 307, cc general social role as places where elderly
dramatic one to use in connection with the
1221). people can go during the day to enjoy a
game of bingo, which we sometimes laugh at
cheap meal, have a bit of fun and chat with
and pass off but it is a form of recreation which
“Many people would rather spend their hard- friends in a warm, safe environment…The
means a great deal to many people…This is not
earned money on subscriptions to BUPA18 so that industry is falling into decline, which can be
an inconsiderable industry. It provides 52 million
they are given medical care when they require it halted only by deregulation that will allow it to
a year to the Exchequer; it provides jobs and a
rather than spend that money on drink or bingo. In compete on a basis equal to that of its main
living for tens of thousands of staff; and it
a free country why should they not have this competitors while it is still in good enough
provides recreation for 13.5 per cent. of the
choice?” (Mrs Knight HC Deb 27 April 1976, vol. shape to take advantage of a level playing
adult population of Britain.” (Lord Harmar-
910, col. 287). field. The Government have rightly
Nicholls HL Deb 4 May 1983, vol. 442, cc.148).
championed competition and deregulation.
“If it were not for bingo our elderly people would No industry is more deserving of the chance
“Some of my constituents enjoy bingo. What
have no social life.” (Mr Roberts HC Deb 29 Oct to enjoy the benefits of those policies than the
about subsidising bingo for ordinary people? It
1979, vol 915, col 840). bingo industry” (HC Deb 11 May 1995, vol.
is an art form for them in the same way that
259, col. 965).
watching and listening to a fat Italian singing in
“We are not interested in the extension of bingo
his own language, dressed like a woman, is an
halls and ferris wheels. We are interested in the
art form. As far as I am concerned, there is no
creation of proper jobs and opportunities for
difference.” (Mr Dicks HC Deb 20 May 1988,
employing our young people and renewing a
vol. 133, col. 1236).
dying industrial situation.” (Mrs Dynwoody HC
Deb 21 April 1980, vol. 983, col. 87).
18 The British United Provident Association, a company providing private medical insurance.

By contrast, non-commercial bingo is now barely In 2009 the Gambling Commission issued a
mentioned by lawmakers in debates about the document on ‘key characteristics of bingo’,
sector. Club associations did not give oral intended to help clarify the game’s boundaries.7
evidence to the 2013 parliamentary committee This focused on stakes and participation fees in
investigating whether the Gambling Act 2005 was bingo machines. Most recently, in 2014 the
‘a bet worth taking,’ for example. This is in part Commission published a guidance note on What
because working class associations have far constitutes bingo.8 This guidance is intended “to
weaker links to lawmakers than in the past. help bingo operators avoid creating and offering
products that we consider to be casino games,
Theme 2: The challenge of defining lotteries or fixed odds betting” (s.1.1). It identifies
the game: The importance of game 3 fundamental principles of bingo: that the game
mechanics and environment is an equal chance game; that it must involve a
degree of participation, and that it must have a
In a key sign of its perceived nature as an clearly defined end point (s. 3.3).
‘everyday’ gambling form, the Gambling
Commission describes bingo as “the only form of Most commercial operators we interviewed
gambling recognised in the Gambling Act 2005 welcomed this guidance, with some seeing profit
that does not have a specific statutory definition, potential in more automated forms of the game
the Act providing simply that ‘bingo’ means ‘any that resemble electronic lotteries. However one
version of that game, irrespective of by what industry insider contended that any game
name it is described.’5 In contrast the legislation definition could be reversed by the Commission in
provides definitions for betting, casino, draw, the absence of a statutory definition, leading to
horse race pool betting, lottery ticket, lottery, prize uncertainty in product development.
gaming, football pools, gaming, and gambling.
As our table of key bingo cases shows, the Membership and gambling in pubs
definition of the game has long been contested.6 Historically membership differentiated the
In fact the issue of whether bingo should have a illegality of gambling in pubs, to which the
statutory definition was debated by the 1977 public has access, from the legality of some
Rothschild commission on gambling. This was in gambling in some members’ clubs, seen as
response to what the Gaming Board (the then private spaces. In the 1968 Betting and
national regulator of bingo) considered Gaming Act the rules governing commercial
objectionable game innovations where high bingo halls were modelled on those for
participation fees were being charged to players. clubs, and so membership was crucial.
However the issue of the game’s boundaries is Under the 2005 Act membership was
especially significant now. In part because bingo scrapped as a statutory requirement for
premises licences offer access to lucrative commercial bingo halls (even though the
games machines entitlements – including up to industry wanted to keep it). Membership still
20% of the total gaming machines being B3 matters for non-commercial clubs, though.
machines (with a £2 stake and £500 prize) – and From that point – when membership was no
in part because bingo machines are explicitly longer a key part of the definition of bingo
defined by the 2005 Act as not gaming machines in both commercial and non-commercial
(meaning that they do not count towards the sectors – the issue of gambling in pubs was
quota of total machines allowed on a premises) destined to re-emerge, because
there has been an attempted expansion in the membership had been such a key part of
type of operators and premises offering bingo. what had stopped higher-stakes bingo from
Some operators have developed new, variant being in pubs in the first place.
forms of bingo, often called electronically, and not
requiring players to stop the game by shouting
out. Membership has also been removed as a Our research suggests that a definition of the
criteria for commercial bingo operators, meaning game focused solely on its mechanics will not
that bingo has expanded into non-member resolve the regulatory challenges facing the
environments such as adult gaming centres. sector, because it ignores the key issue of place.
As a result there has been a growing need for ‘Going to the bingo’ refers both to a premises,
regulators to rule on boundary disputes between and to a game played in that premises. Bingo
bingo and other forms of gaming. premises licensing is largely a matter for local
5 Gambling Commission. (2014). What constitutes bingo? (London: Statioeary Office), s.1.1; quoting s. 363 of the Gambling Act 2005.
6 See for example Rogers v Cowley [1962] 1 WLR 770 (HL); Adcock v Wilson [1968] 2 WLR 914 (HL); and Walker v Leeds, Greenwich and Lewisham [1976] 3 WLR 736 (HL).
7 Gambling Commission. (2009). Key characteristics of bingo. (London: Stationery Office).
8 Gambling Commission. (2014). What constitutes bingo? (London: Stationery Office).
authorities, with the national-level Gambling The regulatory concern with the suitability of (defined as “gambling to a degree that
Commission focusing on operator suitability. The operators, and the suitability of the premises compromises, disrupts or damages family,
2005 Act gives little discretion to local authorities within which they plan to offer bingo, is key to the personal or recreational pursuits”11) and on
on gambling premises licensing (other than for current debate over whether licensed bingo ‘at-risk’ gambling behavior.12 The latter includes
casinos). The expectation is that they will grant a should be allowed in pubs. Pubs can already run people who could be considered ‘at-risk’ of
licence if the core licensing objectives are low-stakes bingo, subject to conditions: there are experiencing negative consequences from
fulfilled. Unlike with alcohol licensing (under the no participation fees allowed, and stakes are gambling, and/or who may be at risk of
2003 Licensing Act) there is no authority to limited to £5 per person per game. But if able to developing problems in the future, but who are
restrict based on concerns about clustering or offer licensed bingo pubs could run games with below the threshold for problem gambling.
proliferation. This inability to restrict has been higher stakes and prizes, with links, and –
criticised by some MPs and anti-gambling crucially – with the entitlement to higher stakes A key operational challenge in law and policy
organisations, but in relation to the perceived gaming machines. In a recent legal case, the around harm prevention in gambling is over
growth in betting shops rather than bingo halls. Gambling Commission had its authority to deny where to the strike the balance between a
an operator licence to a pub chain upheld based standardised approach across all gambling
The Gambling Commission have sought to shape on concerns about the environment within which sectors, versus distinctive approaches to
local authority decision making about premises it sought to offer the game.9 distinctive sectors which may have varying harm
licensing, especially through the concept of potential. For example, according to 2012 health
‘primary gambling activity.’ This intends to Theme 3: Risky play and the survey data the highest overall prevalence of ‘at-
address two concerns: keeping gambling largely risk’ gambling was observed among those who
increasing formalisation of harm
within establishments focused on gambling (a key participated in spread-betting, gambling on
prevention
concern of lawmakers in debates leading up to machines in bookmakers, and betting exchanges.
the 2005 Act), and ensuring that a premises Much has been written on the growing centrality
seeking a licence for one form of gambling in fact of medical models of risk and harm to gambling The challenge for bingo specifically is that while
intends to focus its operations on that form, rather law and policy.10 In the UK, regulatory attention is it has comparatively low levels of problem
than using the licence as a ‘flag of convenience’ increasingly focused on problem gambling gambling they almost always relate to the
to offer other, harder gambling forms. ancillary product (gambling machines) rather
9 Gambling Commission v Greene King [2016] UKUT 0050 (AAC)

10 See, especially, G. Reith. 2007. Gambling and the Contradictions of Consumption: A Genealogy of the ‘Pathological’ Subject. American Behavioral Scientist
51(1): 33–55; F. Nicoll. 2012. Bad habits: Discourses of addiction and the racial politics of intervention. Griffith Law Review 21(1): 164–189; R. Cassidy, C
Loussouarn and A Pisac. 2013. Fair Game: Producing Gambling Research (The Goldsmith report). London: Goldsmiths.
11 Wardle et al. 2014. Gambling Behaviour in England and Scotland, p 101.
12 Wardle et al. 2014. Gambling Behaviour in England and Scotland, p 97.

than the core offering (main stage bingo). Side That said, most hall managers had encountered responsibility codes require licensed bingo
products – including gambling machines and customers who, in their view, gambled too much. operators to put in place measures for sector-
games played in intervals between traditional There had long been mechanisms for dealing wide self-exclusion (where individuals who
bingo games – are central to revenue in the with this, including ‘having a chat;’ calling up request to be excluded from a licensed bingo
commercial sector. Almost unanimously, when family members; telling someone to go home or premises are subsequently excluded from
we asked interviewees from the licensed sector to only come in with a group of family or friends; licensed bingo facilities run by other operators),
about problem gambling in bingo they said that barring someone from the premises as a whole, and for ‘customer interaction.’ This requires staff
it was rare, and that it was normally relevant to or from the machine section; refusing to serve to identify and intervene effectively “where they
machines. That is supported by the latest data on alcohol to someone with a gambling problem; have concerns that a customer’s behaviour may
problem gambling rates across different sectors and ‘letting someone know you are keeping an indicate harm (or risk of harm) as a result of their
from the 2010 Gambling Prevalence Study. eye.’ gambling behavior” (3.4.1). Customers exhibiting
agitation, distress, or aggression are mentioned
Some commercial operators felt that there were These mechanisms are being eclipsed by more as targets for customer interaction, but the
several features of bingo’s distinctiveness that formalised measures laid out in the Gambling Commission also note that:
made it relatively low risk. These included the fact Commission’s Licensing Conditions and Codes of
that the game is popular with older women Practice (LCCP), to which all licensed operators “behaviour that is normal for one individual (eg
(younger people, and men, are more likely to be must adhere. There are two types of code behaviour that might reflect a well-controlled
at-risk gamblers according to the 2012 health provision in the LCCP. Ordinary codes set out leisure experience) might, in another individual,
surveys13); the social nature of the game and the good practice. Social responsibility codes relate be indicative of gambling related harm… For
fact that groups of friends or family often came to ensuring that gambling is conducted in a fair these reasons, the Commission considers that it
together; the close bond between players and and open way; protecting children and other is important to include a code provision that
staff in traditional hall environments (leading, vulnerable persons from being harmed or requires operators to put in place provisions to
some argue, to better monitoring of potential exploited by gambling; and making assistance identify those customers potentially at risk of
gambling problems); the nature of the traditional, available to persons who are or may be affected gambling-related harm, whether or not they are
paper-based main stage game itself (involving by problems related to gambling. Compliance displaying obvious signs of, or overt, behaviour
time-bound, sessional play and built-in breaks, with these codes is a condition of operator associated with problem gambling.”15
and where stakes are limited by the physical licences. A breach may result in a review of the
capacity of the player to mark off tickets); and the licence (and suspension or revocation), In the light of such guidance, some staff we
fact that not all players regard the game as a form imposition of a fine, and/or prosecution. interviewed were anxious about being held
of gambling. responsible for identifying problematic gambling
At first preventing under-age gambling was the behaviour.
key concern of the social responsibility codes.
However in 2015 a revision was undertaken that
made problem gambling far more central to the
regulations.14 For example the new social
Prevalence of problem gambling among those who Total number of gaming machines in
Table 7: Prevalence
reported thatof problem gambling
they took part among those who
in different reported that they
gambling Table 8: Total number of gambling machines in licensed bingo clubs
took part in different gambling activities on a regular (at least monthly) basis. Bingo Clubs
Source: Gaming Board and Gambling Commission Annual Reports.
Source: 2010ac vi esPrevalence
Gambling on a regular (at least
Survey p95-96. monthly) basis.
Number of gaming machines
Percentage 60,000
25
50,000
20 40,000
15 30,000
10 20,000
5 10,000
0 0
Poker in a Bet on Dog races Online slot Casino games Bingo
Club/Pub machine-style
games Year
Type of Gambling
13 Wardle et al. 2014. Gambling Behaviour in England and Scotland, p 2-3.

14 Gambling Commission. 2015. Strengthening social responsibility: Amendments to the social responsibility provisions in the licence conditions and codes of
practice (LCCP) for all operators. (London: Stationery Office).
practice (LCCP) for all operators p 43 (London: Stationery Office).
Recommendations specific to the 2 Consider testing partial self-exclusion for the ‘pink card’ and the police-style model of
England and Wales case study with willing operators regulation it represented (see text box overleaf). It
Some interviewees from the commercial sector has been a challenge for some – especially
1 Involve non-commercial bingo operators
wondered whether partial self-exclusion might be smaller companies without large compliance
more systematically into debates about
a way forward for bingo halls seeking to respond departments – to resource to self-regulation, and
gambling regulation
to the new policy emphasis on responsible to keep up with frequent consultations on
Non-commercial bingo remains a significant part proposed rule changes.
gambling. In their experience, some players had
of the sector, and operators have accumulated
been reluctant to request self-exclusion from a
considerable expertise, over a lengthy period. One recent manifestation of this challenge
bingo facility, even if they had experienced
Since non-commercial bingo is largely self- concerns the growing emphasis on social
problems with their gambling, since typically they
regulated, with most operators exempt from responsibility in the licensing codes. There is
understood their problem to involve gaming
licensing and permits, it is rarely on the radar some anxiety among staff about making mistakes
machines. Excluding from the bingo club as a
for local licensing authorities or the Gambling that will result in serious consequences (fears
whole would cut them off from a key social outlet,
Commission. While it is not a concern in terms of range from losing their jobs to being prosecuted).
where they tended to see friends and family and
compliance, we suggest that more systematic
experience community. Partial self-exclusion
involvement of representatives from the non- Bingo is widely recognised, across our interviews,
would enable them to exclude from a specific
commercial sector will be of benefit. to be a compliant sector, enjoying generally
product (usually gaming machines).
positive attitudes from lawmakers and generally
On a general level, better consultation with the positive relationships with regulators. If these
The Gambling Commission consulted on partial
non-commercial sector will serve as a reminder – anxieties are being raised by bingo staff, we
self-exclusion by product in 2015, but decided
to regulators and all of us who are interested in suspect that they are relevant more widely.
against introducing it due to lack of evidence.
gambling – that a lot of gambling is, and always
There were also objections raised by gambling
has been, run on a not for profit, or mutual aid In turn the Gambling Commission has increased
treatment providers on the grounds that it would
basis, as an ancillary activity in places primarily its emphasis on effective training as part of a
not address the root cause of the harms being
used for other purposes. company’s responsibility.
experienced by problem gamblers, and that “self-
On a more specific level, some rule changes exclusion should be about the total cessation from In the 2015 consultation on the new LCCP, one
suggested by our interviewees could be all forms of gambling.”16 However the operator suggested that the Commission could
accommodated without endangering the Commission committed to continue monitoring create a staff training accreditation scheme in
principles of the Gambling Act. For example, the evidence on the matter. order to instil good practice in the area of training
participation in gaming in members’ clubs is for self-exclusion.17 This was rejected as out of
In our view commercial bingo clubs are an
restricted to members and their bona fide guests, step with the emphasis on self-regulation.
excellent site on which to develop such evidence.
but it must be open to them all. If a portion of the
They are primarily social gambling spaces, with If key elements of social responsibility are to be
stakes of regular players are rolled over, into
low levels of problem gambling associated with downloaded onto staff who work in gambling
accumulating jackpots (‘snowballs’) clubs are
specific products. Those products tend to be facilities then we suggest independent verification
supposed to allow a guest – often someone
separated off from the main stage bingo floor, of the quality of training, and sector-specific
signed in just for the evening – to play for the
allowing partial self-exclusion to be more easily compliance knowledge. We recommend that
prize. It seemed unfair to some for an outsider to
monitored than in other gaming venues. If – as regulators consider attaching a mechanism to
have the chance to win a large, equal chance
we were told – some customers had requested test expertise to the grant of a personal licence.
prize made up of regular members’ contributions.
partial self-exclusion, and some operators are This need not replicate the hazing ritual ‘horrors’
Likewise in the light of recent debates about willing to explore the option, resources could be of the old ‘pink card’ exam, but it needs to go
bingo in pubs it is especially important to consult diverted to researching whether it would be beyond self-verification by the company in order
with representatives of members’ clubs who have useful. to maintain a sense of trust in the professionalism
long offered gambling as an ancillary product in and integrity of the gambling sector as a whole.
3 Consider formalising social responsibility
environments licensed for alcohol. If membership This may also help to ensure that staff are
training and staff accreditation alongside
requirements are, in their experience, a key factor properly protected, and that their anxieties about
the requirement to intervene, across the
in ensuring that gambling is conducted their new roles in protecting players from harm
gambling sector
responsibly within such environments, it may be are allayed.
helpful to consider once again its role within Among individuals with long histories in the
commercial facilities that are primarily designed commercial bingo industry there is a common
around alcohol. thread of nostalgia for ‘command and control’
regulation and clarity about the rules, especially
practice (LCCP) for all operators p 57 (London: Stationery Office).
practice (LCCP) for all operators p 76, rec. 7.34. (London: Stationery Office).

Pink card narratives and the shift from command and control regulation: experiences in bingo
The Gaming Board – which regulated bingo in The stakes were personally high for people, since The pink card process also enhanced respect for,
Great Britain until 2007 – thoroughly a pink card was necessary to progress as a and sometimes fear of, the Gaming Board.
investigated the trustworthiness and expertise bingo manager. Without one you could not be
of people working in licensed bingo. A police left in charge of the premises alone. In them days you could get a good relationship
background check was conducted, and with the Gaming Board as long as they trusted
commercial bingo club managers were issued You were a little bit of a care bear manager… not you and respected you and knew that you were
certificates of consent, known as pink cards, quite there. You couldn’t really make a decision. legal, kosher and everything else. (male, bingo
from the Board. To obtain a pink card you had (female commercial bingo operator, Wales) hall manager, England)
It was very important to make sure that I got that Respondent 1

a pass an interview with a panel of Gaming
otherwise basically my livelihood would be shot. I used to fear them, as a manager.

Board inspectors, many of whom were ex-
Survival is a great instinct. (male, bingo hall

police officers. This interview focused on the
manager, England). Respondent 2

law and its practical application to the running
They could take away your pink card. Having

of a bingo club.
given you this thing which was so aspirational

you have worked so bloody hard to get that you
In all 27 people, across 22 interviews, spoke The pink card process relied heavily on company-
didn’t want it to be messed about. If anything

to us about pink cards when sharing their level training and support. Bingo operators
went wrong, you were the one that they were

experiences of bingo regulation. prepared staff for the interviews, often by
going to come after.

involving ex-Board inspectors. Larger operators
Generally people spoke of the pink card also did mock interviews. However the external
Respondent 1
process in similar terms: as intimidating, validation of expertise involved in the pink card
You wouldn’t want to risk a breach that could

stressful, an interrogation, a trauma, awful, system also bolstered managerial authority, and
potentially lose you your pink card, because any

‘difficult and nerve wracking,’ tough, daunting, wages.
The licence protected my job. You couldn’t come breach could have lost you it. It wasn’t just the
intense, horrendous, ‘like your A-levels or
and do my job, because you had to go through work. This was in my social life as well. If I went
driving test.’ As one manager put it
hoops to get it… Over the years they have had to out and got drunk with my friends and got myself
My hands were sweating and the heart was
pay me a lot of money, because there wasn’t a into any sort of trouble… or driving offences or
thumping. It was the most intimidating exam
great surplus of people with the knowledge and anything like that, I could have my pink card
I’ve ever had in my life—and I’ve had a few
experience or whatever. So this was probably quite revoked. It was a big thing back then in terms of
(laughs). They fired a load of questions at
cynical of me, but to get rid of that process has your behaviour inside work and outside of work.
you… I just felt there was a spotlight missing
enabled a company to open up the amount of (male and female, commercial bingo operations,
from me. … I went with another manager and
managers who they can employ which, in essence England)
he come up crying and I thought, oh my god,
oh my god, I am never going to pass this. has allowed them to reduce the salaries, the
(male, bingo hall manager, Wales).19 wages, they reduced their pensions and that.
(male, bingo hall manager, England)
You felt that you’d joined an elite club… I am

highly fetted and a right and proper person and
all that. I can now operate in quite a lucrative
career. (male, commercial bingo operations,
England).
19 We distinguish between those who were – at the time of the interview – working as bingo hall managers, and those who were working in other roles within
commercial bingo operations.
Pink card narratives and the shift from command and control regulation: experiences in bingo (continued)
Under the current system for personal However most of those who had been through
management licences individuals are required by both systems felt that the older one had been
the Gambling Commission to fill in forms focusing better at ensuring high levels of expertise.
on criminal records, and on financial background.
Testing of gambling knowledge is handled by the The way we used to do it was much better…
company, which provides training and certifies Nowadays, this is my personal prejudice, anybody
the person as appropriately qualified. Licence can now get a gaming licence in a bingo hall. I
holders described this system as faster, and spoke to some of the new people the other day and
much less onerous: I was quite shocked.…They came from (a previous
job in a shop) and they told me that they applied
Nothing really, it was just more of a tick box for their Gaming Licence on the second day that
exercise… I just had to fill in a form. (female, they were in the business, because they were on a
commercial bingo operations, England). training course with our company... That’s all
they had to do. Filled the application form in.
Obviously because I am not a criminal it went (male, bingo hall manager, England).
through quite easy (female, commercial bingo
operations, England). You had to know the law, you would revise six
months prior, they would question you on
If the company is happy then you fulfil all the everything. Then you were given a licence to say
legal requirements (male, bingo hall manager, yes, you know your stuff. And the 2005 Act came
England). along and just that went out of the window. So I
just tick a couple of boxes, write a couple of
Three of those who had been through both things... Nobody’s ever come to see me. (male,
systems felt that the new system was better. As commercial bingo operations, England).
one explained “The onus is on the company to
self police so the onus is on the company to It checks finance doesn’t it and it checks criminal
make sure that I know, that I understand, that I’m record, which obviously it is beneficial. You
trained, that I’m a fit and proper person to run a wouldn’t want someone with any fraudulent past
bingo club. And if that’s not the case the onus is or any kind of criminal conviction. It’s slightly
on the company to deal with me appropriately different because there is no actual gambling
either taking me out of the job or giving me the knowledge needed to hold a PML (personal
knowledge that I require… There are checks with management licence). Whereas, previously we
the police and such like, criminal records and all held a licence which was actually based on your
that kind of stuff which is entirely correct knowledge of gambling. Now we are regulated
because there are some people out there who almost by our personal behaviour rather than our
may not be entirely the right people getting to actual industry knowledge, I guess. There is no
bingo.” (male, bingo hall manager, England) Gambling Commission involvement in that,
almost you just send it away. (female, bingo hall
manager, England).
I was lucky, because I was probably one of the last

lots of people to hold a pink card. (male, bingo
hall manager, Wales)

Top 25 bingo cases

Full citation Brief summary
Bow v Heatly [1960] JC Edinburgh miners’ welfare institute running a tombola/housey housey game for charitable purposes; convicted of illegal gaming on grounds that no
114 entertainment other than the tombola/housey housey was provided. Held that a game of chance, or of chance and skill combined, was in itself an
“entertainment” within the meaning of the Small Lotteries and Gaming Act, 1956, sec. 4 (1), and conviction quashed.
Payne v Bradley [1961] 2 Whether Huddersfield Friendly and Trade Societies Club was rightly prosecuted for unlawful gambling. Tombola was played; proceeds put into
All ER 882 (HL) general funds of the club and used to meet general expenses. Held that proceeds were a ‘private gain’ and hence that gaming was unlawful.
Dissenting judgements by Denning and Morris disagree that benefits to club members constitute a private gain. This case is raised several times
by MPs calling on the government to introduce legislation to amend the 1956 Small Lotteries and Gaming Act so as to explicitly allow such clubs to
apply the proceeds from gaming events to activities benefiting club members. In 1962 a private member’s bill is introduced in the House of
Commons by an MP to reverse the ruling by allowing non-proprietary members’ clubs and sports and athletic and cultural societies to apply
gaming proceeds to club funds. It passes, with government support.
Rogers v Cowley [1962] 1 Undercover police operation reveals bingo being offered to non-members in a seaside club. Charging them to participate was unlawful. However
WLR 770 (QB) allowing legitimate players (members) to buy different numbers of tickets did not violate the equal chance provision since all individual chances
had an equal chance to win.
DPP v Regional Pool The Spastics League Club, with 6 million members, was convicted of running multiple lotteries (described as bingos) out of the headquarters.
Promotions Ltd [1964] 2 Numbers were assigned to members on the basis of their membership card, and winners were notified after Club officials had drawn the numbers.
QB 244 In closing, Lord Parker noted the reluctance with which he made the decision “because it is the undoubted fact that a great deal of the proceeds
of these activities goes, as one would expect from the name, to a most worthy cause” (at para. 256).
Armstrong v DPP [1965] Upheld the conviction of the proprietor of a postal bingo club for running an illegal lottery, on the grounds that buying a ticket in this form of bingo
2 All ER 745 (HL) was not participation in a game. The postal bingo involved 300,000 players. Results were announced in a dedicated bingo programme on the
pirate radio station Radio Luxembourg and published in the cult magazine Tit Bits. Again winners were contacted and notified without having to
claim; again the court held that there was no gaming, since there was no participation in a game and no assembly of players.
DPP v Essoldo Circuit Unlawful nature of a roulette-style interval game (‘super legalite’) played in a bingo club, involving a players’ pool.
(Control) [1966] 1 QB 799
DPP v Bradfute and Bingo prize competition, with tickets included on tins of cat food. Held that this is advertising an illegal lottery.
Associates Ltd [1967] 1
All ER 112 (QB)
Mecca Ltd v Edinburgh Local authority had refused a permit for amusement with prizes machines in an unlicensed club on the grounds that the police had no entry power
Corporation [1967] SLT without a warrant to supervise. Held that local authority had not validly exercised its discretion; application for permit should be granted.
(Sh. Ct) 43
Adcock v Wilson [1968] 2 An early version of a linked national game (National Golden Scoop Game, involving c 500 clubs and up to 200,00 players nightly) was not a legal
WLR 914 (HL) game under the 1963 Betting and Gaming Act. Held that players were taking part in various separate games of bingo. Held that it would be
possible to have a national game, if played at the same time everywhere and if there was instanteous communication.
Douglas v Valente [1968] Overturned the conviction of a shopowner who had run a gaming club. He charged a membership fee to play machines, and offered free bingo
SLT (Sh. Ct) 85 games with prizes of shop goods. Had been charged with conducting and promoting an illegal lottery, but acquitted on appeal on the grounds that
members had not contributed to the prize fund via the membership fee. Lotteries must involve some form of paying into the prize fund as a way of
participation. Using free bingo to attract people into the premises, to buy drinks or use machines, does not establish a contribution by them to the
prize fund (see also Mccollom v Wrightson [1968] 2 W.L.R. 578).
Plaza Bingo and Social Bingo club applied for a permit for amusement with prizes machines; granted but local authority attached conditions that didn’t fall within the list
Club LTD. v Port Glasgow specified in s 49(3) of the 1963 Betting Gaming and Lotteries Act. The conditions were not within the powers of the local authority; the discretion
Burgh Council [1968] SLT bestowed is either to grant or renew. Permit is granted.
(Sh. Ct) 3
Metropolitan Police Confirmed the illegality of a roulette-variant game played in a bingo club that did not offer equal chance to all the players, and where the club kept
Commissioner v I. & N. part of the stakes.
Weston Ltd [1969] 1 WLR
847 (QB)
Rogers v Home Secretary Upheld the denial of a bingo operator’s licence on the basis of information contained in confidential documents, from which the Gaming Board
[1972] 3 WLR 279 (HL) concluded that the applicant was of “dubious character and reputation.” Held that Gaming Board had the right to use these documents to
determine operator suitability, and to withhold them.
Full citation Brief summary
Wheeler v Gibbins [1970] Undercover police operation against a telephone link game involving 23 members’ clubs. Undercover police officers pay the entrance fee and play:
1 WLR 268 (QB) there is no check on membership. Held that persons not members or bona fide guests of members were participating in games with the intention
of claiming winnings; gaming was unlawful.
W.M.T. Entertainments Ltd Upheld refusal to grant a licence for a bingo hall, on the grounds that the demand for bingo was met by existing facilities. The applicants
v Glasgow Burgh unsuccessfully argued that the existing premises were not providing the type and range of facilities that they intended to offer.
Licensing Court [1975]
SLT (Sh. Ct) 39
Granada Theatres Ltd v Overturns a refusal by the licensing authority to grant an application for the conversion of cinema into a bingo hall. The refusal was made on the
Secretary of State for the grounds that preserving the use of those premises for a cinema was more desirable.
Environment [1976] JPL Walker v Leeds, Greenwich and Lewisham [1976] 3 WLR 736 (HL)
96 (QB)
Series of cases involving The cases focus on prize bingo, the definition of a pleasure fair, and permits for amusements with prize machines. Ultimately held that local
local authority licensing authorities can not make ‘blanket resolutions’ not to grant permits for premises used for amusements with prizes (whether with or without gaming
powers over gambling machines).
activity and premises.
Tynewydd Labour WMC HMRC claimed VAT due on admission fees charged to members in a working men’s club. The club argued that those charges were for tax-exempt
and Institute Ltd v The bingo sessions. HMRC argued that the admission charges had been made on days where live entertainment was also provided in the premises.
Commissioners [1980] Held that members who paid the entry fees on the entertainment evenings did so to get live entertainment and bingo. Therefore, those members
VATTR 165 considered that a part of each entry free was for the supply of the live entertainment. VAT was due on that money.
Mecca Leisure Ltd v Upheld local authority discretionary powers to decide on a renewal of a bingo licence involving an inter-linked increase in amusement with prize
Glasgow District machine entitlements. Plausibile for authority to believe that allowing 25 gaming machines in one bingo venue would undermine the social
Licensing Board [1986] character of the bingo club.
SC 230 (OH)
Robertson v Anderson An agreement between two women to share the national game bingo prize would be enforced by the courts, and was not subject to the rules
[2003] SLT 235 (IH) relating to the unenforceability of gaming contracts.
Wilson v Burnett [2007] Woman who won the national game in a bingo club is sued by two acquaintances who claimed that, some days prior, the three had agreed to
EWCA Civ 1170, [2007] share any bingo winnings over £10 pounds. Winner denies the existance of the agreement. Appeal court uphold the lower court decison that there
All ER (D) 372 was no legally enforceable agreement, including because there was inadequate evidence of an intention to create legal relations.
Clockfair v. Sandwell In 2005 Mecca is granted a casino licence (under the 1968 Betting and Gaming Act) for a premises already licensed as a bingo premises; in 2008
Metropolitan Borough it converts both licences into ones held under the 2005 Gambling Act. It subsequently applies to move the casino licence to apply to a new
Council and Grosvenor premises. A rival company applies to the licensing authority to review and revoke the casino licence, on the grounds that it has not been used since
Casinos Limited [2012] granted, and that “the continued existence of the (casino) licence is legally incompatible with the bingo licence that exists in respect of part of the
EWHC 1857 (Admin) same premises” (at para. 7). Appeal court agrees there was an error in law that should have been taken into account in the licensing authority’s
decision about reviewing the licence; decision sent back to the licensing authority for reconsideration.
Carleton Clubs Ltd v HMRC claim a bingo company (operating 13 clubs in the UK) is liable to bingo duty on charges made for the hire of electronic hand held devices
HMRC [2014] UKFTT (“Bingo Bees”) between 2009 and 2012. Company claim that payments to use the devices are exempt, since they are not “payments … in respect
1045 (TC) (Appeal of entitlement to participate in bingo” (at para. 3) within the relevant section of the Betting and Gaming Duties Act 1981. Rather they are simply a
number: TC/2013/01013) payment to use the devices. Company claim that the fees are analogous to the price paid to purchase a bingo dabber, used to cross off numbers
on a paper ticket. Court distinguishes electronic devices from dabbers/pens since dabbers and pens are an option when playing; the electronic
device is a necessity to read the tickets loaded thereon. “The reality is that when playing electronically the electronic handheld device is physically
the “ticket”. Payment for the ticket undoubtedly falls within the ambit of bingo duty (whilst the charges for dabbers and items such as pens that fulfil
that function do not)” (para 41).
Cavenbridge Ltd v HMRC Cavenbridge claim that the duty paid on bingo dabbers was wrongly applied, since they are required to participate in bingo, and optimised for
[2015] UKFTT 0536 (TC) bingo, and fall within the exempt supply of the provision of facilities to play bingo. HMRC claim that the purchase of a dabber/marker pen is
(Appeal number: optional, and not essential or compulsory to play bingo. Ordinary pens can also be used. Court agrees with HMRC.
TC/2013/7359)
Gambling Commission v Gambling Commission successfully appeal against an earlier ruling that quashed their refusal to grant a bingo operator licence for Greene King
Greene King [2016] (operating c1,000 pubs). Case rests in large part on the powers of the Commission to act as national ‘gatekeeper’ under the Gambling Act 2005
UKUT 0050 (AAC) Act, by considering operating environment as part of operator suitability. Commission’s concern was mostly with the availablility of high stakes
gambling machines (to which licensed bingo premises are entitled) in pubs, especially re: the potential for vulnerable people to be harmed or
exploited by gambling due to the centrality of alcohol to the environment, and the fact that gambling would be “an ancillary attraction in alcohol-led
non-bespoke gambling premises” (at para. 39). Judge holds that the 2005 Act gives the Commission power to consider matters relating to the
operating environment. The counter-argument that the Gambling Commission should limit its role to considering suitability for an operators licence
and then object individually to premises applications if necessary, engaging with local licensing authorities on a case by case basis, is rejected:
this would require the Commission to pursue national policy objectives via “some kind of guerilla warfare in each separate locality” (para 55).
CHAPTER 4: REGULATION ON ONLINE

BINGO IN THE EUROPEAN UNION
You combine online and gambling, two

concepts that scare politicians everywhere,
because they are nervous about gambling
traditionally, scared about the Internet
because having control about it and all this
sort of thing. The government is there to
control things and some things you can’t Sweden
control, [it] just touches all the wrong
buttons for them. (Male, Trade Association)
Denmark
Part 1: The scale of play

Bingo was sort of last to the [online] market.
UK
(Male, Affiliate Marketer)
The International Lottery in Liechtenstein allowed

the general public to purchase lottery tickets over Italy
the internet in 1995.1 This is reported to be the
first time the general public was able to purchase
the chance to win a prize, using real money, over
the internet. The first internet bingo website, Spain
Portugal
www.ibingo.com, opened in 1998.2 Interviewees
for this case study said that the initial online bingo
sites were North American focused; it was not
until the early 2000s that the first UK facing online
bingo sites such as www.uk-bingo.net began to
appear. By 2013 it was estimated that the Global
Gambling Revenue for online gambling in the 28 EU Member States mentioned most frequently by our interviewees in relation to online bingo.
European Union (EU) Member States was €10.9
Billion.3 Of this, just over €926 Million was
attributed to online bingo.4
If it’s a country where they have never really done Retail (land-based bingo) is still very much an
bingo, it [online bingo] is a hard sell. It’s such a older clientele and (we) find it very difficult to
Online bingo is not equally popular across all 28
crowded marketplace with the games people are make its proposition attractive to a younger
EU Member States. A number of Member States
familiar with. … For some it is, for some it’s a audience. Whereas, certainly within (our) online
were mentioned repeatedly in relation to online
huge commercial sector of course…. Generalising bingo offering or digital bingo offering, we have
bingo during our research, including the UK,
it, when we reach further east in Europe, it drops a much younger demographic….I think there’s a
Spain, Italy, Denmark, Portugal and Sweden.
off the map. (Male, Trade Association) marked difference there between the two. I also
Despite the popularity of online bingo in these
think that’s technology driven as well from a

countries it remains less important to overall
mobile perspective, and I think it’s also heritage

gambling revenues than other online gambling
The stereotypical image of bingo players –
driven, that a lot of young people are slightly put
forms, such as sports betting, casino games and
female, elderly and working class – was
off from retail bingo.…there’s a lot of stigmas
slot machines.
recognised throughout our research. Many
interviewees pointed out that there is more female around retail bingo…. But I think when it comes
participation in online bingo than in other forms of to digital bingo, it’s much more accessible to a
online gambling. younger audience. (Male, Commercial Online
Bingo Operator)
1 Robert J. Williams, Robert T. Wood and Jonathan Parke, ‘History, Current Worldwide Situation, and Concerns with Internet Gambling’ in Robert J. Williams, Robert T. Wood and
Jonathan Parke (eds) Routledge International Handbook on Internet Gambling Routledge 2012) 3.
2 Robert J. Williams, Robert T. Wood and Jonathan Parke, ‘History, Current Worldwide Situation, and Concerns with Internet Gambling’ in Robert J. Williams, Robert T. Wood and
Jonathan Parke (eds) Routledge International Handbook on Internet Gambling (Routledge 2012) 4. See https://web.archive.org/web/19981205231204/http://www.ibingo.com/
3 European Gaming and Betting Association, ‘Factsheet: Market Reality’ available at http://www.egba.eu/facts-and-figures/market-reality/ accessed 13 May 2016. Citing H2
Gambling Capital.
4 Bwin.party, ‘Our Markets: Online Bingo’ available at http://tinyurl.com/jpvej9e accessed 13 May 2016. Citing H2 Gambling Capital.
The UK operators we spoke to mentioned that European regulation of online bingo focus on ensuring that Member States comply
roughly 60% of online bingo players were female The European Commission decided in 1992 with their obligations under EU law. Importantly,
and that the average age was around 40. A that it would not seek to submit proposals for the Commission has also sought to engage in a
number of operators spoke of the player base harmonised gambling rules. The European ‘soft’ form of harmonisation through the
in terms of the UK National Readership Survey Commission’s decision took into account the development and publication of a non-binding
Social Grades, with players within the C1 (lower principle of subsidiarity, which stipulates that Recommendation on Consumer Protection in
middle class), C2 (skilled working class), D the EU should only regulate if it would be more Online Gambling and has proposed the
(working class) and E (not working) groups. effective than national or local level regulation. development of common technical standards
UK operators generally positioned online bingo Since then, there has been no sector-wide for online gambling equipment.
players as younger than land-based players, and harmonisation of online gambling regulation in
noted that online players were getting younger the EU. There have, however, been a number of The provision of online gambling services falls
with the introduction of mobile gaming. pieces of EU legislation that have or will impact within the scope of the EU’s Treaty rules relating
upon online bingo operators, players, and to the free movement of services and the freedom
Looking beyond the UK, high participation rates regulators. For operators and players, the Unfair of establishment. The freedoms aim to allow
of female players were also observed in other Commercial Practices Directive harmonises the operators to freely provide services on a
Member States. A person familiar with the Danish regulation of misleading and aggressive temporary basis from their country of origin to
online bingo market noted that the demographic marketing practices and thus provides important another Member State (services) or to move on a
of online bingo players in Denmark was “more or rules for one of the core activities of online bingo permanent basis to another Member State to
less the same” as the UK. There were around operators. Indeed, regulations relating to provide services (establishment). The Court of
60% female players that were “40 plus” and it was marketing were identified as key concerns for Justice of the European Union has stated that
“not a high status game.” The interviewee both operators and regulators. In addition, EU gambling may entail certain moral, religious and
emphasised, however, that 40% of the players legislation regulates in the areas of anti-money cultural aspects, involve a high risk of crime or
were male. Interestingly, a recent report from the laundering, online dispute resolution, the fairness fraud, and have damaging individual and social
Spanish online gambling regulator found that over of consumer contracts, and data protection, all consequences. As a result, Member States are in
65% of online bingo players in the jurisdiction of which are applicable to the online gambling principle free to regulate online gambling to
were male.5 A similar player demographic was sector. Finally, the EU legislation also requires achieve certain public interest objectives such as
identified by someone with knowledge of the Member States to send notification of changes to consumer protection, the mitigation of problem
Swedish online bingo market. They stated that online gambling regulation prior to them entering gambling, the prevention of gambling becoming
roughly 60% of online bingo players in Sweden into force. As such, EU legislation provides the a source of private profit, and the prevention of
were male and the average age of players was European Commission and Member States with fraud and crime. It important to note that the use
around 38 years old. Italy also appeared to be a an important oversight role in relation to other of gambling as a means of revenue generation
market where there were more male online bingo Member States’ online gambling regulation. for the state or for good causes cannot be the
players than female. primary objective of a Member State’s gambling
In 2011, the European Commission published its regulation. Furthermore, Member States must
Part 2: The law and regulation of Online Gambling Green Paper. The Green Paper demonstrate that their regulatory approach is
provided a framework for debate on the proportionate, necessary, and suitable to
online bingo
development of online gambling in the EU and achieving such aims, and that the public interest
sought responses from stakeholders. In 2012, objectives are being pursued in a consistent and
Memories of pre-regulation and the Wild systematic manner.
West following the consultation on the Green Paper,
the European Commission published its online
I think that perhaps in the early days…. it National approaches to the regulation of
gambling action plan. This action plan concluded
was a bit wild west. Whereas it’s got a lot online bingo
that:
more serious. It’s got a lot more suited and
In view of the type of challenges posed by the
With no sector-wide harmonisation and a wide
booted and leaner for me now. It’s kind of a
development of online gambling and their
margin of discretion afforded to Member States in
lot more, serious players in the market now,
implications for each Member State it is not
how to regulate online gambling, the regulation of
whereas back in 2000, early, early
possible for Member States to effectively address
online bingo in the EU is a patchwork of national
noughties, it was kind of, there wasn’t
these challenges alone and to provide individually
regulatory regimes and approaches. The
really…. it felt pretty maverick, a bit of
a properly regulated and sufficiently safe offer of
emergence of online gambling has challenged
Delboy. ‘Cause now, it’s actually quite
online gambling services.7
not only traditional approaches taken by Member
serious. (Male, Software Provider).6 States to gambling regulation, but also the ability
of Member States to control the provision and
The Commission’s action plan proposed the consumption of gambling services. It also altered
creation of an expert group on online gambling, regulatory assessments of risks posed to
increased cooperation between regulators, and a consumers.
5 Directorate General for the Regulation of Gambling, ‘Report: Analysis of the Online Player Profile’ (The Ministry of Finance and Public Administration 2014) available at
http://www.dgojuego.minhap.gob.es/es/informe-jugador-online accessed 13 May 2016.
6 'Delboy' was a working class TV character on British television renowned for his rule-bending, can-do entrepreneurial attitude.
7 European Commission, ‘Communication from the Commission to the European Parliament, the Council, the Economic and Social Committee and the Committee of the
Regions towards a comprehensive European framework for online gambling’ COM(2012) 596 final, 5.

The last ten years has seen a number of Member with the practical result that online bingo can only
States move to a local licence regime for online be offered by, or on behalf of, charity lotteries. 28 shades of grey
bingo as part of their online gambling regulation. Both the Netherlands and Ireland are currently in Back then [2000] it was very grey.… The
Such a regime requires online bingo operators to the process of regulating online gambling. Ireland product was ahead of the legal system. So,
obtain a national licence before they can offer has proposed to allow commercial online bingo back then it was only two or three places
gambling to customers from that jurisdiction. Italy while the Netherlands has sought to reserve like Curacao, Costa Rica, places like that
was the first jurisdiction to move to such a regime online bingo to lottery operators. that had actually proactively said: “yes, we
in 2007, with Spain, Romania, Portugal and the will license online gaming”. The rest of the
United Kingdom later embracing this approach. While state monopolies for online gambling are in world hadn’t said: “no, you can’t” but at the
In contrast to the local licence regimes such as decline in the EU and the European Economic same time hadn’t said: “yes, you can. (Male,
Italy, Spain and the UK, Belgium operates what Area, a number of jurisdictions such as Norway Affiliate Marketer)
has been called a “licence + model” where and Finland still retain a state gambling monopoly
authorisation to offer online gambling services is that has extended to online gambling. In Sweden, Sweden is a good market and it’s still grey,
dependent upon possession of a land-based the prevention of gambling becoming a source of so you can put your dot com solution into
gambling licence. private profit is a cornerstone of the regulatory Sweden. (Male, Software Provider)
regime. The result of such an approach is that We feel comfortable operating in Sweden.
A number of jurisdictions have established a local only the state operator, Svenska Spel, and a small (Male, Commercial Online Bingo Operator)
licence regime for certain categories of online number of charity operators are permitted to offer
gambling products but have reserved the online bingo. We are very white in terms of the country
provision of online bingo to national lottery we approach. We don’t take, if it’s slightly
operators. For example, both Denmark and Any discussion of online gambling regulation in grey then we won’t touch it. (Male,
France define bingo as a lottery product that the EU must recognise the existence of a “grey Commercial Online Bingo Operator)
can only be offered online by Danske Spil and market” where the distinction between what is Finland is meant to be closed off to
Française des Jeux (the state monopoly legal and illegal is unclear, blurred or obscured. Veikkaus [State Lottery Monopoly] but a lot
providers) respectively. In Germany, too, bingo In Sweden, for example, the offer of online bingo of people still operate there. They are
is characterised as a lottery game and reserved to customers within its territory is not explicitly obviously not marketing through TV and
for the state lotteries. While online gambling is prohibited, but commercial operators cannot be radio, etc. But they are still getting online
currently prohibited in the Netherlands, an licensed to offer such services. Sweden and traffic through other means. (Male, Software
exception exists for lottery operators and charity Ireland emerged as key “grey markets” within Provider)
lotteries. Such operators are permitted to offer the EU while an online bingo software provider
lottery products online, with bingo being one such joked that the entire EU was a “grey market”. The position in relation to other jurisdictions
product. Ireland currently only explicitly regulates Operators respond differently to this lack of clarity is they may not have, or their legislation may
online betting. However, Ireland’s land-based depending on their own interpretations of EU law, not allow you to apply for a licence or the
gambling and lotteries regulation technically also and their differing appetite for regulatory and law is really outdated and it doesn’t really
applies to the online provision of such services reputational risk. deal with it. In those instances, we adopt
what’s called a ‘country of origin’ approach.
Obviously our main hub is in Gibraltar and
we are legal and licensed in that
jurisdiction. There’s obviously European
Union rules about the supply of services
between Member States and having taken
legal advice and (becoming) clear on the
position in each country, we supply into a
number of European countries from our
Gibraltar hub, into jurisdictions that don’t
have those licensed regimes and where the
law allows us to rely on EU arguments to do
so. (Male, Commercial Online Bingo
Operator)
Extract from a certification document issued by a testing house that tests the integrity of random number
generators in online bingo. Image taken by Donal Casey.
!
Part 3: Key themes

Chatting about community and participation in online bingo
1 The social nature of the game
You can argue that online bingo isn’t bingo
So if you think about desktop, the real innovation in desktop was chat, because you can’t talk
anyway (Male Commercial Bingo Operator,

while you are playing bingo. You would be thrown out of the bingo club if you talk while you are
England).
playing bingo. Obviously, chat allowed people to create a sense of community and we spent a bit
of time explaining the benefits of that. But in order to chat, there was a real drive to make the play
Companies that have specialised in bingo I think
automatic. (Male, Commercial Online Bingo Operator)
have a more fundamental understanding of their
bingo customers…. I think companies that are
To be fair, I mean, I’ve worked, I’ve done some experience in retail bingo clubs as well, and we
generic online gambling companies and have

spoke about community and community elements for retail and online bingo and multi-channel
embraced bingo as part of their suite of products

elements in my past as well. And I could put an argument that online bingo is actually more
don’t have the same, how can I put it? They don’t
community focused. And from the community I mean that people are sharing the experience of
have the same sense of community as perhaps you

the game. People are talking about different things. Talking about television, talking about what’s
know, a mainstream bingo company would have,

happening in their lives. Friendships are built online. (Male, Commercial Online Bingo Operator)
because they understand the culture, the history of If they have to mark their tickets, online, in the same manner (as in-hall) then there would be a lot
bingo as a game. (Male National Regulator) less chat going on…. But then again, you lose that element of danger that if you miss your
number or you don’t call in time and lose the prize. (Male, Commercial Online Bingo Operator)
The questions of what happens to bingo when it The chat room, I think it’s the most distinctive feature of the game. The bingo is a very social
moves to the online environment, and how law game, compared to all the other online games. (Female, National Lottery Operator)
and regulation deal with this transition, coloured
much of our research. These challenges have I guess it’s different in the sense that no-one really dabs numbers in online, so you are really only
even made their way to the UK’s House of Lords interested in the bit where you are getting close to the win. Whereas, land based there is more
during domestic debates on gambling regulation. concentration and you can’t really multi task so your focus is on the game whereas online you
In March 2016, Lord Collins of Highbury noted can do a bit of chat and you can play mini game slots, etc or look at Facebook and then the
that: bingo is just a small proportion of your attention and just keeping an eye on it or not even
watching it. You can play and not just—it’s like the lottery, you come back and see if you’ve won,
One issue which concerns me, but has not been later on. How many people actually watch the draw compared to those that buy tickets. (Male,
mentioned so far, is bingo. It is a community Software Provider)
activity and, conducted communally, it is a very
positive thing. But online gambling has taken the
I made the bingo initially. It’s many years ago, almost ten years ago. Somebody said, let’s make a
word “bingo”, adapted it and changed it out of all
bingo without chat. And then I said, we can’t launch bingo without chat, because the chat is
recognition. It has now become a gambling
everything. Bingo is just bingo. (Female, National Lottery Operator)
activity done in isolation, not a community one.
How do we catch up with these things? (HL Deb.
I think that’s [chat] very very important. I think many of the bingo players, they are not only
11 March 2016, col547).

playing bingo to win a lot of money. They are playing bingo for having one hour of fun and chat
with other customers. Have a nice time. I think the social aspect of bingo is very very important. I
also think that is one other reason why there’s a little bit more of women in bingo than other
The social interaction between players, the products. (Male, National Lottery Operator)
resultant sense of community that flows from
these interactions, and participation through
daubing and calling out to win are central
features of land-based bingo. While there is an
assumption that online bingo is a solitary activity,
our research indicated that the chat forums and
the social interaction that they allow are crucial for
many players. Both non-profit and commercial
operators providing online bingo, across a
number of jurisdictions, highlighted the social
nature of online bingo as a distinctive feature
setting the game apart from other forms of online
gambling. Many interviewees we spoke to
pointed out that the automation of online bingo –
players’ cards are automatically daubed and
players do not need to call to win – provides more
opportunity for social interaction than land-based
bingo. Indeed it was the importance of the social
element of online bingo that drove its automation.

2 Defining the game 3 Slots, casino and other side games

The move to the online environment not only Diverse game definitions [O]nline bingo is just a portal and a gateway into
complicates the distinctiveness of the game; it In the early days of online harder forms of gambling online. (Male,
also challenges how regulators seek to regulate gambling…product definition wasn’t at the Commercial Bingo Operator).
play. In particular, the move to the online forefront of what they were controlling
environment raises the question of how to people on. So it’s much more about Slots, casino games and other side games are
regulate a game that, at its core, is just a payments and security and RNG (random a significant revenue stream for online bingo
randomly generated set of online numbers number generation) and telling the truth and operators. Operators reported that in some
paying out winners automatically, but which may all of this, rather than focusing on product. I cases bingo was run as a ‘loss leader’ and that
have a long land-based tradition and approach think to some extent that’s still in place…. around 50% of their revenues were generated
to regulation. While some Member States have There is still less emphasis on product through slots, casino and side games. Most
drawn upon their understanding of land-based definition than there is perhaps in the land commercial, and some non-profit, online bingo
bingo in regulating its online mechanics, others based market. (Male, Commercial Online operators offer such games. Many of the online
have allowed a more flexible approach to how the Bingo Operator) operators interviewed spoke candidly about the
game can be run. In the UK, for example, the importance of these games for the online bingo
There [UK] is no limitation as to the number
Gambling Commission’s 2014 guidance on What business model and drew comparisons with the
of balls in a game and the way the tickets
constitutes bingo8 incorporates components of use of slot machines in the retail bingo sector in
need to be displayed and the total RTP
online play, such as the ability to win without the UK. Moreover, a number of the regulators
(return to player) that needs to be offered to
calling out to stop play. By contrast, both Spain interviewed drew attention to the use of side
the player and total maximum ticket price,
and Italy drew directly from their land-based games by online bingo operators.
minimum ticket price, minimum number of
regulation when developing their online bingo players. It was like the world is your oyster.
regulation. In Italy, only 90 ball bingo is allowed Spain provides an interesting example of how
(Male, Software Provider)
and prizes can only be awarded for the first line the importance of side games for revenue, and
and full card. Spain only allowed for 90, 80 and In some ways we didn’t significantly the mingling of games, can impact regulation.
75 ball bingo and requires online bingo to be distinguish between online bingo and online When Spain initially introduced a local licensing
strictly pari-mutuel (where prizes come directly casino products, because most of the regime for online gambling it did not allow online
from the common pool of money wagered in a characteristics are the same, so there’s a slot machines. However, in the last year Spain
particular bingo game only). random number generator. The rules of that, has introduced regulations for the provision of
parts of that, fairness, social responsibility online slot machines. An interviewee stated that
Despite the role that land-based regulations play measures and so on are all very similar. the reason for this change was a realisation that
in defining online bingo in certain jurisdictions, (Male, Regulator) online gambling operators needed “a robust and
a number of interviewees highlighted how, as synergic portfolio of products”. Indeed, a
Bingo is considered as a casino game…. software supplier noted that the Spanish online
markets open, pressure increases to relax rules
That way it’s still a concern. It’s not being bingo market hadn’t taken off because it was
on game definition. As jurisdictions that license
considered as an innocent game. That’s the only recently that operators could legally offer
online bingo seek to both attract players away
difference from the land based game where online slots. Furthermore, a recent study
from unregulated operators, and create an
everybody knows that elderly people like to undertaken by the Spanish regulator showed that
attractive regulatory environment for online bingo
play bingo at hotels and so on. (Male, a high proportion of online bingo players were
operators, there is a trend away from prescriptive
Regulator) also playing casino games such as roulette and
rules relating to game mechanics. In 2013, Spain
relaxed its regulations on the variations of the It has to be born in mind that, for us, the blackjack.9 An interviewee indicated that the
game that can be offered, and Italy has proposed core element in the bingo regulation has to relationship between online bingo and casino
amended regulations that offer a broader be, or the core feature of bingo has to be, games, and recognition that such games are
definition of bingo, not restricted to 90 ball play. the pari-mutuel element and the fact that the available on online bingo sites, drove the
game of bingo is a mutual game, where reconsideration of how the advertising of online
players make a deposit or participate bingo should be regulated. While the advertising
economically and this funds the prize. If you of bingo had previously been regulated in the
departed too much from this, you would end same way as lottery products, proposed
up with a different animal. (Male, Regulator) regulations will treat online bingo in a similar
manner to casino games. Thus, the relationship
So online bingo could be offered by pure between casino games and online bingo, and the
online operators, but online bingo as a mingling of games on online bingo sites, led to
product was a simple transposition of the the rethinking of a “bingo exception” in Spain’s
retail product…. [W]e had to use the same gambling advertising regulation.
rule for online bingo. (Male, Regulator)
8 Gambling Commission. (2014). What constitutes bingo? (London: Stationary Office), s.1.1; quoting s. 363 of the Gambling Act 2005.
9 Directorate General for the Regulation of Gambling, ‘Report: Analysis of the Online Player Profile’ (The Ministry of Finance and Public Administration
2014) 32. Available at http://www.dgojuego.minhap.gob.es/es/informe-jugador-online accessed 13 May 2016.
The use of online bingo as a ‘gateway’ to offering In addition to national lottery operators, many
slots, casino games, and side games, and the Online bingo and slot machines (continued) charities also offer online bingo. For example,
mingling of these forms of gambling on some I think definitely the ability for someone to Marie Curie (a cancer charity) offered online
sites, challenges how we perceive online bingo. lose a lot of money on bingo has increased bingo in the UK up until this year; Folkspel (a
The potential for bingo to be an ‘alibi’ or because of slots. So when I started, you group of charities including the National Sports
camouflage for other forms of gambling leads couldn’t spend a lot of money on bingo, Association and the Breast Cancer Association)
some to challenge the perception that bingo is a really. It was a slow game. The tickets were offer online bingo in Sweden; and Rehab Lottery
gentler, less risky form of online play. quite cheap and that kind of stuff, whereas (helping people with disabilities) offers online
now, you can play a lot of slot machines. bingo in Ireland. The People’s Post Code Lottery
You can spend a lot of money very quickly. I (whose beneficiaries include groups such as the
Online bingo and slot machines: views from think that’s something we are very Dogs Trust and the World Wildlife Fund) operates
interviewees conscious of. We have to be very nervous online bingo in the UK, Sweden, and the
Quite a lot of people play bingo and slots about that. (Male, Commercial Online Bingo Netherlands.
and casino games, but if you are just Operator)
playing bingo it’s actually probably quite Interestingly, both Ireland and the Netherlands are
hard to spend too much money too quickly, in the process of regulating online gambling. One
because it’s only one game every six 4 Lotteries, charities and online bingo key issue that has emerged during these
minutes or five minutes. (Male, Commercial processes is whether the online bingo market
One of the key themes that emerged from our
Online Bingo Operator) should be opened to commercial operators in a
research is the use of online bingo as a means
similar way to other forms of online gambling.
People say they are only offering bingo but of revenue generation by states and by the third
Both jurisdictions currently class bingo as a
they are also offering roulette. There is 1p sector. Member states have taken varied
lottery product, which can only be provided by
cards at bingo, but people are staking £10 regulatory approaches to this issue. As a result of
certain charities and non-commercial operators.
on roulette games and games of black jack bingo’s importance for some state lotteries and
Ireland’s proposed Gambling Control Bill
and slots. Bingo operators often can’t say, charitable organisations, in some places within
indicates that the government intends to move
we are just a bingo operator and this is a the EU online bingo has been a focal point of
away from the current situation and
less harmful form of gambling, because contestation in the process of liberalisation and
commercialise the online bingo sector. By
they are offering repetitive RNG [random commercialisation of online gambling.
contrast, proposed regulations in the Netherlands
number generator] based games alongside will not liberalise the lottery market and will treat
this that don’t have any of the Many interviewees noted the similarity between bingo as a lottery product.
characteristics that make bingo more social bingo and lotteries, and some claimed that online
and slow and less likely to cause significant bingo was “just” a type of lottery. A number of
harm. (Male, Regulator) Member States have categorised bingo as a
lottery product that may only be offered by either
It’s [slot machines] critical in most state or charitable lottery operators. Denmark was
instances. I think it’s where the money is one of the first EU Member States to liberalise its
made. Customers will come in and play online gambling market. In so doing, however,
bingo. Most companies actually – and we Denmark defined bingo as a lottery product. The
are included – operate bingo pretty much at provision of lottery products is reserved to the
a loss. So bingo itself does not make national lottery operator Danske Spil. An
money. It just sits there and it draws interviewee indicated that although industry
customers in to play bingo and it’s actors wanted, and indeed still do want, online
community-led and it’s experiential and then bingo to be commercialised in Denmark,
they go and they play slots around the decision-making about the law and policy
bingo and that’s where the money is made. framework was driven by non-profit interests.
(Male, Software Provider) Similarly, although France liberalised some forms
of online gambling, bingo is characterised as a
Whilst there are many many thousands of
lottery product and can only be offered by the
bingo players, the bingo, the online bingo
national lottery operator, Française des Jeux.
model is remarkably similar to the offline
Denmark and France provide important examples
bingo model in that the bingo game can be
of how regulation can be used by Member States
a loss leader or making a modest profit, but
to cement a relationship between lotteries and
because the gaps in the game and the
bingo, including in order that online bingo
distractions of slots and other games and
provides direct revenue to states.
the cross selling of other products, it’s
essentially used as a marketing vehicle.
(Male, Commercial Online Bingo Operator)

Part 5: Policy recommendations However, if there is something distinctive about

Online bingo and lotteries: views from online bingo that sets it apart from other forms of
interviewees Representation of bingo at the European
online gambling – and this research suggests that
The perception of bingo is obviously that it’s a level
there is – in our view policy makers and regulators
softer, more acceptable form of gambling and Our research shows the absence of bingo from need to consider how the game could be better
maybe there isn’t the same societal taboo that discussions of online gambling at the EU level. represented in policy debates at the EU level.
there might be about casino or table games. Bingo is largely subsumed within discussions of More comprehensive outreach with stakeholders,
So the lotteries think well, if we are going to online gambling, lotteries, or games of chance in ranging from large commercial operators that use
enter this market we don’t want to cannibalise general. With limited exception, the Court of proprietary software to small charities, would help
or piss off customers we’ve already got or Justice of the EU has tended to speak about improve the depth of debate about the
create a perception that we are some sort of online gambling as a singular form of gambling, distinctiveness of the game and the effectiveness
hard gaming companies. So actually, the way and has mentioned bingo only in passing when of supranational regulations currently impacting
we could do that is going to enter through discussing games of chance. A similar approach operators and players.
bingo. (Male, Software Provider) is evident in the political debates, and policy
documents, of the European Commission, the Recognising the importance of bingo for
Everybody knows in the Netherlands that
European Parliament, and the Council of the charities
lobbying from current incumbents and
European Union. When different forms of
lobbying from the good causes has played a The importance of gambling in fund raising for
gambling are distinguished by European
significant role, because they see a threat that good causes and broader welfare objectives has
online gambling is expected to be regulated institutions, it is largely with reference to lotteries
been recognised at the EU level, albeit in a limited
…. For some games it’s clear that it will be and sports betting.
way. This recognition has occurred in EU case
regulated [licensed]: sport betting, poker, law, political debates, and policy documents
casino games. For some games it’s clear that Online bingo is less economically significant than
from EU institutions such as the European
it will still remain illegal online like the lottery. other forms of commercial gambling (such as
Commission, the European Parliament and the
But for bingo it’s not clear. (Female, Regulator) sports betting), and state operated gambling
Council of the European Union.
(such as lotteries). State lotteries are particularly
I mean, frankly in my experience, most well represented at the EU level, and constitute a
companies have the same sort of mindset, However, despite frequent references to “other
powerful lobbying force. Furthermore bingo is not
including lottery companies who I’m games of chance” within these fora, lotteries and
universally popular in all Member States, unlike
particularly critical of, because they try and sports betting dominate such debates. In turn, at
more widely available forms of gambling such
dress up their activities in a way that you the Member State level, discussions around the
as sports betting and lotteries. These factors
know, makes them look as if they are just role that online gambling plays in fundraising are
contribute to the absence of bingo from EU
doing something for the public good. But in dominated by lotteries, and are largely framed
level discussions about gambling.
fact [they] are increasingly, through their around the “either/or” choice of opening or
lobbying activities, being enabled to provide a
range, a whole range of mainstream, really
mainstream gambling activities under the
banner of lottery. So I don’t buy the argument
that lotteries are more benign. (Male,
Responsible Gambling Consultant)
[The] Danish government wanted to channel

unlicensed gambling into (a) licensed
regulators framework. It decided to go ahead
and open a multi-licensing regime, but only for
online betting, for online casinos and online
poker, and there were discussions about
online bingo. Obviously the industry wanted
online bingo to be part of the online reform
and to be privatised, but other stakeholders
thought that bingo should be kept in the
monopoly with the lottery games and that was
the outcome. (Male, Trade Association)
When the negotiations take place if there’s

any sort of give, often it’s the bingo that is not
allowed to be licensable to private companies
first. But that’s where the lotteries would see
themselves moving to next if they moved
anywhere. (Male, Commercial Online Bingo
Operator)
Charitable donations are a key feature of some commercial online bingo companies, as in this example of a
UK-based site raising money for veterans. Image taken by Donal Casey.
closing markets for particular gambling services Expanding the concept of fairness within concern of players. However, in many cases
to competition. The cases of Ireland and the online gambling regulation fairness appears in regulations only in relation
Netherlands discussed above provide The focus of EU level discussions on consumer to the integrity of the random number generator,
contemporary examples of such discussions. protection in online gambling has been on issues and transparency obligations.
such as problem gambling, underage gambling,
In our view policymakers and regulators should and responsible gambling. Greater attention Nevertheless, some interviewees spoke about
consider giving greater consideration – at the EU could be paid to fairness. fairness in broader terms and in ways not
and Member State level – to the fundraising role mandated by regulation. They mentioned issues
that online bingo does and could play for third Along with ensuring a minimum level of safety in such as ensuring a high return of money
sector organisations, and to exploring how such consumer markets, fairness has emerged as a wagered back to players, monitoring average
organisations could be supported in offering central principle of the EU’s consumer protection player loss, fair wagering requirements, and
services. In particular, as Member States move regulation. Both the Unfair Contract Terms ensuring quick and easy withdrawal of winnings.
towards liberalisation of online gambling, Directive and the Unfair Commercial Practices These stakeholders talked about substantive
stakeholders should consider how licensing Directive seek to embed fairness in Member fairness in online bingo in ways that shifted focus
requirements can be used to better harness States’ consumer regulation. Despite this, fairness away from the responsibility of the player to be
market gatekeepers, such as software and is rarely mentioned in discussions at the EU level aware of the terms under which the game was
network providers, for use by non-profit in relation to online gambling. For example, the offered, to the responsibility of the gambling
organisations, in order to open up more space for European Commission’s Green Paper and its service provider.
the third sector within newly-competitive online Action Plan on online gambling are largely silent
markets. on the issue of fairness and mention it only in In line with this approach, stakeholders should
relation to sports betting. The absence of fairness consider whether, and to what extent, a minimum
At the EU level, this could involve the creation of from such discussions is in stark contrast to the level of substantive fairness should be embedded
more space for discussions around the important prominent role that problem gambling plays in EU in Member States’ online gambling regulation,
role that gambling plays as a means of revenue debates and policy discussions, and in “soft” (not and whether the EU can and should play a role in
generation for third sector organisations, and legally binding) forms of harmonisation such as such a process. Existing EU consumer protection
more explicit inclusion of bingo in such the European Commission’s recommendation on legislation, such as that mentioned above,
discussions. At the Member State level, principles for the protection of consumers and outlines broad concepts of fairness and may
stakeholders should consider how third sector players of online gambling services. provide a spring board for such discussions.
organisations that wish to use online bingo as a Furthermore, existing fora such as the European
means of fundraising could be better supported The requirement that online gambling services, Commission’s Expert Group on Gambling
in so doing. Perhaps policymakers could consider including online bingos, are offered in a fair and Services could provide space for discussions of
incentivising software providers to work more transparent manner was mentioned by most how the concepts of substantive fairness could
effectively with small non-profit organisations regulators and operators as an important have concrete application in the online gambling
wishing to offer online bingo but lacking the component of current approaches to gambling sector.
technical expertise, for example. regulation in Member States. It is also a key
A screenshot from an internet search engine, suggesting player concern with the fairness of online bingo.
Image taken by Donal Casey.

Top 22 European Union-level cases on the regulation of online bingo

Unlike with the other three case studies in our research, there is no clear line of legal cases on online bingo regulation at the European level. However there
are many cases dealing with on-line gambling that impact online bingo.
NB: CJEU = the Court of Justice of the European Union. The CJEU “interprets EU law to make sure it is applied in the same way in all EU countries, and
settles legal disputes between national governments and EU institutions. It can also, in certain circumstances, be used by individuals, companies or
organisations to take action against an EU institution, if they feel it has somehow infringed their rights.” (http://europa.eu/about-eu/institutions-bodies/court-
justice/index_en.htm, original emphasis).1
EFTA court = the Court of Justice of the European Free Trade Association. This has jurisdiction over the three states (Iceland, Liechtenstein, and Norway)
that are signatories to the European Free Trade Agreement and parties to the European Economic Area Agreement, which guarantees the free movement of
people, services and capital. These three states are not members of the European Union.
Citation and year of Summary

judgement
Case C-275-92 Schindler UK legislation prohibited the importation of lottery tickets and promotional material relating to lotteries. Held by the CJEU that lotteries were a
service for the purpose of the EU Treaty and the prohibition on the importation of tickets and promotional material from other Member States
1994 constituted an obstacle to the free movement of services. However, given the peculiar nature of lotteries, Member States could restrict the provision
of lottery services from other Member States given the concerns of social policy and the prevention of fraud.
Case C-124-97 Läärä Finnish legislation granted monopoly rights for the operation of slot machines. Held by the CJEU that the provisions relating to freedom to provide
services did not preclude national legislation that granted exclusive rights for the operation of slot machines given that such regulation sought to
1999 achieve public interest objectives such as the protection of consumers, the mitigation of problem gambling and the prevention of crime and fraud.
Case C-67-98 Zenatti Italian legislation restricted betting on sports events to events supervised by the National Olympic Committee and the National Union for the
Improvement of Horse Breeds. Held by the CJEU that Member States may restrict the free provision of sports services by granting special or
1999 exclusive rights to certain organisations provided the legislation seeks to achieve social policy objectives and the restrictions are not
disproportionate.
Case C-243-01 Gambelli The case concerned the regulation of the Italian sports betting market (see Zenatti above). Held by the CJEU that while Member States are free to
set the objectives of their gambling regulation, they must seek to achieve those objectives in a consistent and systematic way. In this case, although
2003 the Italian legislation had the stated objective of reducing gambling opportunities, the Italian state had encouraged participation in gambling and
engaged in the expansion of the national sports betting market in order increase tax revenues.
Case C-42-02 Lindman Under Finnish law, winnings from games of chance conducted in Finland were exempt from Finnish income tax while winnings from games of
chance conducted in other Members States were subject to Finnish income tax. Held by the CJEU that such a scheme directly discriminated
2003 based upon the nationality of the service provider and is prohibited by the Treaty. The Finnish government had failed to provide evidence as to the
appropriateness and proportionality of the discriminatory tax regime.
Case C-338-04 Placanica Italian sports betting legislation had the effect of prohibiting gambling operators that were quoted on regulated markets such as the London Stock
exchange from becoming licensed or authorised to offer services in Italy. Held by the CJEU that it was for the Italian courts to determine whether
2007 the licensing system genuinely contributed to the objective of preventing fraud or crime. Member States are prohibited from excluding as operators
companies whose shares are quoted on the regulated markets, and Member States may not impose criminal penalties on operators that offer
gambling services without a licence or authorisation where those operators are unable to obtain a licence or authorisation because of national law
that is in breach of EU law.
Case E-3-06 Ladbrokes Ladbrokes challenged three decisions to reject its application to offer online and offline gambling services in Norway. In Norway certain forms of
gambling could only be offered by the State monopoly while other forms of gambling, such as betting on horse races, could be offered by non-
2007 profit organisations. The EFTA court held that Member States could grant exclusive rights to offer gambling services in order to achieve social
policy objectives and could grant licences only to non-profit organisations in order to prevent gambling becoming a source of private profit.
Case E-1-06
EFTA Norway amended its regulations with the aim of reducing the number of gaming machines. It created a state monopoly for operating the machines.
The EFTA Court held that the exclusive rights system that was introduced in Norway was a more effective means of achieving the social protection
2007 objectives of the legislation compared with other options, such as a licensing system.
Case C-42-07 Liga Portuguese regulation granted Santa Casa, a non-profit organisation, the exclusive right to offer lottery and sports betting services, including via
Portuguesa electronic means. Held by the CJEU that Member States may extend exclusive rights to offer gambling services to online gambling. Furthermore,
Member States may prohibit online gambling operators licensed in another Member State from offering games of chance over the internet within
2009 their territory.
1 Last accessed 10 May 2016.

Citation and year of Summary

judgement
Case C-409-06 Winner German regulation granted monopoly rights to provide lotteries and sports betting. The German courts asked the CJEU whether national gambling
Wetten regulation that was in breach of European Union law could still be applied during the transitional period, before being amended. The CJEU held
that national gambling regulation that is inconsistent with European Union law cannot continue to apply during such a transitional period.
2010
Case C-316-07 Markus German regulation granted monopoly rights to provide lotteries and sports betting. Held by the CJEU that Member States may opt for a system of
Stoß monopoly rights to ensure a high level of consumer protection. However, Member States must ensure that the monopoly does in fact pursue this
objective in a consistent and systematic manner. In this regard, the monopoly could not engage in advertising that sought to encourage or
2010 stimulate participation in gambling or expand into offering “riskier” games in order to maximise its profits.
Case C-447-08 Sjöberg & Swedish legislation prohibited the advertising of unlicensed gambling offered by operators based in Sweden, as well as gambling that was
Gerdin operated from other Member States. The CJEU held that Member States could restrict the advertising of commercial gambling in order to prevent
gambling becoming a source of private profit. However Member States could not have stricter penalties for unlawfully advertising gambling offered
2010 from another Member State than for unlawfully advertising unlicensed gambling offered from that territory.
Case C-203-08 Betfair The Netherlands provided monopoly rights to offer and promote games of chance to customers in the Netherlands, including games offered over
the internet. Held by the CJEU that a monopoly rights system may be justified in order to prevent fraud and crime.
2010
Case C-46-08 Carmen German regulation granted monopoly rights to provide lotteries and sports betting. The CJEU was asked whether Germany was required to allow
Media Group an operator licensed in Gibraltar to offer betting services in Germany. The CJEU held that Member States are not required to recognise
authorisations to offer gambling services issued by another Member State.
2010
Case C-64-08 Engelmann Austrian legislation required that only public limited companies established in Austria could apply for a casino licence. The CJEU held that such a
requirement constituted discrimination based upon the nationality of a company. Such a restriction on where companies could be established
2010 could not be justified and was not proportionate.
Case C-258-08 Same issue, and decision, as Case C-203-08 Betfair (above).
Ladbrokes Betting
2010
Case C-347-09 Dickinger Austrian legislation reserved to the Austrian state the right to offer gambling services. The Austrian state granted only one concession to offer
& Ömer casino games over the internet. The CJEU held that a system of monopoly rights can be justified in order to ensure a high level of consumer
protection, but the monopoly operator must operate in a way that is consistent with such an objective. Furthermore, the CJEU held that Member
2010 States are not required to recognise authorisations granted by another Member State.
Case C-212-08 Zeturf France granted monopoly rights to offer betting services for horseracing in France. The CJEU held that a system of monopoly rights can only be
justified where Member States seek a particularly high level of consumer protection owing to the restrictive effect of such a system on the provision
2011 of gambling services.
Case C186-11 Stanleybet Greece granted monopoly rights to OPAP to operate games of chance and certain forms of betting. The stated object of the monopoly system was
International to restrict the supply of gambling and to combat criminality in the operation of games of chance. The CJEU held that Member States may not grant
exclusive rights to operate games of chance where the legislation does not genuinely seek to limit gambling opportunities in a consistent or
2013 systematic manner and where the public authorities do not have strict control over the monopoly operator’s expansion. At the time, OPAP had
expanded to offer games of chance in Cyprus.
Case C-156-13 Digibet The case concerned the legality of an operator licensed in Gibraltar offering games of chance and sports betting over the internet to customers in
Germany. The provision of games of chance via the internet was prohibited in all but one of Germany’s states. Held by the CJEU that the Treaty did
2014 not preclude such a situation provided the legislation was proportionate.
Case T 721-14 Belgium v Belgium sought to annul a European Commission Recommendation on principles for the protection of consumers and players of online gambling
Commission services and for the prevention of underage gambling online. Belgium argued that the Commission did not have the power to adopt a legally
binding instrument that sought to harmonise Member States’ online gambling regulation. The CJEU held that the Recommendation was not legally
2015 binding on Member States and therefore could not be annulled.
Case C-336-14 Sebat Germany introduced a licensing system for sports betting, having previously had a system of monopoly rights. Germany’s previous monopoly
Ince system had been held to be contrary to European Union law (see Case C-409-06 Winner Wetten;Case C-316-07 Markus Stoß and Case C-46-08
Carmen Media Group). No licences had been granted and the German court observed that the previous monopoly system was, in practice, still in
2016 effect. Held by the CJEU that Member States may not criminally prosecute an operator, licensed in another Member State, for unlawfully offering
gambling services if the existing monopoly rights system is ruled contrary to European Union law by the national courts.
CHAPTER 5: SOME LESSONS FROM

THE COMPARATIVE PERSPECTIVE
2 The need for context-specific

When we began the research for the Bingo Project, we obviously wanted to learn about bingo consideration of whether non-
regulation in our four case studies. But we also aimed to contribute some new perspectives to commercial actors should be
debates about gambling regulation. In particular, we hoped that bingo could offer a distinctive privileged as bingo operators by
lens on some long-standing concerns within law, politics, and political economy, including around regulators, taking into account how
the role of the state; the role of commercial and non-commercial actors; and the role of gender such actors use proceeds, how they
in regulating chance. In this chapter we highlight some of the ways in which our findings, across are connected to players as donors,
all the case studies, might add to those existing debates. and how they mobilise volunteers.
Across all four case studies, bingo has benefited
from its association with fundraising for good
causes. This has occurred because it is linked,
1 The value of expanding the concept procedures such as the public posting of game
variously, to charitable lotteries (online EU);
of ‘responsible gambling’ to better rules. More substantive concerns about the
working class associational forms (England and
reflect fairness for players and workers fairness of the game, and especially the rates of
Wales); service clubs (Canada), and sports
return to players, are minimised in both the EU
As several researchers have argued1 problems associations (Brazil). Using Sytze Kingma’s notion
and Canada. The assumption is that informed
associated with gambling consumption are over- of the charitable alibi for gambling law reform,2
players can choose whether or not to accept the
whelmingly discussed in languages borrowed we can say that the charitable alibi has been
operator’s game terms. In England and Wales
from psychological literatures on addiction. This essential for bingo’s legalisation. Unlike with
(where all stakes have to be returned to players)
has contributed to a policy and research lotteries that were often legalised to increase
regulations focus on the need to display
landscape that is heavily skewed towards revenues for states, non-profit groups are typically
participation fees, rather than on limiting what
medicalised or therapeutic interventions. It involved in directly running games rather than
can be charged to participate as a proportion
also results in the privileging of increasingly simply receiving a share of profits, and they have
of stakes.
formalised measures that enable individuals often taken very active roles in lobbying for law
who are considered vulnerable to harm through reform and protecting their interests.
The predominant focus of responsible gambling
excessive consumption to voluntarily abstain from policies on problem and at risk gamblers makes
play. Although non-commercial actors are central
it more difficult to hear, and respond to, the
stakeholders in bingo, their centrality to regulation
interests of workers (paid and unpaid) in bingo. In
Our analysis of bingo confirms the need to varies considerably, within and across case
the law and policy debates of many jurisdictions
expand this addictions-focused approach. studies. In Brazil non-profit third sector partners
psychologists are far more likely to be consulted
Whether framed in terms of problem or at risk did not play a visible role in policy debates
by gambling regulators than organisations
gambling (England and Wales), problem during the legalised bingo era. In England and
representing gambling workers. The under-
gambling or gambling addiction (EU); or Wales working men’s clubs have diminished
inclusive understanding of who counts as an
responsible gambling (Canada), consumer in significance within debates about bingo
expert creates a cycle whereby policy is more
protection initiatives in legal bingo are regulation: the commercial sector is the key voice
and more driven by psychological literatures on
overwhelmingly focused on treatment services nowadays. In BC charities were eclipsed as the
addiction (where bingo is rarely a focus), and less
and self-exclusion policies for the very small actors conducting and managing games in
and less reflective of experiences on the ground.
minority of people who identify as being unable association bingo halls after the province took
In the England and Wales and Canadian case
to control their gambling (and who usually exhibit over that role, making the survival of
studies, some employees expressed anxiety
this problem through excessive spending on independently licensed charitable bingos
about measures to prevent excessive play, and
products other than bingo). In Brazil, where bingo conducted in a charity’s own premises especially
worried that they would be held responsible in
is illegal, we encountered frequent discussions significant. In Ontario, in contrast, charities have
the event of a problem. In Canada, some
about the compulsivity of its players. partnered with the province and commercial
unpaid workers spoke of feeling coerced into
gaming service providers within ‘c-gaming’
In the case studies where bingo is legal, volunteering in bingos as a condition of receiving
facilities, where the association of bingo with
preventative measures intended to keep players services for their family members. It is necessary
volunteering and local-level benefit to
responsible are prioritised, for example via to significantly expand debates about responsible
communities is a key defining feature. In the EU,
information leaflets to overcome myths, posters in gambling to allow such concerns, and such
online bingo is used by a number of charitable
toilets, or notifications about time spent playing. expert stakeholders, to feature more prominently
lotteries to raise funds. These relatively large
Fairness is often only mentioned with reference to in policy debates.
organisations have a strong lobbying presence at
equipment standards (such as those affecting the the national level, especially in countries such as
generation of bingo numbers), or transparency the Netherlands and Ireland. They are also
represented at the European level by
organisations such as the Association of Charity
Lotteries in the EU. By contrast, smaller charitable
1 See for example Reith, G. 2007. Gambling and the Contradictions of Consumption: A Genealogy of the ‘Pathological’ Subject. American Behavioral Scientist 51(1): 33–55;
Nicoll F. 2012. ‘Bad habits: Discourses of addiction and the racial politics of intervention.’ Griffith Law Review 21(1): 164–189. Cassidy, Loussouarn and Pisac. 2013. Fair Game:
Producing Gambling Research (The Goldsmith report). London: Goldsmiths.
2 Kingma, S. 2008. ‘The liberalization and (re) regulation of Dutch gambling markets: National consequences of the changing European context.’ Regulation & Governance 2(4),
p.448.

Older people playing card bingo in Brazil. Image credit: Senior week – bingo at the senior’s day centre. www.flickr.com/photos/prefvotuporanga/ ASCOM Prefeitura de Votuporanga
organisations do not appear to be key the sector. Its online bingo site has since shut support for gambling as a mutual aid form of
stakeholders in discussions around online down. fundraising, including the fact that it has a long
gambling regulation. history in many jurisdictions, is rarely a compliance
Notwithstanding such examples, our case studies concern, and is run on such a small scale that
One response to that divergence – one we heard of bingo regulation do not lead us to recommend transparency is relatively straightforward to ensure.
from some interviewees and that was reflected in a blanket restoration, or bolstering, of the Bingo players can intuitively judge the fairness of
an early report from Ontario on bingo regulation in charitable role in gambling. A key lesson from our the returns being made via prizes if the scale of
1990 – is to put charities ‘back in the driving research is that the non-commercial sector is play is limited – something that can not be said of
seat’3, via better support for their attempts to use diverse, and that its privileged promotion should large scale lotteries.
equal chance gaming for good causes. For be considered carefully. In particular charities
example, some Canadian interviewees favoured should not be assumed to represent ‘the However in other instances charities may have
rules to ensure that private gaming providers and community’ or ‘the public’ interest in gambling, almost no connection to players. Under such
provincial governments were not capitalising on without further exploration of how they use circumstances, the automatic privileging of non-
the charitable connotations of bingo without proceeds, how they are connected to players commercial interests needs further exploration. For
giving a correspondingly high level of control to as donors, and how they mobilise volunteers. example, players may not be particularly interested
charities to determine the use of proceeds. In in donating to charity: they may simply wish to play
England, we interviewed one charitable For example, some good causes funded using bingo and socialise with their friends and family. In
organisation that had found online bingo to bingo proceeds are closely linked to players as some places they may be required to do so under
be more successful than traditional raffles at donors. This is especially true of members’ clubs, arrangements that offer low prize boards in order
reaching women, and younger people, as donors. many religious organisations, and First Nations that funds are set aside for organisations that are
However charity sector bodies did not have bingo communities. In such instances bingo is a form very distant from their own communities, as when
on their radar, and the national gambling regulator of mutual-aid style fundraising for a group with a gaming proceeds are extracted from players in
primarily consulted with charities in relation to distinctive class-, gender-, nation-, and age–based bingo halls located in poor neighbourhoods to fund
lotteries. As a result it was challenging to demographic. In our view there are good reasons middle class sports clubs or school associations in
disseminate that organisation’s experiences within for regulators to extend privileged treatment and other areas.
3 Charitable gaming: putting the charities back in the driver’s seat. Ministry of Consumer and Commercial Relations. Toronto. 1990.
Relatedly, if use of volunteer labour is required for and the key role of the game in non-commercial We have encountered similar ‘culture clashes’
organisations to access charitable exemptions and religious spaces. However the game itself is around policies that seek to move customers
from gambling prohibitions (as in Canada, and also seen as distinctive due to its association with away from cash and into account–based play
many parts of the US), volunteers need to be soft, low-stakes social play: in fact some players (evident in both BC and England and Wales).
consulted as a separate group of regulatory don’t regard bingo as a form of gambling. These policies are motivated by concerns about
stakeholders. Charities should not be assumed to money laundering, and the impaired ability to
speak for them. Some stakeholders we interviewed wished track the play of cash users for responsible
regulators to take more account of bingo’s gambling purposes. They have been designed
A further example of the importance of exploring distinctiveness. They tended to want regulators with high-spenders, and machine users, in mind.
charitable gaming in greater depth can be found to get to know the game, and its distinctive However in bingo many customers have a strong
in the case of online bingo. In general the very atmosphere, better. Others felt that bingo’s preference for cash, and some find it helps them
large scale of play involved in online bingo, and survival depended on the enhanced ability to limit their spending.
the relative anonymity of players, means that it not of operators to offer other forms of gaming
generally used as a means of mutual aid style (especially electronic bingo and gambling Developing alternatives to such generic polices,
fundraising. However online bingo is offered by machines). As a result those interviewees were which are attentive to the risks that exist in the
a number of large scale charity lotteries in EU generally supportive of standardised rules and sector and the environment that makes it
Member States, and recent debates in Ireland procedures across gambling sectors (eg to distinctive, requires that regulators have a deeper
and the Netherlands shed light on the important prevent underage access to halls; to introduce understanding of operational bingo expertise,
role bingo plays in charity fund raising activities. responsible gaming measures). and the confidence to design bingo-specific
The level of transparency with regard to how standards. Given that the bingo player
donations are used varies significantly, as does It is possible – and we think valuable – for demographic is poorly represented in most
the disclosure of the profits made through regulators to avoid either/or decisions on this regulatory agencies, this will likely require
partnerships with commercial operators. question. Specifically, while it is true that bingo considerable training.
operators in all four of the case studies rely for
3 The need for rules that reflect the their profitability on ‘harder’ forms of gambling, 4 A potential role for regulators in
in three of those case studies people can choose
distinctiveness of bingo as a game, supporting and preserving everyday,
to legally engage in those forms in other
and a playing environment vernacular forms of play like bingo
“Some of them look at bingo and there is this kind
environments. Bingo is thus not simply a soft and
There is an ongoing discussion among gambling
of… it’s patronising. It’s slightly insulting and
social ‘mask’ for harder forms of gambling; there
researchers about the impact of globalisation on
disrespectful, because in their minds it’s a poor
is something attractive about the bingo
vernacular forms of play.4 Our research has
person’s casino, which of course it’s nothing but. I
environment (online or land-based), even if some
repeatedly returned to the issue of bingo’s
just wonder to what extent that influences some of
customers subsequently play slot machines
perceived distinctiveness as an everyday, local
the regulators [3 second pause]. What I mean by
there.
form of gambling, materially embedded in
that is that they don’t spend enough time or they With this in mind, it would make sense to regulate ordinary life in a variety of ways (the local church
don’t really get to know the product.” (male, ‘harder’ gaming products on offer in bingo or members’ club or elderly care facility offering
commercial bingo operator, England). facilities as they are regulated in other gaming bingo every week; widespread advertisements for
environments, and to ensure the centrality of online bingo on social media; the dabbers that
Do players, operators, politicians, regulators, bingo to a bingo facility (eg by looking carefully are available for purchase in budget shops; and
judges, and the wider public see bingo as a at the use of space, the times in which bingo is so on). As the game moves online, and as
distinctive gambling sector? If so, what impact available, the prominence of bingo versus technologies devised in one jurisdiction are
should this have on how bingo is regulated? machines in advertisements for the facility, etc). transplanted into another, in some places the
These were key, recurring questions from our Furthermore, consideration should also be given game is changing form quite rapidly. Automated
research, and they relate to broader debates to whether and how such approaches to variants, and new formats of numbers and
about the harmonisation of regulation across regulation could be implemented in the online patterns (especially those derived from the North
gambling sectors. environment. American 75 number variant) are increasingly on
offer.
There are many topics that came up in our case However our research suggests that the
studies under the theme of standardisation, imposition of generic rules treating bingo In the light of such developments, in our view it is
including taxation rates on bingo in relation to premises or websites as if they were casinos is past time for policymakers to explicitly consider
other sectors (England and Wales); differences in unwise. As is clear from the example of ‘dusting whether national gambling regulation should aim
regulation between online and land based bingo off’ rules in BC, casinos are poor generic models to support, and preserve, vernacular forms of
(EU; England and Wales); and perceived for risk-based regulatory standards across play. Support for vernacular sports, and other
inequalities in the ability to offer the same range gambling sectors. When such standards were manifestations of everyday culture (such as
of ancillary gaming products as can be offered ‘cut and pasted’ into provincially-run bingo popular music), is taken for granted as a
by operators of casinos, or race tracks (Canada). facilities they lead to inefficiencies; unnecessary legitimate part of a state’s role in many
Bingo is typically seen as distinctive because of burdens on operators; and culture clashes. They jurisdictions. Policy makers and regulators could
the player demographic (in terms of age, class, also harmed the distinctive appeal of bingo, for likewise consider the value of preserving the
gender, First Nations status, or sometimes all four) paid and unpaid workers and for players. distinctiveness and key features of vernacular
4 See for example Cassidy, R., A. Pisac and C. Loussouarn (Eds.). 2012. Qualitative research in gambling. Exploring the production and consumption of risk. London: Routledge;
Kingma, S. (Ed.). 2010. Global gambling: Cultural perspectives on gambling organizations. London: Routledge.

forms of gaming, such as those evident in bingo, through international or regional bodies such as
where they exist. the International Institute of Municipal Clerks; the
Congress of Local and Regional Authorities of the
There is of course a risk that regulators may be Council of Europe; the Council of European
less likely to approve game innovations if they Municipalities and Regions; United Cities and
adopt an objective of supporting and preserving Local Government, or the Commonwealth Local
vernacular gaming forms. No doubt policymakers Government Forum.
would debate this issue. But in our view the risks
are worth it. In particular, explicit conversation At the same time, however, our research shows
about whether to adopt this objective will help to that ‘everyday’ gambling is increasingly affected
de-centre the Las Vegas casino as the imagined by transnational rules and standards-setting.
reference point for national debates about Effective oversight requires close cooperation
gambling. In many jurisdictions, US-style resort between national and supranational regulators.
casinos – and the foreign investors that seek to This is especially evident as bingo has moved to
profit from them – seize opportunities when the online environment. For example the
reform potential emerges in gambling law and European Commission has recommended
policy. Games like bingo, dog-racing, dominoes, particular practices in relation to responsible
chase the ace, la Lotería (Mexicana); jogo de gambling regulation, proposed the creation of
bicho, etc. are at a distinct disadvantage. It may common technical standards for online gambling
be necessary to design a policy environment that technology, and formalised cooperation and
helps lawmakers and regulators remember that a information sharing between EU Member States.
lot of gambling is, and always has been, run on In our view the emergence of online gambling
an ‘everyday’ basis, as an ancillary activity in makes collaboration on technical standards
places primarily used for other purposes. Bingo, especially important. Such measures can assist
in particular, challenges assumptions that countries (such as Brazil) that may choose to
gambling is a ‘destination’ or ‘resort’ activity; liberalise their gambling markets in ways that
instead, it shows that gambling is local, everyday, account, from the outset, for online play.
and familiar (in both senses of the word).
Debating whether such vernacular forms of 6 Is gender relevant to the regulation
gambling should be supported, and preserved, of bingo? A diverse answer
would be one way to open space for alternative,
non-casino centered regulatory conversations. A key question animating our research in the
Bingo Project was whether the female-dominated
nature of the game effected its regulation.
5 The need to better support
international collaborations across Our answer to that question, across the case
local governments that license low- studies, varied. In two of our case studies
level forms of gambling such as (England and Wales; Canada) the player-base is
bingos unambiguously predominantly female; up to 80%
In three of our case studies (Brazil; England and of attendees are women according to some
Wales; Canada), sub-national governments have interviewees. This is not the case across the
taken central roles in gambling regulation. We board in the other two case studies (EU online;
expected to see lower levels of government Brazil) – but even then the game has a relatively
Prize won at a seaside bingo arcade in North West
taking a greater role in regulating gambling as high percentage of female participants, far higher
England, 2014. The prize is a wooden board that
we moved the spotlight away from casinos as than for EU online poker sites, for example.
holds paper bingo tickets in place for easier play.
Image taken by Andrea Shieber. destination gambling resorts (often of regional
One unexpected finding was that the gender of
importance, involving higher levels of
the players seemed to matter less to the early
government) to the sort of low level licensing
history of regulation than the gender of the
and permits associated with everyday gambling
organisers and intended beneficiaries of bingo
forms like bingos. However while national and
games. In England and Wales and Canada bingo
sometimes provincial or state governments have
exemptions were carved out of general gambling
taken measures to share expertise on gambling
prohibitions due to the lobbying pressure of male-
regulation amongst themselves, jurisdictional
dominated organisations that used, or wanted to
collaboration is substantially weaker at lower
use, bingo to fundraise. In England and Wales
levels of government. In particular, information
working men’s clubs (and political parties) were
sharing about best practices could be better
key lobbyists; in Canada service clubs (the Elks,
supported for local governments, within and
Moose, Kiwanis etc.) played the same role.
across case studies. For example, there are
Women were denied entry as full members to
opportunities to explore better collaboration on
some of these key lobbying groups until relatively
effective regulation of ‘everyday’ gambling forms
late in the 20th Century. In Brazil, elite male football
clubs were the intended beneficiaries of the mainstream halls. These dimensions of the game since the game had a tradition of being relatively
relevant reform, although there was little evidence environment can be overlooked if bingo is – welcoming of young people – and sometimes
of them lobbying Brazil’s federal government for wrongly – assumed to involve a conservatively children – if they were playing with family
bingo legalisation. Economic elites also secured traditional gendered atmosphere. members.
casino-like bingo environments in which to
socialise, network and conduct business. The We found that politicians and the media, in both The intergenerational and familial transfer of skill
ability of male-dominated associations to Canada and England and Wales, have and enthusiasm for bingo has been impacted by
influence law and policy was thus the key sporadically raised fears that poor women are under-age gambling restrictions. However, the
explanatory factor in bingo’s sometimes generous wasting state welfare benefits on bingo. In land-based game is still seen to be distinctive in
treatment from regulators. In England and Wales Canada, concerns focused on the bingo play of part because it is an unusually inclusive family
those associations were rooted in working class mothers, and First Nations women. But in general affair in age terms, spanning multiple generations.
social, economic, and political life; in Canada and concern declines with age. As an amusement Hence while many operators focus on combating
Brazil they were rooted in middle class social, associated with older women, licensed bingo what they called the ‘blue-rinse stereotype,’
economic and political life. tends to be tolerated as harmless. We have found including by attracting young people through
no evidence of political opposition to the elderly investment in new technology, others see the
In England and Wales, the fact that women play wasting their pension money on bingo play, future of bingo as in part reliant on maintaining
the game, and that it is associated with low- although there was some concern expressed the intergenerational feel of the game. This
stakes, family fun subsequently became crucial about the vulnerability of elderly female players requires it to be kept affordable for, and
to the commercial sector’s ability to survive (especially in Brazil). welcoming to, different age groups. As one Welsh
restrictions on gambling imposed by the 1968 interviewee put it when asked about the future of
Gambling Act. However in Canada bingo’s This helped us realise that age, in its intersection the sector:
with gender, class, and indigenous identity, is far
“The next five years, we will still be dancing. We
positive valence is far more associated with the
more significant to land-based bingo regulation
will still be dancing. It’s all about the people and
proceeds it generates for charities than the
that we had expected. In particular, the fact that
looking after (them) and not taking too much from
female-dominated player demographic. In
the game provides a space for inter-generational
them. Keeping them playing. Keeping them
Brazil, the negative connotations of bingo, and
socialising and play appears to be a key part of
dancing. Keeping them coming back... We have
especially its links to criminality, are typically
its appeal in England and Wales, and Canada.
got mothers, grandmothers, daughters, sisters,
associated with the preferences of male players
While many players enjoy bingo because it gives
they come in. I love to go to tables and say, there is
and owners for slot machines. Brazilian women
them a break from caring for their family, and
a young man, 22 year old young man and he’s got
who played slot machines, sometimes
provides a space where they can comfortably sit
his girlfriend. ‘That’s my girlfriend. I have come
compulsively, are more commonly regarded as
alone, others considered it a family activity. Hence
in with my grandmother as well.’ I love it.”
vulnerable – as “sad” or “mad” rather than “bad”,
strict enforcement of restrictions on young
(female, commercial bingo operator, Wales).
to use the distinctions common to literatures on
criminal justice.5 Such women were seen by people’s presence proved jarring in both places,
professionals to be particularly likely to benefit
from regulation aimed at responsibilisation or
treatment. For online bingo, although many
regulators discussed the fact that online bingo
attracted high rates of female players, they did
not link this to regulation. Most did not distinguish
between different forms of online gambling in
terms of regulatory approaches, although
some mentioned specific risks associated with
particular games, such as collusion in online
poker. In short there was no evidence that the
gender of the players affected the game’s
regulation in a uniform way across the four
case studies.
For the two cases where gender was most

significant (England and Wales, and Canada),
bingo games were sometimes quite sexualised,
flirtatious environments. Female players regularly
engaged in suggestive banter with male bingo
callers (when they were not insulting them for
drawing the ‘wrong’ numbers), and groups of
players were often ‘naughty’ in between games,
making jokes about body parts, touching
bottoms, and so on. Drag bingo is also popular, in
gay and lesbian venues and sometimes in
Mural painted on the side of a bingo hall, England 2014. Image taken by Kate Bedford. .
5 Worrall, A. Offending women: Female lawbreakers and the criminal justice system. Routledge 2002.

Gender and Bingo Regulation: reflections from across the case studies
Brazil I think there are lots of women who enjoy bingo. You’ve got people fighting over chairs. It’s four
My 85-year-old mother liked to play bingo For example, I had a group of older ladies who o’clock and it’s just opened and ‘That bitch is in
when the halls were open. I often took her in were dependent on bingo. Some were mildly my chair!’. There is 200 empty chairs. ‘Take
the car and would stay to watch. She really depressed women who stayed at home and had another one.’ ‘No I want mine!’ I’ve seen fist fights.
liked it and used to say things like “when I’m nothing much to do. They weren’t heavily Little old ladies. They are zealots (laughs). (male,
at the bingo, I’m out in the world …I forget all depressed but life was kind of boring and volunteer organiser of an independent charity
about my problems. It makes me feel super unhappy. They had gone to bingo and found it bingo, BC)
good.” One thing that I noticed a lot in the really exciting. It was like a ‘wow’ moment.
These women could become compulsive players You will notice lots of men in bingo. Well a lot of
bingos was that most of the players were people
so in those cases, where there was perhaps a them come with their wives. But I see a lot of
of a certain age, say 30 or 40 and older. Young
predisposition let’s say, bingo caused havoc. younger men, especially gay men. Gay men love
people didn’t go. It was very difficult to find a
(Female, treatment provider and researcher, bingo, I don’t know why. (female, charity bingo
young person there. There were more older
São Paulo). hall manager, Ontario)
people, more seniors.” (Male, former journalist,
Rio Grande do Sul).
One kind of bingo player is the grandma who, The new technology clashes with our typical bingo
instead of giving her pension to her grandson who customer. When Mabel comes to play bingo,
The old man uses the bingo as a space of
does not work to spend it all on himself… instead Mabel knows she can play thirty six bingo cards.
socialising and independence. It lets him do
she goes to the bingo to have fun with her friends. She’s done it for years and she knows how to play
something that is independent of the family.
She spends maybe 50 reais [ca. 10 pounds] per the game. Someone new comes in and they can
He goes to the bingo hall, maybe he takes a taxi
day, which she can afford. She sees her friends only play nine bingo cards. Well, in Mabel’s mind
to get there. He plays there and meets other
there, has a coffee break, drinks some tea. (Male, the new player has to pay their dues in order to be
people. He feels good, he feels connected to
industry expert, Rio de Janeiro). able to play that many cards to compete against
other people; he feels cherished; he socialises.
Mabel, right? With the introduction of bingo
He probably starts by playing card bingo at the
verifiers a layman can come in and with computer
tables and then his play evolves into machine Canada assistance play the same amount of cards against
bingo so that he can play ten, 20 or 100 cards Bingo, in the ‘80s, it was a social. We had tables Mabel and Mabel doesn’t like that. There is a bit
at the same time. Obviously the harm increases of bingo players; you know, ten or fifteen women, of a clash that goes on. (male, commercial bingo
with more intensive play... (Its) the same kibitzing back and forth. They prided themselves operator, Ontario)
mental mechanism as drug use. (Male, in how many cards they could play. Some of these
problem gambling service provider, Rio women can play twenty cards, right. I could
Grande do Sul). barely keep up with one little one. (male, England and Wales
commercial bingo operator, Alberta) If the wife went to the husband at seven o’clock at
The compulsion to play – well you never know night and said, can I have £30 to go to bingo he
when it will develop. It can happen at any The first (rule) that they started with was raising would give it to her just like that. If she said, can I
time. There was a woman in our group – the age to 18. That has affected bingo as well have £30 to go to a nightclub with the girls
she’s dead now – whose gambling became because when the kids came and learnt and tonight, he would kick up a storm. It’s that safe,
compulsive at 80 years-old. From age 80 to age played, they played with their grandmother, they clean environment to go to. You know what I
81 she lost four apartments. She had five, she played with their mum or whatever, and now mean? (male, commercial bingo operator,
lost four. She did not lose the last one because they’re not getting that. (female, charity bingo England)
her son found out what was happening. hall manager, Alberta).
(Female, former player, Rio Grande do Sul). When we opened our new build clubs through the
I have noticed lately we are starting to get some 90s, we would invite the chairman and the
younger people coming. But the majority of mine secretary of the local working men’s clubs to come
are definitely seniors. All time miserable – believe to the opening day, because I know that the wives
me. Absolutely hate women callers and are nasty of the members are going to be coming to us.
to them, they just are absolutely wicked to women Occasionally we would get the husbands with
callers. (female, charity bingo hall manager, them as well. (Male, commercial bingo operator,
Alberta) Wales).
Gender and Bingo Regulation: reflections from across the case studies (continued)
There’s always been a case of gran maybe We are looking to bring bingo kicking and
bringing her granddaughter to the bingo for the screaming into the 21st century and remove
first time and she’s 17 or 16 and somebody the, what was always the wrong view of bingo
points that out. As a manager you were always in the first place, the blue rinse brigade.
very unpopular stopping one of your best Remove the old lady syndrome from bingo.
customers bringing her underage Because it’s not that. (male, commercial bingo
granddaughter in to play bingo (male, operator, England).
commercial bingo manager).
You look at some of the age group that we have EU

here and these people are quite dependent on From the perspective of the profile of the player,
coming here. This is their life. You know that bingo is often said to be a specific game
might sound a bit dramatic—but I think that it consumed by, if you allow me and excuse me
is that for a lot of people. My mum plays bingo. please, mid aged to elderly ladies at mid hours
And I don’t know what she would do if she of the day. Well, this is common belief. (Male,
didn’t come here. This is it, all roads lead to National Regulator).
here. (female, commercial bingo operator, Wales)
Most bingo sites skin themselves up in pink
Before I came here, I had always assumed that and they’ve got ladies and ladies promotions,
it was pensioners. But there is a lot of single because that’s the perceived notion, that only
mothers. Most of the people I would say are women play bingo. That’s just not true. … A lot
below 50 – most of them haven’t retired yet. of men play online bingo. A lot of men go to
There is quite a lot of youngsters come, like 18 to bingo halls. My dad and my gramp used to go
25. They come all dressed up ready for town to bingo halls, maybe not in such large
after. You have quite a few, well, rich people who numbers, but there were always a good portion
like to play the machines. (male, commercial of men every night. (Female, Commercial
bingo employee, Wales) Online Bingo Operator)
Respondent: I am quite a regular. I come up Often I think people assume that bingo is
here and then I got voted onto the women’s something that only older people are
section committee. participating in and get involved in. The
Kate: Why do you think the women’s section traditional phrase I think is, Blue Rinse. It’s
runs the bingo? sort of an indication of a nod to the fact that an
Respondent: Because if it’s left to everyone else it ageing lady would typically dye her hair and
wouldn’t go on (laughs). They have been doing it therefore you are thinking, 65 plus. But online,
for years. I just think that it just took a couple of and particularly on the mobile you are seeing a
people to get in there and start organising it and much younger audience demographic. The
just happened to be the women. I guess it’s most recent stuff that we’ve been running we
always the women that are more into bingo than are seeing as young as 25 year old players
the men. I don’t know. They (the men) enjoy it getting involved which is a substantial change
when they are here. I wouldn’t say that they for the industry. It’s not something that’s been
would be bothered to organise it. (woman, non- seen before. (Male, Online Bingo Software
commercial bingo organiser, England) Provider).
APPENDIX 1: RESEARCH METHODS

AND APPROACH TO ANALYSIS
Our research for the Bingo Project involved a In all we conducted 217 interviews, with 255 Brazil
range of qualitative methods. It included respondents. This is far in excess of the 166
To understand the rise and demise of licensed
interviews with individuals involved in bingo, such interviews we committed to conduct in our
bingo in Brazil we examined the regulatory
as operators (commercial and non-commercial), original grant application. We are still being
systems, processes and requirements established
regulators (at many levels, from the municipal to approached by people who want to contribute
to govern the game and spoke to key informants
the supra-national), politicians, specialist lawyers, their experiences of bingo to the research.
with relevant experience of the game and its
judges, employees, volunteers, software
We uploaded the documents associated with regulation. We did not directly observe or
designers, and bingo equipment manufacturers.
these research activities (cases, reports, interview participate in any games because bingo halls
Interviews were semi-structured, so they ran more
transcripts, fieldnotes, etc.) into a software were unlawful at the time of the study. However we
like a guided conversation than a survey. Notes
programme called NVIVO. As we analysed the have sought to access the experience of bingo as
or a full transcript of the interview (whichever the
documents, the software helped us keep track of reported by key informants and in media accounts
interviewee preferred) were sent back to the
key themes (both those that were already in our and contemporaneous studies. Our data consist
interviewee in case they wished to make any
questions, and those that emerged during the of the following sources:
changes. Once a final version had been agreed,
an anonymised version could be created for course of the research). For example we were
Twenty semi-structured interviews with twenty four
analysis. able to compare how the issue of responsible
people knowledgeable about the game of bingo in
gambling appeared in court cases, versus in
Brazil during and after legalisation. We talked to
We conducted observations of legal bingo political debates. Similarly we could compare
current and former players and ex-bingo owners,
games in three of the four case studies. (We were whether attitudes to bingo regulation were
a judge, lawyers and public servants involved in
unable to find legal games in Brazil, and as a different for men and women (they weren’t), or
law enforcement, industry experts, journalists, a
condition of our research ethics agreement our for interviewees associated with charities and
politician, addiction researchers and support
researchers there could not participate in illegal commercial operators (they were). Towards the
services providers. Informants were located in São
gaming). We also conducted a systematic review end of the research we were also able to
Paulo and Rio Grande do Sul (the two states that
of relevant case law, legislation, and regulatory compare the key themes across the case studies,
hosted the highest numbers of bingo businesses
guidance, official records of political debate, seeing how clusters of themes emerged
when bingo was legal), Rio de Janeiro (a state that
consultations, and annual reports from bingo differently. In total we created tags for 37 themes
has a long tradition of popular gambling and is
regulators and operators. (many with sub-themes). Some of those themes
home to prominent industry analysts), and Distrito
have been developed into academic publications.
We collected much more data that we had Federal (the home of the nation’s capital and seat
For example Kate used material tagged under the
expected to. We had a sense before we started of the Federal government which is responsible for
themes ‘smoking,’ ‘gender,’ ‘class,’ ‘Race/First
our research that bingo was important. But we gambling legislation). One informant, interviewed
Nations’ and ‘technology’ in a recent conference
didn’t expect that we’d find so much material by Skype, is in London, UK.
paper on how bodies are regulated in Canadian
about its regulation that we’d have to increase our bingo halls. Some themes will develop in the Legislative and regulatory texts from the
allocated server space three times in order to coming months. For example material associated liberalisation period and recent bills that are part
store the information. We have a collection of over with the theme of ‘self-regulation’ is central to of the contemporary legalisation debate. We
1000 relevant legal cases across the four case Donal’s upcoming conference paper on risk and collected and reviewed 20 legislative texts on
studies, stretching back to 1845.1 We also have welfare in online gambling regulation in the bingo regulation at the national/federal level and
thousands of pages of political debate about European Union. analysed in depth the most significant sources for
bingo, stretching back to 1936.
the bingo sector (Lei Zico, Lei Pelé, Lei Maguito
and their respective Decretos). At the state level,
Interviewees, by case study Court Cases collected, by case study
Number of interviewees
N = 255 N = 1035 Number of cases collected 16 legislative sources were analysed from the
states of Rio Grande do Sul, São Paulo, Rio de
Janeiro and Distrito Federal.
10% Analysis of superior court cases (ten in the

16% 13% Superior Tribunal de Justiça (Superior Court of
Justice) and seven in the STF (Supremo Tribunal
Federal (Federal Supreme Court), and more than
16% 400 cases at the Tribunal de Justiça do Rio
29% 45% Grande do Sul (Court of Appeals of the State of
Rio Grande do Sul). Our data include also legal
cases from two other Brazilian states (São Paulo
and Minas Gerais) selected by reference to
45% specific topics that were actively litigated in those
26% regions, such as the licensing of occasional
charitable bingos in Minas Gerais.
Reports of the Commissão Parliamentar de

Brazil Canada Brazil Canada Inquérito dos Bingos (CPI dos Bingos), a
England & Wales EU England & Wales EU comprehensive parliamentary inquiry into
bingo that reported in 2007. It included
1 Allport v Nutt [1845] 1 C.B. 972, S. C. 3 D. & L. 233; 14 Lr J. C. P. 272; 9 Jur. 900. This case concerned illegal
gambling in a public house.
APPENDIX 1: RESEARCH METHODS

AND APPROACH TO ANALYSIS
contemporaneous surveys of bingo Classifications forclassificaons

Interviews the Englandbyand
'RoleWales Interviews
in bingo', In addition to informal scoping chats, we
England and Wales
establishments, interviews, and reports on site N = 115 conducted 40 semi-structured interviews with 41
visits conducted before the market was formally online bingo stakeholders between June 2015
closed. and March 2016. The types of organisations
3%
represented in the interviews included regulators,
Data and commentary published by non- 13% trade associations, lottery operators, commercial
governmental sources including industry analysts' operators, charities, testing houses, law firms,
reports on bingo and other forms of gambling in software providers, affiliate marketers and
Brazil; newspaper archives, journal articles, responsible gambling consultants.
websites, blogs and theses.
18% 57%
We undertook observations of online bingo sites
Canada during the research. Six online bingo sites were
chosen. They ranged from a large operator
We analysed relevant law, policy, and guidance running proprietary software, a leading UK brand,
(eg gambling legislation, licensing regulations 9%
a small commercial white label site, and white
at provincial, municipal, and First Nations level; label sites operated by charities. The
codes of practice; guidelines; information observations not only gave us a sense of
bulletins from regulators); annual reports from Commercial bingo mechanics of the game and the interactions that
provincial gambling operators and regulators; Commercial sport/social & holiday park occur during play, but also how regulations
and data on licensees and use of proceeds. We impact upon and are experienced by players as
Non-commercial/charity
have records of official federal and provincial they sign-up, play and (sometimes) win. We also
political debate on bingo (stretching back to Regulator
conducted participant observation at nine
1938), and we collected and reviewed 271 cases Service provider
industry conferences and events.
involving bingo. These ranged from high level
cases involving constitutional debates at the
Supreme Court of Canada, to divorce cases, Finally we conducted observations in different Classifications for the EU Interviews
labour disputes, and civil lawsuits over how to bingo spaces (seaside arcades, bingo halls, N =EUEU
Interviews
40 Interviews
divide up bingo winnings. sports clubs, holiday parks, working men’s clubs
etc). This gave us a chance to see how 5%
In Ontario in 2015 we conducted 19 recorded 3% 5%
regulations are interpreted in different venues, 3%
interviews (with 24 people); 3 unrecorded and to chat informally with staff and other 10%
10%
interviews with notes (with 3 people), and 5 customers. 32%
32%
scoping chats (involving 8 people). In 2015 in 3%
BC we conducted 25 transcribed interviews 3%
(involving 28 people), and a further 7 European Union
untranscribed interviews (involving 12 people). In At the European Union (EU) level we collected 10%
10%
total 59 interviews were funded by this research judgments from the Court of Justice of the
grant (with 75 people). We also participated in European Union and the Court of Justice of the 3%
bingo games, of varying scales, across British European Free Trade Association court, along 3%
2%
Columbia and Ontario. with the opinions of the Advocate Generals and 2%
10%
the available data relating to infringement 10%
England and Wales proceedings initiated by the European 22%
22%
Commission.
We analysed relevant legislation, case law, policy, Regulators
Regulators
guidance, and licensing statements on land- Although there is no sector specific legislation Charities
Charities
based bingo in Great Britain, including Hansard on gambling at the EU level, we collected EU Commercial operators
Commercial operators
references to bingo/housey-housey (going back legislation that applies to the online gambling Lottery operators
Lottery operators
to 1936); legislation, proposed legislation, and sector such as the Unfair Commercial Practices Testing houses
Testing houses
early day motions (going back to 1908); case law Directive, the Notification Direction, the Money Problem gambling/responsible gambling consultants
Problem gambling/responsible gambling consultants
(we collected a total of 163 relevant cases, going Laundering Directive and the Data Protection Lawyers
Lawyers
back to 1845), operator codes of practice and Directive and Regulation. Software providers
training manuals, regulators’ annual reports; and Software providers
Affiliate marketer
consultations and inquiries in which bingo was a Affiliate marketer
We used the European Commission’s Technical Trade Association
consideration. Regulation Information System (TRIS) as a means Trade Association
by which to identify changes in Member States’

We also conducted 98 interviews, with 115 regulation of online bingo.
people involved in bingo in England and Wales.
We spoke with a range of informants, from We examined policy documents and political
volunteers running small non-profit games in debates at the EU level relating to gambling, and
members’ clubs to commercial bingo executives. more recently, online gambling, with a focus on
We also targeted local level licensing officials the European Commission, the European
alongside national level regulators. Parliament, the Council of the European Union
and the European Council.
APPENDIX 2: ACADEMIC SOURCES

WE HAVE FOUND USEFUL
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Annals of the American Academy of Political Public Policy 17(7): 1024-1038.
Baker, T. and J. Simon (eds.). 2002. Embracing
and Social Science 556: 22–35.
Risk: The changing culture of insurance and Dixey, R. 1987. It’s a Great Feeling When you Win:
responsibility. London: University of Chicago ———. 2003. ‘“Gambling in Canada-From Vice to Women and Bingo. Leisure Studies 6(2): 199-
Press. Disease to Responsibility: A Negotiated 214.
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Baldwin, R., M. Cave, and M. Lodge. 2012. Douglas, A. 1995. British Charitable Gambling
20 (1): 121–49.
Understanding Regulation: Theory, Strategy, 1956-1994. London: The Athlone Press.
and Practice. Oxford: Oxford University Press. Casey, R. (2008). Working class women,
Downs, C. 2009. A Social, Economic and Cultural
gambling and the dream of happiness.
Balleisen, E., and D. Moss (eds.). 2012. History of Bingo (1906-2005). Berlin: VDM.
Feminist Review 89: 122–137.
Government and Markets: Toward a New
Eckert, S. 2015. The Social Face of the
Theory of Regulation. Cambridge: Cambridge Cassidy, R., A. Pisac and C. Loussouarn (Eds.).
Regulatory State: Reforming Public Services in
University Press. 2012. Qualitative research in gambling.
Europe. Manchester: Manchester University
Exploring the production and consumption of
Bedford, K. (forthcoming). ‘Bingo Regulation and Press.
risk. London: Routledge.
the Feminist Political Economy of Everyday
Edensor, T. et al. (Eds.). 2009. Spaces of
Gambling: In Search of the Anti-Heroic.’ Cassidy, R, C. Loussouarn and A. Pisac. 2013.
vernacular creativity: Rethinking the cultural
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economy. London: Routledge.
(The Goldsmith report). London: Goldsmiths.
———. 2015. Regulating volunteering: Lessons
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of Gambling in Great Britain.’ The Journal of
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Gambling Business and Economics 7 (3): 1-34.
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Bell, K. 2011. ‘Legislating Abjection? Secondhand
Gidluck, L. 2015. ‘Funding Policy and the
Smoke, Tobacco Control Policy and the Public’s Chazkel, A. 2011. Laws of Chance: Brazil’s
Provincial Lottery: Sport, Culture and
Health’. Critical Public Health 21 (1): 49–62. Clandestine Lottery and the Making of Urban
Recreation in Saskatchewan.’ In P. Elson (ed).
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Current Legal Problems 54 (1): 103–46. social history of working men’s clubs.
Haller, M. 1991. ‘Policy gambling, entertainment,
Bloomington, IN: Authorhouse.
Belanger, Y. (ed.). 2011. First Nations Gaming in and the emergence of black politics: Chicago
Canada. Winnipeg: University of Manitoba Chinn C. 1991. Better Betting with a Decent Feller: from
Press. Bookmaking, Betting and the British Working
1900 to 1940.’ Journal of Social History 24(4):
Class, 1750–1990. London: Harvester
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APPENDIX 2: ACADEMIC SOURCES

WE HAVE FOUND USEFUL
Hutter, B. 2001. Regulation and Risk: Morris, D. 1999. Volunteering: A Nice Little Job Schüll, N. 2012. Addiction by Design: Machine
Occupational Health and Safety on the for a Woman? In Feminist Perspectives on Gambling in Las Vegas. Princeton University
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O’Donnell, 113–38. London: Cavendish.
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Regulation of Gambling: European and Morton, S. 2003. At Odds: Gambling and Regulatory Enforcement and Compliance: A
National Perspectives. Leiden ; Boston: Brill Canadians 1919–1969. Toronto: University New Common Sense about Regulation’. The
of Toronto Press. ANNALS of the American Academy of Political
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and Social Science 649 (1).
Cultural perspectives on gambling Nicoll F. 2012. ‘Bad habits: Discourses of
organizations. London: Routledge. addiction and the racial politics of intervention.’ Stäheli, U. 2013. Spectacular speculation: Thrills,
Griffith Law Review 21(1): 164–189. the economy and popular discourse. (E.
Kingma, S. 2008. ‘The liberalization and (re)
Savoth, Trans.). Stanford: Stanford University
regulation of Dutch gambling markets: National Reith, G. 2002. The Age of chance: Gambling
Press.
consequences of the changing European in Western Culture. London: Routledge.
context.’ Regulation & Governance 2(4): 445- Strange, S. 1986. Casino Capitalism. Oxford: Basil
———. 2007. Gambling and the Contradictions
458. Blackwell.
of Consumption: A Genealogy of the
Lange, B., D. Thomas, and A. Sarat (eds.). 2013. ‘Pathological’ Subject. American Behavioral Williams, R., R. Wood, and J. Parke (eds). 2012.
From Economy to Society? Perspectives on Scientist 51(1): 33–55. Routledge International Handbook on Internet
Transnational Risk Regulation. Studies in Law, Gambling. London: Routledge.
Paarlberg, L. et al. 2005. ‘Charitable Bingo in
Politics, and Society Vol. 62. Emerald Group
Indiana: Issues and Implications’. Nonprofit Williams, T. 2010. ‘Open the box: an exploration of
Publishing Limited.
Management and Leadership 15 (4): 433–48. the Financial Services Authority’s model of
Laybourn, K. 2008. ‘“There Ought Not to Be One fairness in consumer financial transactions.’ In
Parke, A., A. Harris, J. Parke, J. Rigbye, A
Law for the Rich and Another for the Poor M. Kenney, J. Devenney and L. Fox O’Mahoney
Blaszczynski. 2014. Responsible Marketing
Which Is the Case To-Day”: The Labour Party, (eds.) Unconscionability in European Private
and Advertising in Gambling: a Critical Review.
Lotteries, Gaming, Gambling and Bingo, Financial Transactions: protecting the
Journal of Gambling Business and Economics
c.1900–c.1960s’. History 93 (310): 201–23. vulnerable (Cambridge, Cambridge University
8.3: 21-35.
Press) pp. 227-45.
Light, R. 2007. ‘The Gambling Act 2005:
Phillips, J., B. Chapman and D. Stevens (eds).
Regulatory Containment and Market Control’. White, M. et al. 2010. ‘Bingo in Alabama: More
2001. Between State and Market: Essays on
The Modern Law Review 70 (4): 626–53 than Just a Game.’ Cumberland Law Review
Charities Law and Policy in Canada. Montreal:
41:509–32.
Littler, A. 2011. ‘Member states versus the McGill-Queen’s University Press.
European Union: The regulation of gambling.’
Phillips, S. and S. Rathgeb Smith (eds). 2011.
Martinus Nijhoff Publishers.
Governance and Regulation in the Third Sector.
Marionneau, V. 2015. ‘Justifications of national London: Routledge.
gambling policies in France and Finland.’
Planzer, S. 2014. Empirical views on European
Nordic Studies on Alcohol and Drugs 32(3):
gambling law and addiction. Springer.
295-309
Prestes Filho, L C. 2013. Inteligência Empresarial
Maurutto, P. 2003. Governing Charities: Church
37: O tempo livre como ativo economico. Um
and State in Toronto’s Catholic Archdiocese,
jogo entre o licito e o ilicito. CRIE-UFRJ: Rio de
1850–1950. Kingston, ON: McGill-Queen’s
Janeiro.
University Press.
Ragazzo, C.E.J. and Riberio, G.S.A. 2012. ‘O
Miers, D. 2004. Regulating commercial gambling:
Dobro ou nada: a regulação de jogos de azar.’
Past, present, and future. Oxford: Oxford
Revista Direito GV. São Paulo 8 (2): 625-650.
University Press.
Ramsay, I. 2006. ‘Consumer law, regulatory
Mohun, A. 2012. Risk: Negotiating Safety in
capitalism and the new learning in regulation.’
American Society. Baltimore: Johns Hopkins
Sydney L. Rev. 28 (2006): 9-35.
University Press.
WHO WE ARE
The researchers Dr Donal Casey, Lecturer in European Law, Kent Professor Toni Williams, Professor of Law, Kent
Law School Law School
Principal Investigator: Dr Kate Bedford, Reader in My research concerns multilevel and My current research concerns regulation,
Law, Kent Law School transnational regulation, and the role that law, economic development and the role of personal
My academic research is on law and political standards and other norms play in shaping finance products such as loans and insurance in
economy. I have conducted research on gender regulatory regimes. In particular, I am interested familial and household relationships. I have written
and sexuality in development lending, especially in how regulatory actors seek to legitimate their about microcredit and financial education, and
in Latin America, and on international debates activities. I have published in leading international about financial consumer protection in the wake
about care policy. I am interested in bingo journals including the European Law Journal, the of the recent financial crisis. Much of my work
because it is a key site of working class women’s Journal of Law and Society, the British Food focuses on the development of a transnational
gambling, and because it often mixes charity and Journal and Regulation & Governance. I was a model of personal finance regulation that aims to
commerce. I therefore think that it offers important fellow of the Hague Institute for the increase household dependence on consumer
lessons to academics and policymakers about Internationalisation of Law in connection with the finance products. I am interested in the gendered
gender, class, and the regulation of speculation. project Transnational Private Regulation: understandings of risk and responsibility that this
Constitutional Foundations and Governance model entails as well as the gender implications
I have also played bingo since I was a child, and I Design. I have also previously held a visiting of increasing household reliance on personal
enjoy learning about how the game is run, position at Osgoode Hall Law School (York finance markets. I have worked on these
regulated, and played in different places. University, Toronto) as a fellow of the Critical questions with colleagues in Brazil, Germany,
Research Law in Law and Society. Canada, Australia and Canada.
I led the research on this project, drawing on
previous research on bingo regulation in seaside I led the European Union (EU) case study that I was excited about the bingo project because it
Kent (England), and Ontario and Alberta examined the regulation of online bingo within the engaged with my interests in global and
(Canada). My favourite parts of the research are EU. This case proved a fascinating laboratory for transnational changes to regulation and
when people share their bingo stories with me. study as gambling, and online gambling in governance and gendered understandings of
particular, represent significant and long running risk. More specifically, the Brazilian case study
Dr Oscar Alvarez-Macotela, Research Associate, sites of contestation within the European Union. was an exciting opportunity to explore gender
Kent Law School Moreover, given the distinctive culture and aspects of debates about the effects of personal
My academic work focuses on law and character of bingo, I was interested to see how credit expansion and recent reforms to gambling
development. I have undertaken research on law the game is operated, played and regulated regulation.
and financial development looking at both when it moves from its traditional land-based
developed and emerging countries, and on environment to the virtual world.
international debates about policy and legal
reforms to boost local and regional economies. I Maria Luiza Kurban Jobim, Research Assistant,
have worked as a legal practitioner in international Kent Law School
business and commercial law, and I have My academic research focuses on consumer and
experience with social anthropological research regulatory law with particular emphases on the
examining oral histories of daily life in Uganda, economic and social aspects of law, and the
and on ethical finance. extent to which legislation contributes to
development.
I have worked on the case studies of England
and Wales and the EU. Working in the field of gambling regulation
allowed me to apply many of the lessons learnt
I think bingo is an intriguing activity. It is an old during my previous studies. I focused on the
game that has survived, and evolved, in many reasons why gambling, and particularly bingo,
countries. remain so popular and widely-practiced. The
interaction of legal and social issues in the
international regulation of gambling was also an
interesting research focus.
WHO WE ARE
The support team Helen Johnson, NVIVO Coding, Kent Law School Andrea Shieber, Communications Coordinator, Kent
I have coded some of the interviews for the Bingo Law School
Joao Araujo Monteiro Neto, Portuguese Translation, My role is one of communications support for the
Project. I have over ten years of research and
Kent Law School
project management experience in the legal, research team, helping to disseminate news of
I am a PhD candidate at Kent Law School. My
policy, charity and academic spheres. I have project events. I’ve also enjoyed employing my
work engages with the study of internet
worked as a barrister, research consultant, amateur photography skills to capture images of
governance and law. I am especially interested in
wellbeing specialist and policy advisor. I bingo memorabilia gathered by the team during
the impact of multi-stakeholder practices within
specialise in the use of innovate qualitative the course of fieldwork. Exposure to the world of
the Internet governance system.
methods, gender, service provision, emotions and bingo regulation was a major influence in my
I have translated the website and the transcribed desistance. decision to photograph people playing bingo for
the Portuguese language interviews for the an Adult Education class project. During visits to
research team. I am interested in how different Melina Malli, NVIVO Coding, Kent Law School my local bingo hall in Herne Bay I discovered for
I am a PhD Candidate in Applied Psychology,
groups engaged with the policy making process myself just how much it’s valued by players as a
SSPSSR (Tizard Centre. My academic research
around bingo in Brazil construct strategic legal space to enjoy the company of friends. Many of
focuses on attitudes and stigma, with particular
narratives to promote or block the regulation of the players are women who have been members
emphasis on children with intellectual and
gambling. for more than 15, 20 and even 25 years. They go
developmental disabilities within the school
on the same night each week, sit in the same
Mark Dean, IT support, Kent Law School environment. I have experience with semi-
seat, order the same drink and, as one of them
After finishing my MPhil, I worked in the NHS and structured and in-depth interviews. I have coded
explained, they ‘share a gossip, a laugh and a
in Social Services on a variety of projects many of the Canadian interviews for the project.
joke.’ For them ‘winning is a bonus’ but it would
supporting people with disabilities. I developed The Bingo Project grasped my attention because
seem the real bonus is the very existence of the
an interest in ICT whilst enabling people with it explores attitudes and believes about gambling.
bingo hall within the community.
limited speech to communicate using early BBC It also uses personal narratives and experiences
computers with specialist input devices. I then to better understand changes within the sector, Sarah Slowe, Research Support Administrator, Kent
worked for several years as a freelance consultant which is interesting to me. Law School
and trainer and in mainstream ICT support with a I provide administrative support for all aspects of
Microsoft partner company before joining Kent Linda Pitt, Transcription, LAPTOP Confidential research at Kent Law School, including research
I run a transcription company based in grant applications and grant management. I have
Law School.
Withernsea, specialising in transcriptions for been involved in the Bingo Project since the first
Sarah Gilkes, Assistant to the Research Support academic work. I have transcribed the English- pilot project based in seaside Kent towns, and
Administrator, Kent Law School language interviews that the research team have throughout both the pilot and this project.
I am responsible for assisting with KLS research conducted.
activities, including co-ordinating the organisation I provide excel wizardry and emotional support.
of internal and external conferences and This has been an interesting project for me to
workshops, providing administrative support to work on and it has been a pleasure to work with
the School’s research staff and centres, and Kate, Donal, and Oscar.
managing general post-award administrative
processes for research grants. I organise the
Bingo Project’s research events, booked most of
the research travel, and helped with the compiling
of data, reports, and webpages.
Advisory group Professor Amy Chazkel Dr Carolyn Downs

Historian of gambling criminalization in Brazil, Dr Downs is an expert in historical and cultural
Miles Baron
and Associate Professor of History at Queens analysis of bingo, and the former coordinator of
Miles Baron holds an M.B.A. from the University
College and the CUNY Graduate Center. the Leisure, Recreation and Heritage Research
of Leeds. Mr. Baron joined the bingo industry in
Professor Chazkel is the author of a socio-legal Group at the University of Salford. Carolyn has
1983. He worked for Mecca Bingo in a variety of
study on the criminalization of Brazil’s ‘animal pioneered research into virtual gambling and
positions such as Operations Director and Sales
lottery,’ Laws of Chance: Brazil’s Clandestine content-generated risks to young people from
and Marketing Director. His expertise and
Lottery and the Making of Urban Public Life in online social networking. She led the first UK
leadership in the sector are witnessed by his
Brazil (Duke University Press, 2011). Other study into gambling-related debt, and a pilot
appointment in 2012 as the Chief Executive of the
publications include articles on penal institutions, study into the relationship between leisure and
Bingo Association and, at the same time, Chief
illicit gambling, and forced labor in post-colonial under-age alcohol use. Her academic work on the
Executive of the National Bingo Game.
Brazil. social, economic and cultural history of bingo
Professor Colin S Campbell (1906-2005) acted as a springboard for her
Gambling law and policy expert; author of several Dr Ruth Cherrington
current research into various social aspects of
Dr Cherrington is a leading authority on the
key studies of charitable gambling in Canada. gambling. That research was featured in the BBC
history, development and decline of Working
Professor Campbell teaches criminology at documentary ‘Eyes Down! The Story of Bingo,’
Men’s Clubs. Brought up on a post-war housing
Douglas College, Coquitlam (British Columbia). broadcast in 2012.
estate where most residents regularly used the
Dr Emma Casey local club, Ruth witnessed the centrality of this Cherry Hosking
Sociologist specialising in women’s gambling institution to people’s lives. Decades later she With prior expertise as Company Secretary in
cultures. Dr Casey is Senior Lecturer in Sociology combined her sociological training with personal commercial property and the professional
at Kingston University. Her books include Women, experiences and insights to document this club. services industry, Cherry joined the Bingo
Pleasure and the Gambling Experience (Ashgate, Her book ‘Not Just Beer and Bingo!’ A social Association (the trade association of licenced
2008) which was shortlisted for the BSA Philips history of working men’s clubs, was published in bingo operators in Great Britain) in 2007. She is
Abrams Memorial Prize, and Gender and 2012. She has written academic articles on the Company Secretary to the Executive Council.
Consumption: Domestic Cultures and the club movement and she has presented at Cherry is also Company Secretary for The
Commercialisation of Everyday Life (edited with numerous conferences. She gives regular media National Bingo Game Association Limited
Lydia Martens, Ashgate, 2007). She is currently interviews on club-related issues, and is the (NBGA), which holds a remote bingo operating
working with the Mass Observation Archive on an owner/editor of the website licence from the Gambling Commission. The
ESRC funded project on the theme of gambling www.clubhistorians.co.uk. A member of the NBGA has operated games of combined bingo,
and households. Warwick Drinking Studies Network, Ruth is linking hundreds of clubs to play joint games,
currently Employability Manager at the School of since 1986.
Professor Rebecca Cassidy
Business and Law, University of East London.
Professor Cassidy is a gambling anthropologist.
She is the Principal Investigator for GAMSOC, an
ERC-funded project which used ethnography to
investigate the expansion of commercial
gambling in Europe. and coordinator of
Goldsmith’s network on gambling. She is the
author of several key research texts on gambling
including Sport of Kings: kinship, class and
thoroughbred breeding in Newmarket
(Cambridge University Press, 2002) and co-editor
of Qualitative Research in Gambling: exploring
the production and consumption of risk
(Routledge , 2013)
She writes an occasional blog about gambling at:
https://gamblingacrossborders.wordpress.com.
WHO WE ARE
Dr Sytze Kingma all aspects of licensing and is accredited by the Dr Jane Rigbye
Dr Kingma is a European gambling policy analyst. British Institute of Innkeeping Awarding Body Dr Rigbye is the Director of Commissioning at the
He works in the Organisation Sciences (BIIAB). David is also regional Chairman of the Responsible Gambling Trust (UK). She is
department of VU (University of Amsterdam). He Institute of Licensing (East Midlands) and a responsible for the Trust’s harm prevention and
is the author of several key texts on global member of the Board of the Institute. He has treatment programmes. Her doctoral dissertation,
gambling liberalisation trends, including Global contributed to Paterson’s Licensing Acts on the psychology of gambling, is titled: ‘Barriers
gambling: Cultural perspectives on gambling (Butterworths) on the Licensing Act 2003 and to Treatment Access among Young Problem
organizations (Routledge). Gambling Act 2005. Gamblers’ (Nottingham Trent University). Prior to
her current appointment, Jane was Head of Youth
Professor Roy Light Professor Debra Morris Services and Policy Development at GamCare.
Professor Light is a leading licensing barrister Professor Morris specialises in charity law, She has lectured on gambling studies at the
and academic analyst of gambling law. With property, and employment law. Her research has University of Salford (Salford Business School)
expertise in administrative law, licensing, and focused on many different aspects of charity law and at Nottingham Trent University (Division of
planning, he is a member of St Johns Chambers and regulation, ranging from the ‘public benefit’ Psychology), and has published a range of
(Bristol). He writes and lectures extensively, test through to the regulation of fundraising. academic and consultancy papers on gambling
regularly speaks at national conferences and Debra’s work on charity mergers and acquisitions and problem gambling.
provides training for local authorities and others. and the resolution of disputes in the charitable
He is professor emeritus at Bristol Law School, sector was carried out in close consultation with Jonathan Watkin
and a member of the Portman Group the charitable sector and this approach helps to Mr Watkin is a gambling industry specialist and
Independent Complaints Panel. He also sits on ensure that the recommendations are pertinent Senior Policy Development Officer with the
the editorial board of Licensing Review. and useful to charities. Debra has also published Gambling Commission (UK). He is the
on the legal position of private schools and not- Commission’s research liaison with the Bingo
Dr Alan Littler for-profit hospitals. Debra is currently examining Project.
Dr Littler is an academic specialising in gambling the impact of the Equality Act 2010 on charities.
law within the European Union. He is the author of Debra teaches Equity and Trusts, Land Law,
several key articles on European gambling Employment Law at the University of Liverpool.
regulation, including on remote gambling. He
practices at a gambling law firm in Amsterdam. Professor Gerda Reith (Chair)
Dr. Littler is also an ‘Extramural Fellow’ of the Professor Reith works in the sociology
Tilburg Law and Economics Center (TILEC) at department at the University of Glasgow. Her
Tilburg University (The Netherlands), where he research interests centre on problematic forms of
completed his PhD. consumption, particularly those considered risky
or ‘addictive.’ She is a leading expert in critical
David Lucas gambling studies, with publications including
David has over 30 years experience in licensing Consumption: Regulation and Excess (2005,
law. He specialises in all aspects of gambling, Routledge) and The age of chance: gambling in
alcohol, and entertainment licensing. With a client Western culture (2002, Routledge).
list which includes national and local operators, Professor Reith is a Gambling policy expert and
licensing and responsible authorities he has former Chair of the Research Panel at the
practical experience of all aspects of licensing Responsible Gambling Strategy Board.
and regulatory issues. David is the solicitor
instructed by Greene King in their landmark bingo
operating licence case. He provides training on
www.kent.ac.uk/thebingoproject

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THE BINGO

Rethinking gambling regulation

THE BINGO PROJECT:

Why bingo? So, taking gambling seriously in law and political

say I rob old ladies of their pensions. Which

advisor (laughs)” (male, bingo hall manager,

“What we established here in Brazil was bingo,

bingo as a neighbourhood game, a place for

individuals to socialise” (male, industry

analyst, Rio de Janiero)

forget these two elderly ladies, they must have

been in their 60s, 70s, loving it. They said, ‘we

are loving this. But you know who really loves

this?’ And I said ‘Who?.’ They said ‘our mom.’”

(male organiser of bingo-based entertainment

events in British Columbia, Canada).

“Gambling is at the boundary between personal

freedom and state intervention. On one side of the

boundary is the reasonable expectation of adults

who, within the law, exercise their right to live

their lives as they choose. On the other is the role

of the state: to recognise human frailty, and in

particular to respect its duty to protect children

and the vulnerable. As a Government and a

THE BINGO PROJECT: AN INTRODUCTION

THE BINGO PROJECT: AN INTRODUCTION

4 On-line bingo in the European Union (EU) state-approved monopoly providers, or

THE 10 COMMANDMENTS OF BINGO

THE BINGO PROJECT: AN INTRODUCTION

CHAPTER 1: THE REGULATION

Figure 1: Regional distribution of bingos in

Scale, distribution, and demographics A more comprehensive survey, conducted by the

CHAPTER 1: THE REGULATION

lotteries embraced the cause of bingo. They had

the attitude, so here’s the bingo game, we’ll take

care of anything about the game, we’re going to

There were judges who allowed Bingo Halls to

operate normally….And there was speculation

CHAPTER 1: THE REGULATION

laundering, tax evasion, and increasing violence.

To 43%, the bingo halls have no positive features.”

(CPI dos Bingos 2006, p.120)

certificate and the back taxes I was able to develop

a bingo on behalf of this small sports federation.

And this is what happened all the time. Licences

were obtained in partnership with small sports

rather than the big sports clubs that the

legislators had envisaged. (São Paulo, male,

former bingo owner).

Bingo Imperatriz in São Paulo, taken from p.1250 of the

“The [regulator] INDESP was a tiny organisation

CHAPTER 1: THE REGULATION

which shows that they really had a lot of capital

whisky. …The old bingo has became a chic leisure

The slot machine is the most harmful. I consider

the slot very harmful. They put the coin slot up

here at the level of your eyes, if they put it down

there at the level of your pocket, you will think