Ms Sue Rossiter:

I thank the joint committee for inviting me. I represent the Remote Gambling Association, the largest trade association representing the on-line gambling industry.

RGA membership is restricted to operators and software suppliers. The operators must be licensed for gambling purposes within the European economic area, the Isle of Man and the Channel Islands. The members of the RGA have substantial experience in engaging with legislators, regulators and other stakeholders to ensure remote gambling is conducted in a fair, safe and crime-free environment. This experience is based on operating in fully regulated jurisdictions where it is possible for private sector operators to obtain a licence on a non-discriminatory basis.

The licence objectives and the bulk of provisions in the heads are supported by the RGA. However, in our submission we set out a number of suggested improvements. Rather than restate all of the arguments outlined in the submission, I will recap our recommendations.

Although outside the scope of the legislation, the Government should acknowledge that the regulatory regime cannot be considered in isolation from the tax regime and should ensure the tax burden is not so onerous that it will undermine the regulatory system and its social objectives. Where possible, the expertise and experience of the gambling industry should be utilised by the Government and the regulator and a constructive dialogue sustained throughout the process. It should be established that remote operators must apply the regulatory requirements to those who are normally resident in the State.

On the OGCI, success will be dependent largely on appointing people with the right skills and experience. The OGCI should establish an intelligence-gathering and sharing function to help safeguard the integrity of sport. As a point of principle, licence fees should not exceed the cost of regulation and the requirement for an extensive range of suppliers to be registered with the OGCI should be removed or limited significantly.

We have questions on the definitions in the Bill. The definition of "bingo" should be expanded to cover all forms of the game, as this has caused us problems in other jurisdictions. Some flexibility should be introduced in order that the OGCI can take full account of management control factors as part of an assessment of overall viability rather than being overly constrained by the one criterion of having adequate reserves.

Customers should have the option of being able to exclude by particular products; the self-exclusion register should be restricted to Irish residents; the self-exclusion period should be a minimum of six months rather than one; and customers should be able to use other methods to self-exclude rather than being restricted to doing so in writing.

We recommend early engagement between the OGCI and its licensees to consider how best to apply the new regime in a way that is practical and effective. As others have mentioned, contributions to the new social fund, irrespective of whether it is voluntary or compulsory, should be based on a percentage of company gross profits, not turnover; the sponsorship rules should be amended in order that a potential source of valuable funding is not denied to professional sports; and there should be consistency between licensing periods for comparable land-based and remote gambling activities.

These are our key recommendations. We, too, will be more than happy to answer questions committee members may have.