This was a speech I made during the debate on the Gambling Control Bill and the Gambling Regulatory Authority of Singapore Bill on 11 Mar 2022 in Parliament.
As Parliament sits today to debate the Gambling Control Bill and the Gambling Regulatory Authority of Singapore Bill, a fact that should be at the forefront of our minds is this: Gambling may seem like harmless fun for many people, but it can be a scourge on families impacted by problem gambling.
The National Council for Problem Gambling’s 2020 survey found that almost half of Singapore residents aged 18 and above participate in gambling activities, with 6% reporting that they lack self control when gambling.
The survey found that gamblers with poorer self-control are more likely to regret the way they have gambled, have emotional problems and have family quarrels. Worryingly, 37% of Singapore residents with no income reported participating in gambling.
Regrettably, the avenues for Singaporeans to gamble have expanded over the years. Two casinos were opened in 2010 and in 2019 the Government raised the cap on the number of slot machines allowed and increased the floor space allocated to gambling. In 2016, Singapore Pools and the Turf Club were allowed to operate online gambling services, including sports betting. This remains a concern as, according to the NCPG survey, 23% of gamblers who participated in sports betting reported poor self-control.
With this mind, I would like to sound a note of caution about any further expansion of the space for gambling in Singapore.
Social Gambling
Social gambling is not disallowed by current legislation. This Bill explicitly legalises social gambling in Singapore.
On the one hand, the Government has said in the past that the law can and should reflect social norms and attitudes. As a matter of logical consistency, then, should the Government not be cautious about making social gambling explicitly legal, so as to avoid being seen to be issuing an official stamp of approval to gambling?
On the other hand, as a practical matter, since social gambling has never been illegal, what is the concrete policy gain in providing this inadvertent signal of acceptability?
I would therefore like to understand the Government’s reasons for explicitly legalising social gambling.
Gambling Among Minors
The Bill also does not proscribe social gambling by minors. May I ask the Minister of State why there will be no restrictions on minors engaging in social gambling? I hope this does not mean that the Government condones gambling by minors.
How does the Government intend to communicate to children, adolescents and their parents that it discourages gambling by minors?
I am also concerned about how explicitly permitting gambling for children could provide a gateway to more problem gambling habits later in their lives.
Current policy to prevent gambling by minors is inconsistent. While the minimum age is set at 18 for certain types of gambling such as 4D, TOTO or placing horse racing bets, it is set at 21 for casino gambling.
In recent years, the Government has raised the minimum smoking age from 18 to 21 so as to denormalise the use of cigarettes amongst adolescent youths, especially since most cultivate the habit between the ages of 18 and 21.
The NCPG survey similarly found that 35% of Singapore residents had their first gambling experience between the ages of 18 and 24 — the highest amongst all age groups. With this evidence in mind, can MHA consider taking the same approach as with smoking, and harmonise the minimum gambling age to 21 all across the board? This could ameliorate its pernicious effects of gambling on not just young people but also on their families and society.
Loot Boxes
I would now like to discuss a particularly challenging issue with respect to combating gambling by minors — loot boxes. Loot boxes are virtual items within games that can be purchased and redeemed to receive another random, desirable virtual item. Gaming companies have been pushing loot boxes in their games — especially in mobile games — leading to increased gaming spending and debt.
Many consumers of loot boxes are children. Research from the United Kingdom has found that of the 93% of children who play video games, 25 to 40% have made loot box purchases. Other research has found — consistently and unambiguously — a link between loot boxes and problem gambling.
This being so, I would like to ask the Minister of State as to how the GC Bill intends to regulate loot boxes in online games. Clause 9 of the GC Bill defines a lottery as a scheme to distribute prizes based on luck — and prizes here refer to money or money equivalent or any “thing of value”. Can I ask the Minister whether the GC Bill considers such virtual rewards to be “things of value” even when they cannot be monetised, such that operating any loot box system would be considered operating a lottery? If so, what will the regulatory regime for online game operators be like?
Several other countries have already sought to regulate or restrict loot boxes in online games. Belgium’s Gaming Commission has declared loot boxes to be gambling and hence illegal. The Netherlands Gaming Authority issued a legal opinion that some loot box systems contravened the Dutch Betting and Gambling Act, hence requiring the relevant game developers to change their mechanics, or face fines or even game prohibition.
In Asia, China has imposed daily limits on the number of purchased loot boxes that a player can open, while Japan has banned “complete gacha”, which is a system that offers rare prizes to players who successfully obtain a complete set of items through random draws.
Of course, game developers can and do find ways to circumvent these restrictions, but this is no reason to do nothing. The Government will just have to ensure regulation is sufficiently nimble to keep up with technology.
Education
I have spoken of law and policy thus far — but no amount of regulations and restrictions will be able to completely eliminate gambling activities in Singapore. In fact, one argument against prohibition is that it might drive gambling activities underground. We therefore need active educational efforts to discourage gambling among our population. With the introduction of the GC Bill, will there be greater educational efforts to discourage Singaporeans, particularly young people, from participating in gambling activities and delaying their first gambling experience?
I am glad to know that schools have, since 2021, been trying to teach students about the ills of loot boxes. I would urge MOE to continue to assess the efficacy of such programmes. Have such educational efforts been found to genuinely reduce loot box use amongst youth, and if not, how can such outreach be improved?
Conclusion
I understand that many Singaporeans gamble on occasion. However, the risk of problem and pathological gambling, and its often-accompanying financial ruin, is very real. On balance, the job of public policy in the area of gambling is to maintain moderation – to allow responsible adults to take part in this activity, but not so much that they ruin themselves, and to discourage impressionable children from taking up the habit in the first place.
In summary, I would like to call on the Government to reassess its position on social gambling and to take a strong hand against gambling by children, especially in the area of loot boxes. We should complement policy levers with better education against gambling. More generally, I call on Parliament to take a stronger stance against gambling.
I hope the Minister of State will be able to address the concerns I have raised on the Bills. Notwithstanding these concerns, I support the Bills.
