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What is Beheaded?
They recommended banning direct marketing by operators and affiliates except for essential account or safety communications.
The committee also suggested a ban on inducements (free bets, sign-up bonuses) as these promotions stimulate betting activity and recruit new or lapsed customers.
Another point of contention was content marketing and influencer promotions. The Lords committee advised treating this as advertising and, if a full ban were not immediately feasible, prioritising its prohibition.
What is Beheaded?
Lower barriers to entry could significantly widen the pool of potential game creators. Curwen sees opportunities not only for established and emerging studios, but for operators, suppliers, entrepreneurs and potentially entirely new entrants.
“The big change is that technology can increasingly provide the infrastructure,” he says. “The creator provides the idea. And I think that will make the industry much more interesting.”
For Yggdrasil, Game in a Box and Studio in a Box are therefore intended to become more than tools for its own development operation. Curwen envisages them supporting a wider creator ecosystem, although he acknowledges that proving the model commercially must come first.
How to play Beheaded
Kevin O’Neal, a DOCV board member, argued the scale of the investigation calls the GGL’s broader black market estimates into question. He cited the regulator’s 2025 activity report, which put the 2024 share at 23% (€547 million in gross gaming revenue), against Nielsen data suggesting a share of around 56%.
The trade body has long been critical over the discrepancy between channelisation estimates made by the regulator, and other independent reviewers.
The DOCV reinforced its calls for a unified federal licensing regime for online casino games and stronger enforcement mechanisms against illegal operators.