A regulated, competitive and responsible market

1. Regulate the market that actually exists

Digital activity does not vanish when prohibited; it moves channel, jurisdiction or payment rail. Good policy begins with an evidence-based map of providers, users, payment systems and complaint routes. Rules built on incomplete assumptions can burden visible operators while leaving opaque supply untouched.

We propose public registers of operators, beneficial owners, authorised domains, critical suppliers and final sanctions. A visitor should be able to verify authorisation without opening an account, and the register should preserve history.

2. Proportionate licensing and competition

Licensing should test financial capacity, management integrity, technical controls, prize solvency and customer support. It should not manufacture scarcity through arbitrary caps or entry fees that only dominant firms can meet.

Core duties—segregated funds, audit, security, age checks and financial-crime controls—are non-negotiable. Reporting intensity and guarantees can scale with activity and risk. Authorities should publish timelines, refusal criteria and appeal routes.

• Public register of licences, brands and domains.
• Technical criteria published before applications open.
• Guarantees tied to actual exposure.
• Orderly exit plans protecting balances and complaints.

3. Risk-based privacy and AML/CFT

Finding risk does not require collecting every possible data point from every person. Data minimisation reduces breach impact. A risk-based approach defines thresholds, warning signals, limited retention and human review, while telling users why data is needed and how errors can be corrected.

Blockchain analytics can support investigations but an automated score should not become conclusive proof. Users need a route to challenge false positives, and rules should distinguish self-custody from intermediated services.

4. Enforceable user protection

Protection requires clear rules for balances, withdrawals, promotions, advertising, conflicts and complaints. Account restrictions should carry a reason and a review channel.

Authorities should publish comparable aggregate metrics: withdrawal times, complaints, self-exclusions, security incidents and sanctions. Independent dispute resolution lowers the cost of making a valid claim.

5. Verifiable responsible play

Self-exclusion should operate across related brands. Deposit and loss limits should be easy to set and deliberately slower to raise. Risk detection must not become a marketing profile for vulnerable people.

Distributed ledgers may help verify an exclusion without publishing identity, but they still require governance, recovery, data minimisation and accountable operators. Pilots should be independently assessed before becoming mandatory.

6. Sustainable taxation and review

Tax design needs a clear base and must account for prizes, promotions and compliance costs. A high nominal rate does not guarantee revenue if consumers move outside the licensed market. Authorities should publish methods, actual receipts and channelisation.

Technology rules age quickly. Periodic review, open consultation and impact evidence should be built in. Success means less fraud, resolved complaints, effective channelisation, net public revenue and demonstrably lower harm—not simply more prohibitions.

7. Implementation, evidence and accountability

A credible reform needs a sequence, not only principles. The authority should first publish the market baseline, draft rules and licensing criteria, then run an open consultation with a response document explaining which comments changed the text. Technical testing should happen before commercial launch, while transition rules protect balances, pending withdrawals and valid complaints. Enforcement priorities should distinguish deliberate evasion from a correctable reporting failure.

Regulatory data should be useful outside government. Machine-readable registers can connect a legal entity, trading names, approved domains, licence status and official support channels. Aggregate dashboards can report withdrawals, complaints, self-exclusions, security events and sanctions without exposing personal information. Clear definitions and stable time periods matter more than decorative charts because they let researchers compare outcomes.

Accountability also applies to this proposal. A competitive regime may still fail if advertising overwhelms safeguards, if taxes drive users offshore or if complaint systems are inaccessible. The framework therefore needs scheduled review and the possibility of tightening or simplifying individual rules based on evidence. Temporary emergency measures should expire unless lawmakers renew them after publishing an assessment.

Crypto-related provisions deserve the same discipline. Rules should identify the function of an asset—custody, transfer, settlement or investment—and the entity responsible at each step. They should not imply that blockchain makes a product fair, nor treat every self-hosted wallet as proof of wrongdoing. Proportionate controls, auditable decisions and meaningful appeal are more durable than technology-specific slogans.

8. What success should look like

Success should be measured through channelisation, resolved complaints, withdrawal performance, security incidents, effective tax receipts and evidence of reduced harm. Publishing definitions and baselines before reform prevents authorities and industry from selecting only the indicators that flatter the outcome.