19 PUBLIC GAMING INTERNATIONAL • JANUARY/FEBRUARY 2026 player. By contrast, casino games typically allow players to have an impact on the result. Lottery games also operate based on a prize table, which is not the case for casino games. Generally, dynamics further underline the difference. Casino games are characterised by fast gameplay. This is not the case for lottery games. Even though e-instants are the fastest variant of lottery games, the gameplay is slower simply because an e-instant lottery game is purchased and not ‘played’ like a casino game. Casino games are played in series, but this is not the case for lottery games, which are purchased individually. This distinction is also reflected in player behaviour. There is no player who connects with an online casino website just to play one casino game. But players do connect with an online lottery website for that reason. These universal characteristics mean that the gaming experience of e-instants is fundamentally different from that of online casino games. In a lot of countries regulation depends on the level of risk associated with games of chance. Lotteries are in general considered to represent a lower risk than casino games. Casino operators point out that e-instants represent a risk level that is similar to casino games. Do you consider that e-instants have a similar risk level to casino games? P. Van Baeveghem: Not at all. E-instants present a lower risk level than online casino games - which has much to do with the way different games stimulate player behaviour, such as dopamine production Online casino games are typically characterised by high frequency, rapid repetition, and continuous play. They often create an illusion of player control, incorporate near wins, and rely heavily on extra sensory experiences. All these elements stimulate dopamine. If e-instants add a game element or create the illusion of a game by perhaps giving the player a few choices without any impact, this is rather to cope with a growing societal trend of gamification. The comparison made by some online casino operators is often intended to create confusion in the minds of regulators so that they, online casinos, would be subject to less stringent rules than lotteries are subject to. However, it is not only the characteristics of the game that must be taken into account, but also the game operator. The identity and behaviour of the operator matter. Lottery operators – our own association members – operate with transparent commitments to responsible gaming standards that include ongoing monitoring in this regard. This provides an additional guarantee that the risk factors associated with the game have been taken into account, putting player protection as the highest priority. Another important factor in terms of risk is whether one has exclusive rights or is active in a market with multiple competitors offering similar games that are in direct competition with each other. D. Gale: No, we do not view e-instants as having an inherently similar risk level to casino games. Risk is not defined by visual presentation or speed alone, but by game mechanics, frequency, wagering structure, and safeguards. E-instants are designed within controlled parameters that include limits on prize structures, clear disclosure of odds, mandatory responsible gaming tools, and strong age and identity verification. These elements align e-instants more closely with traditional lottery products. Casino games, by contrast, often involve continuous play, higher event frequency, variable player interaction, and dynamic wagering options. These structural differences are not just cosmetic – they fundamentally shape player experience, risk profile, and regulatory treatment. That said, we strongly believe that player health must remain central to product evolution. As digital lottery products grow in popularity, lotteries and regulators must continually assess play data, monitor behavioral indicators, and adjust safeguards where appropriate. This is why NASPL supports evidence-based risk assessment and ongoing collaboration with regulators, researchers, and responsible gaming experts. How can suppliers of e-instant games help lotteries to create more transparency about the nature of e-instants towards their regulators and their players? For example, should suppliers certify how e-instants are functioning and that they have universal characteristics of lottery games? D. Gale: Suppliers can play a critical role in supporting transparency and trust. First and foremost, suppliers should ensure clear explanation of game mechanics, including how outcomes are determined, how odds and prize structures are set, and how responsible gaming features are integrated. Independent testing and certification can and should be leveraged to clearly demonstrate that e-instants function as lottery games of chance, not casino-style wagering. Alignment with recognized frameworks such as the WLA Responsible Gaming Certification provides regulators and players with confidence that products meet internationally accepted standards. Equally important is collaboration. Transparency is most effective when suppliers, lotteries, and regulators work together to ensure that player-facing communications are clear, accurate, and accessible. P. Van Baeveghem: I believe that suppliers play an essential role in explaining game mechanics to regulators, but also in providing clarity about the nature of the player experience. Suppliers offering both online casino games and e-instants have access to extensive data and are familiar with the technical and behavioural differences between these different types of games. Providing clarity is a sector-wide responsibility. . Consider that e-instant games sometimes use certain images or symbols that are also used for casino games: does this mean, in your opinion, that players could have a similar gaming experience to casino games, or is the gaming experience not comparable, for example, due to the course of the game, the degree of interaction that can influence the result, the higher payout, or other differentiating factors? P. Van Baeveghem: The idea that the use of certain symbols or images would result in an identical gaming experience seems greatly exaggerated to me. The reality is that game symbols are used as a kind of “market demarcation”. In a context where there are several operators - some of which have a monopoly - the legislator or regulator has to draw a line somewhere. Whether market demarcation based on such symbols is relevant is another question. A scratch card with a blackjack game theme, for example, does not create an experience identical to the casino game. The player experience is in fact quite different. We have evolved to the extent that we no longer need to measure a gaming experience in terms of symbols, but instead we can Continued on page 44
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