Study on the sharing of information and reporting of suspicious sports betting activity in the EU-28 : executive summary.
Date: 2016-09-23
Institutions: Directorate-General for Education, Youth, Sport and Culture
Subjects: fight against crime, gaming, gaming establishment, professional sport, regulation, report, self-regulation, sport, sports body

Study on the sharing of information and reporting 

of suspicious sports betting activity in the EU 28 

A study for DIRECTORATE‐GENERAL EDUCATION AND CULTURE,  
Directorate Youth and Sport, Unit Sport 

EXECUTIVE SUMMARY 

 
 
 
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doi: 10.2766/79934 

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Study on the sharing of information and reporting of suspicious sports betting activity in the EU 28 

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Disclaimer 

The report is produced by Oxford Research of Denmark and law Professor Marjan Olfers of VU University Amsterdam with 
input from Professor in Criminology Toine Spapens of Tilburg University and Professor in Internet Governance and Regulation 
Arno Lodder of VU University Amsterdam. 

The information and views set out in this study are those of the author(s) and do not necessarily reflect the official opinion of the 
Commission. The Commission does not guarantee the accuracy of the data included in this study. Neither the Commission nor 
any person acting on the Commission’s behalf may be held responsible for the use which may be made of the information contained 
therein. 

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Study on the sharing of information and reporting of suspicious sports betting activity in the EU 28 

Executive Summary 

In recent years - at least in perception - the nature and scope of match fixing seems to have become more 
severe  and  has  come  under  closer  scrutiny.  Media  attention  is  rising,  and  the  concern  within  betting 
regulators,  sports  federations  and  international  organisations,  such  as  the  IOC,  FIFA  and  UEFA,  is 
increasing. 

European institutions have reacted to the perceived broadening scope and accelerated pace of match fixing 
and  the  Commission  has  recently  been  paying  increasing  attention  to  the  issue.  In  January  2011,  the 
Commission adopted the Communication entitled "Developing the European Dimension in Sport" and only 
two months later, the Commission  published a green  paper public  consultation on on-line gambling in the 
Internal Market, where the issue of match fixing was addressed. In October 2012, the Commission adopted 
its  Communication  'Towards  a  comprehensive  European  framework  for  online  gambling”,  where  the 
Commission  announced  it  intends  to  adopt  Recommendation  on  best  practices  in  the  prevention  and 
combating of betting-related match-fixing. This study gathers evidence and contributes to the preparation of 
this Recommendation. 

The  Council  of  Europe  is  also  active  in  the  field  and  has  been  given  a  mandate  to  negotiate  a  binding 
convention  against  match  fixing.  This  of  great  significance,  and  a  fundamental  step,  as  a  new  international 
Convention will be valid as law in the signatory countries. The European Commission was given a mandate 
by Member States to participate in the negotiations. A significant added value of a Convention against match 
fixing is expected to be the creation of a platform for cross-border and cross-sector cooperation, involving all 
the relevant actors. The Convention is expected to be formally adopted and declared open for signatures in 
2014. 

The overall objectives of the study can be summarised as: 

1.  To identify existing national regulations, self-regulatory arrangements and practices governing 
the  detection,  collection,  processing,  sharing  of  information  and  reporting  of  suspicious 
sports  betting  activity,  involving  sports  organisations,  betting  operators,  gambling  regulators, 
providers  of  betting  monitoring  mechanisms  and  other  relevant  national  authorities  in  the  28  EU 
Member States; 

2.  To  describe  the  role  and  tasks  of  national  authorities  (including  gambling  regulators,  police, 
public prosecutors, judicial bodies, etc.), sports organisations, and betting operators in relation to 
suspicious sports betting activity, including the collection and storing of relevant data. 

3.  To  identify  arrangements  at  EU  and  international  level  (bilateral  or  multilateral  arrangements) 

that ensure exchange of knowledge and intelligence about suspicious sports betting activity. 

4.  To draw conclusions with regard to the possibility for the EU to act to improve the situation on 

the basis of identified problems. 

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ANALYTICAL APPROACH AND METHODOLOGY 
The  analytical  design  was  structured  to  accurately  and  comprehensively  address  information  sharing  in  the 
EU 28, focusing on national and international dimensions. The study covers many highly different types of 
actors  such  as  gambling  regulators,  general  sport  organisations,  specific  sports  organisations,  public  and 
private betting operators, betting surveillance companies, etc. 

The  research  draws  on  a  range  of  policy-oriented  and  academic  literature.  Match  fixing  has  received 
attention  from  the  popular  media,  the  scholarly  community,  and  from  policymakers.  There  is  therefore 
information  available  on  the  subject,  though  there  is  little  structure  to  the  types  of  information  that  are 
available.  Much  of  the  information  is  generated  episodically  and  dependent  on  specific  events,  specific 
organisations,  or  high  profile  incidents  related  to  match  fixing.  This  is  beginning  to  change,  with  a  more 
systematic approach taken to understanding match fixing at a theoretical and policy level. At the same time, 
very little has been written on the specific topic of sharing of information related to match fixing. 

The study also included interviews with key stakeholders. Two types of interviews were carried out. The first, 
exploratory  interviews  with  stakeholders  at  the  European,  and  international  level,  were  undertaken  to 
understand broad issues related to match fixing and the various approaches taken. These were followed by 
confirmatory  interviews  to  provide  a  detailed  assessment  of  the  information,  to  address  any  conflicting 
types of information, or to go into detail.  

Out of the 28 countries the study covers, we have selected 8 for more  in depth  case studies to illustrate 
challenges,  solutions,  and  key  findings  through  concrete  examples,  which  are  easy  to  understand  and 
communicate.  The  case  studies  are  based  on  desk  research,  surveys  to  gambling  regulators  and  betting 
operators  and  interviews  with  representatives  from  gambling  regulators,  betting  operators  and  sport 
federations/associations. In the remaining 20 countries, the team has executed desk research and surveys to 
gambling regulators and betting operators which is utilised to answer the most relevant study questions and 
give  an  overview  of  how  the  regulatory  and  self-regulatory  frameworks  function,  the  scope  of  information 
shared, and the role of key actors.  

REGULATORY AND SELF‐REGULATORY FRAMEWORKS 
The  study  focused  on  regulation  of  information  collection,  storage,  and  sharing,  examining  both  formal 
regulations  imposed  through  the  official  regulatory  system  in  each  country  along  with  industry-led  self-
regulatory  approaches.  Overall,  a  minority  of  the  EU-28  Member  States  have  a  direct  obligation  for  the 
national  Gambling  Authority  to  proactively  collect  and  process  information  on  suspicious  sports  betting 
activity in a national or regional gambling Act, licence conditions, or similar legislation for betting operators, 
or  sport  governing  bodies.1  However,  more  countries  have  started  doing  so  -  roughly  10  out  of  the  28 
member states - and some countries have indirect obligations, typically stating that licensed betting operators 
must  act  to  protect  betting  integrity  or  prevent  match  fixing.  There  is  a  broad  range  of  approaches  taken 
across Europe and the various models are highlighted in the report.  

It  is  more  frequent  that  the  betting  operators  have  to  report  suspicious  betting  activity  to  the  Gambling 
Authority. This is the case in about half of the EU member states. In general an obligation for the Gambling 
Regulator to collect information or for the Gambling operators to report suspicious betting activity is more 
likely to be found in the countries that have revised their legislation recently.  

1 We distinguish between unusual and suspicious betting patterns. An injury to a key player can create sudden unusual 
activity in the market. But the activity is not suspicious because an unexpected event caused the unusual betting pattern.  
However,  if  no  logical  explanation  of  betting  activity  can  be  found  and  it  polarises  around  a  single  outcome  pushing 
prices out of line with what would is expected the betting pattern is not only unusual but also suspicious.   

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Study on the sharing of information and reporting of suspicious sports betting activity in the EU 28 

Even in the absence of formal regulatory or legal obligations to do so, the sports betting industry collects and 
processes  a  wealth  of  data.  The  collection  and  processing  of  information  is  an  integral  part  of  betting 
operators’ business, and the industry has developed detailed systems to monitor markets, odds movements, 
bets, and customers. The betting operators use surveillance systems to monitor betting volumes in markets, 
their  exposure  to  certain  outcomes,  price  movements,  betting  patterns  of  customers  collectively,  as  well  as 
individual  betting  accounts,  winning  and  losing  of  customers,  opening  of  new  accounts,  etc.  They  use  this 
information  to  set  odds,  adjust  odds,  regulate  betting  limits,  suspend  bets,  limit  risks,  direct  marketing 
towards  specific  customers  at  specific  times,  and  other  aspects  of  risk  management  and  customer  service. 
However,  this  information  is  not  standardised  across  the  industry,  and  there  are  limitations  to  sharing 
information on individual accounts.  

Ultimately, initiatives aimed at promoting the collection and processing of information will begin within the 
context of an industry that already actively collects information. Self-regulation and industry cooperation are 
often in place because it minimises risk for operators or because it promotes the professional autonomy of 
operators. Self-regulatory frameworks can take several forms including Memorandums of Understanding 
(MoUs)  (typically  between  gambling  regulators  and  sports  associations/federations),  mutual  interest  in 
cooperation between betting operators to inform each other of suspicious betting activity, and commercial 
contracts between a betting monitoring company and one or more buyers of their surveillance services. 

The study examined if and to what extent differences exist across sports. While major scandals have involved 
football  and  tennis,  the  main  sports  included  in  the  study,  there  have  been  examples  in  other  sports  with 
smaller  audiences,  less  media  attention,  and  a  tighter  network  of  athletes.  Some  types  of  match  fixing  are 
particular and inherent to certain sports, such as individual competitions. However, there did not appear to be 
formal  differences  across  sports.  One  tendency  is  for  a  rise  in  the  number  of  MoU  with  football  leagues, 
especially  the  most  popular  leagues.  However,  this  appears  to  be  driven  by  mutual  interest  combined  with 
local factors such as individual officials, the presence of a scandal, and traditions of collaboration. Systematic 
differences did not appear to exist.  

SCOPE OF INFORMATION AND ROLE AND TASKS OF KEY ACTORS 
Determining the existence of suspicious betting patterns requires the triangulation of evidence, with a mix of 
top-down statistical approaches to monitoring the betting markets, supplemented by investigative processes, 
expert  level  knowledge  of  a  particular  sport  or  market,  and  in  many  cases,  common  sense  on  behalf  of 
experienced operators, sport associations, regulators or law enforcement agencies. It is inherently infeasible 
for a single agency or type of organisation to be in a position to carry out this triangulation on its own. While 
sports  data  firms  have  built  up  the  capacity  to  monitor  betting  patterns,  other  sources  of  information  are 
required  to  confirm  suspicious  activity,  with  inputs  from  sport  associations,  the  legal  system,  and  national 
regulators.   

The existence of suspicious betting patterns is difficult to delimit. Unlikely patterns in betting activity or the 
field of play are generally considered ‘unusual’ until there is a reason to consider them ‘suspicious.’ Sport is 
interesting precisely because unusual outcomes occur, and betting is predicated on the same idea. Activities 
on the pitch can appear unusual. It is a fine line between ‘unusual’ and ‘suspicious’ patterns in sports betting, 
reinforced by a number of confounding factors. For example, players or teams can affect the outcome of a 
match  through  deliberate  underperformance  for  ‘sport-related’  match  fixing,  such  as  to  avoid  a  specific 
opponent  in  a  tournament,  to  save  particular  athletes  for  later  matches,  or  to  keep  particular  tactics  as 
surprises  for  later  competitions.  However,  when  linked  to  betting,  there  is  an  additional  element  (betting-
related match fixing) that is generally associated with unusual betting patterns.  

Unexplained outcomes and unusual betting patterns are generally the two necessary conditions that are linked 
to ‘suspicious’ patterns. Suspicious activity is viewed on a case-by-case basis and it is often important to take 

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into account local factors based on the sport or county involved, but in general terms, the same processes and 
procedures can be applied to all sports and countries. There are no set criteria that set out whether a bet is 
suspicious or not and to a large extent a common sense and fact-based approach is needed to try to explain 
the observed patterns.  

Betting operators, sport governing bodies, and public authorities have access to different types of information 
about  suspicious  betting  activity  and  play  different  roles  in  detecting  suspicious  betting  patterns  and 
protecting betting integrity. On the industry side, the betting operators have access to customers, their betting 
accounts  as  well  as  betting  patterns,  and  can  use  this  to  monitor  individual  bets,  total  bets,  amounts, 
frequency,  historical  patterns,  and  volumes.  They  also  monitor  odds  movements  across  the  market  and  at 
individual  competitors.  They  can  compare  this  information  with  vast  statistical  information  about  events, 
teams,  athletes,  and  other  variables  to  monitor  if  odds  and  odds  movements  are  as  expected.  Odds 
monitoring companies play a somewhat complimentary role to the betting operators. They also monitor the 
market  and  developments,  but  instead  of  relying  on  access  to  individual  bets  and  the  betting  history  of 
punters,  they  detect  unusual  betting  patterns  by  looking  at  odds  movements  across  betting  operators  and 
compare the movements to what statistics predict the odds would be. 

Sport governing bodies and sports clubs have limited access to bets or betting patterns, but they have access 
to  athletes,  officials,  events,  matches,  and  other  participants  on  a  daily  basis.  Through  these  channels  the 
sport governing bodies and clubs can come across information about breaching of betting rules by individual 
athletes  or  match  fixing  organised  by  betting  syndicates.  Sport  governing  bodies  can  also  prosecute  and 
sanction athletes and officials who breach the rules. Internal investigations by sport governing bodies are in 
general less resourceful than police investigations and are an important tool to sanction athletes and officials 
in cases of minor offences. 

The role and importance of the betting regulator varies from country to country. In some countries they have 
a  rather  passive  role  mainly  being  responsible  for  establishing  and  maintaining  the  regulatory  betting 
framework and overseeing that it is respected, while in others they have a very active role. As set out above 
the active role will typically either include an obligation for the national Gambling Authority to proactively 
collect  and  process  information  on  suspicious  sports  betting  activity  or  a  requirement  for  the  betting 
operators to report suspicious betting activity to the Gambling Authority. 

To  establish  an  efficient  framework  for  protecting  betting  integrity,  it  is  important  that  the  key  parts  all 
contribute in gathering and sharing of information and collaborate. Public prosecutors and Courts of Justice 
can  initiate  criminal  investigations  and  prosecutions  in  larger  cases  of  match  fixing  involving  more  serious 
breaches  of  rules.  They  may  address  either  the  gambling  regulator  or  the  betting  operators  and  sports 
organisations directly, to request information they need over the course of an investigation. Sport associations 
and  federations  can  also  initiate  investigations  and  can  sanction  within  the  sports  system.  As  mentioned 
minor  offences  will  often  be  handled  by  the  sport  itself  and  is  less  resourceful  than  a  formal  police 
investigation. However, the sport federations/associations can often not receive sensitive information from 
the  police  and  public  prosecutors.  They  may  not  be  able  to  receive  sensitive  information  from  betting 
operators either due to legal restrictions on what personal information the betting operators can share. This is 
explained further below. 

EXCHANGE OF INFORMATION AT INTERNATIONAL LEVEL 
The barriers to the sharing of information are dependent on the type of information to be shared. Specific 
barriers are highlighted throughout the report, and generally fall into two types: legal barriers and practical 
barriers.  

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Study on the sharing of information and reporting of suspicious sports betting activity in the EU 28 

Legal barriers vary by Member State due to different interpretations of the European Union Data Protection 
Directive. Information on odds movements can in most cases be shared since it does not contain personal 
information. If personal data is affected (e.g. customer data), such data can only be shared if the necessary 
legal  requirements  and  formal  processes  are  observed.  Account-level  information  is  less  easily  shared,  and 
generally  only  done  so  for  the  purposes  of  a  specific  investigation.  Detailed  customer  information  (names, 
addresses, credit card numbers, IP address, etc.) can be shared with public authorities and law enforcement 
agencies in case of an investigation into suspicious betting activity or match fixing, but there are specific data 
protection practices and, in some cases, regulations that prevent account level information from being shared. 
At the international level, European approaches are being developed to support cross-border collaboration. 
This  is  especially  relevant  for  the  mechanisms  that  Europol  and  Interpol  have  developed  to  support  joint 
investigations.  

Cultural and political barriers exist too, such as a general reluctance to share information and cooperate with 
organisations  that  do  not  share  the  same  mandate.  Sport  associations  and  law  enforcement  agencies  have 
different sets of incentives. These are explored more fully throughout the report.  

Further compounding these barriers are practical barriers to information sharing. As mentioned, MoUs are 
often used by various partners to regulate the sharing of information. However, since many betting operators 
provide betting options on many sports and in many countries, they will generally not have MoUs with sport 
governing  bodies  for  all  the  sports  and  countries  they  cover.  If  they  come  across  suspicious  sport  betting 
activity  in  a  country  and  sport  where  they  do  not  have  a  MoU,  this  can  present  a  barrier  to  sharing  of 
information. Betting operators can still decide to share information even without an MoU but might decide 
not  to  do  so.  They  are  especially  likely  not  to  share  information  if  the  receiving  sport  governing  body  is 
deemed not to have good information-handling procedures and cannot document that they are able to handle 
sensitive personal information. 

At an even more practical level, public authorities and/or sport governing bodies must know who to contact 
and  who  to  share  the  information  with,  which  in  itself  can  be  quite  a  task.  While  the  national  platforms 
suggested by the Council of Europe in the draft convention of match fixing will, if implemented successfully, 
help solve this problem, interpersonal barriers could remain.  

RECOMMENDATIONS: NECESSARY AND APPROPRIATE EU ACTION 
The report contains major recommendations linked to both the practical and legal barriers to the sharing of 
information  across  borders.  The  EU  could  play  an  important  role  in  minimising  both  barriers.  First,  the 
creation of a linked network of National Platforms, as suggested by the Council of Europe in the draft 
convention  on  match-fixing,  could  solve  some  of  the  practical  problems  related  to  sharing  of  information 
across  borders.  The  National  Platform  will  provide  a  single  point  of  entry  to  relevant  authorities  in  each 
country.  Thus,  a  national  platform  in  one  country  can  collect  information  from  relevant  sources  and  share 
them with a  national  platform in another country.  The national  platform in the receiving country  can then 
share  information  with  the  relevant  actors  in  their  country.  This  will  limit  the  number  of  actors  involved 
substantially,  create  a  directory  of  contact  persons  covering  all  the  countries  which  have  ratified  the 
convention  and  streamline  coordination  and  sharing  of  information  across  countries.  Match-fixing  is 
however,  (also)  a  cross  border  activity  and  international  cooperation  is  necessary.  International  structures 
would require sufficient competence and remit that allows for a broad scope of activities. At the same time, it 
has  been  pointed  out  that  the  establishment  of  a  framework  alone  does  not  solve  the  problems.  How  the 
platforms are implemented and how many resources they are given are essential factors which will influence 
how effective the national platforms will be. In relation to this, the EU could work to support Member States 
that sign up to the convention. Due to the financial constraints many countries are under these years it is not 
a  given  that  the  necessary  resources  will  be  devoted  to  the  platforms.  The  EU  could  facilitate  sharing  of 
information and lessons learned regarding the appropriate mandate, funding, staffing, participation, function, 

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etc.  of  the  national  platforms.  The  EU  could  also  play  a  role  in  encouraging  and  streamlining  cooperation 
with countries that might not sign up to the Convention and/or create a national platform.   

The European Union Data Protection Directive 95/46/EC of 1995 is designed to protect the fundamental 
rights and freedoms of natural persons, and in particular their right to privacy with respect to the processing 
of personal data. However, there are differences between Member States when it comes to implementation 
and interpretation of the directive. Personal information generally includes personal contact information such 
as  addresses,  telephone  numbers,  e-mail  addresses,  etc.  Currently,  sensitive  personal  information  can  be 
shared if it is in accordance with the data protection regulation, i.e. if it is deemed to have substantial public 
interest. For selected areas of special public interest personal information can be shared more freely but sport 
and betting integrity is currently not defined as such an area. 

Many parties are risk averse when it comes to information sharing because it is unclear what can be shared 
under which circumstances. There is little precedent from previous legal cases to guide actors in similar cases 
and it is different from country to country how the rules are interpreted and what information can be shared.  

On  25  January  2012,  the  European  Commission  proposed  a  reform  of  the  data  protection  rules  to 
“strengthen  online  data  protection  rights  and  boost  Europe’s  digital  economy”.2  With  this  proposal,  the 
European Union modernises the rules and brings them in line with the digital age. One of the innovations 
will  be  a  pan-European  law  for  data  protection,  replacing  the  current  national  laws.  This  will  probably 
improve the cross border sharing of information. 

Also,  on  27  March  2013,  the  European  Commission  proposed  to  make  the  EU  law  enforcement  agency 
(Europol) “more effective at collecting information, analysing it and sharing these analyses with the Member 
States”.3  The  Commission  strives  for  more  (concrete)  support  to  national  law  enforcement  authorities  in 
cross-border  cooperation  and  investigations.    Since  match  fixing  is  (foremost)  a  cross  border  activity,  this 
initiative might improve (operational) cooperation between Europol and the national authorities. 

Thus, conditions under which personal information can be for shared are likely to be relaxed in the future but 
the exact interpretation of the rules in relation to match fixing will most likely be unclear. At least initially. It 
would  be  useful  if  the  European  Union  could  provide  specific  guidance  and  training  in  terms  of 
information  sharing  –  what  can  be  shared  under  which  circumstances  -  to  actors  that  could  come  in 
possession of information on match fixing. It is complicated to provide guidelines since judgement must be 
applied in each case and no cases are identical but given the current state characterised by so little precedent it 
would  be  possible  to  bring  more  clarity  to  the  boundaries  for  sharing  of  information.  Scenario  workshops 
where  relevant  actors  discuss  fictional  but  realistic  cases  is  an  example  of  a  tool  that  could  be  applied  to 
enlighten  discussions  on  when  and  what  information  can  be  shared.  Scenario  workshops  could  both  be 
conducted at the international level and at national level.   

Finally,  it  is  recommended  that  future  EU  initiatives  are  coordinated  with  the  work  by  the  Council  of 
Europe. It is also important that the EU considers if future initiatives should open for Third Countries, given 
the  international  nature  of  sports  betting.  Betting  integrity  goes  beyond  the  EU  and  it  is  important  that 
countries  inside  and  outside  the  European  Union  work  together,  coordinate  their  efforts  and  share 
information through an enabling mechanism that supports the flow of information.  

2 http://ec.europa.eu/justice/data-protection/document/review2012/com_2012_11_en.pdf 
3 http://europa.eu/rapid/press-release_IP-13-284_en.htm 

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doi: 10.2766/79934 

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