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IAAPA's Statement on New Gaming Regulation in Spain


Fernando Prats Máñez
Director del Área de Ordenación y Control del Juego
Consejería de Economia, Empleo y Hacienda
Plaza de Chamberí, 8, 4. Planta
28010 Madrid

Brussels, 7th March 2019

Dear Mr. Prats Máñez

We are writing to you as President of the European Gaming and Amusement Federation (EUROMAT) and Executive Director EMEA of the International Association of Amusement Parks and Attractions (IAAPA). EUROMAT represents the manufacturers and operators of low stakes gaming and amusement equipment across 13 European countries. IAAPA represents over 6,000 amusement-industry members in more than 100 countries worldwide.

The European industry is deeply concerned about Decree/2019 Amendment to Decree 73/2009 of July 30 approving the regulation of recreational and gaming machines and of the decree 106/2006 of November 30 which approves the regulation of bets in the community of Madrid.

Of particular concern is the removal of machines for children or sports games with prizes, known as redemption games, from Section (d) of Article 3. This brings these machines into scope of highly inappropriate regulation.

Redemption machines are games of skill, from which the player can obtain a reward which is proportional to their score. Rewards can come in the form of non-cash prizes directly or they can come in the form of tickets which can be redeemed for prizes of varying value. They are a long-established amusement game suitable for family leisure environments and are common place across Europe, the Middle East, the United States and Asia.

In the Madrid region alone, there are 32 Family Entertainment Centres containing 2000 machines. The combined annual turnover of these operations is approximately €53 million. These companies employ 600 people creating a further 1500 jobs indirectly. An estimated 80% of these sites would be at risk of closure if the decree goes ahead in its current form[1].

We strongly believe that policymakers should act based on evidence. In this case there is no evidence to suggest that redemption machines pose any risk to players. Where there has been a thorough examination of the risks associated with redemption machines these have failed to identify any risk. For example, the Dutch Kansspelautoriteit published a report in January of last year which reached this conclusion. France, a country which currently limits redemption machines to travelling funfairs, is now discussing legislation to lift this restriction and open the market for Family Entertain Centres in the country.   

However, while the evidence of risk does not exist, we do recognize that there is a need to be sensitive to the family environment in which redemption machines are operated. For this reason, EUROMAT is currently working with the global manufacturing industry for these machines to establish a Code of Conduct, which together we will promote with operators. EUROMAT is also supporting European-wide research into the risk of redemption machines which should conclude later this year. We are not complacent; if there is a genuine risk, then we want to understand it and manage it, but we need the evidence first in order to act.

We are happy to work with you to assess the level of risk and ensure that we can promote best practice in operations in the city, but we urge you to refrain from imposing draconian restrictions in the absence of evidence.

We would be happy to meet with you to discuss this matter. If this is feasible then please suggest a suitable date.

Yours sincerely,

Jason Frost
Jason Frost

Jakob Wahl

Jakob Wahl
Executive Director
IAAPA Europe, Middle East, Africa


[1] Figures from Sega Amusements International