They also complained about proposed gambling advertising restrictions and asked why National Lottery ads do not come under proposed laws. Maltese officials had also questioned the justification for the bill's proposed limits on how much people can bet or win when playing certain games. ' At its core, the bill is a public health measure aimed at protecting our citizens from gambling harm, including younger people and those more vulnerable in our communities,' a Department of Justice spokesman said. The Department of Justice said it entered a consultation process earlier this year after receiving requests from the European Commission and Malta, but this process has since ended without the Government being asked to make changes to the bill. An analysis by KPMG found the sector accounts for more than 12% of Malta’s GDP, and the 300-plus gaming companies on the island employ 10,000 people. The Mediterranean island is a hub for betting companies and has seen strong growth in the digital gambling sector. 'The absence of a product in the regulated market may be counter-productive - in that, in the absence of a safe, legal and regulated offer, players might opt for the unsafe, illegal and unregulated offer.' 'Prohibition is not a proportionate and effective manner to regulate online gambling,' Maltese officials claimed, as reported by the Irish Independent. The submission said restricting certain games threatened freedoms under EU law to provide services, and could also limit operators based in other member states intending to establish games in the country. Malta officials say part of the bill would enable the Irish gambling regulator to determine which games operators may provide, but claim there is a 'lack of clarity' on what these 'relevant games' entail. Malta’s government also claimed proposals to allow Ireland's new gambling regulator to restrict times when people can bet may be disproportionate 'without further empirical evidence, research and justification,' reports the Irish Independent. EU member states can use the TRIS to make submissions on proposed laws and changes in other countries to prevent trade barriers from occurring. The officials used a European Commission technical regulation information system (TRIS) to voice their concerns. The government in Valletta said proposed Irish legislation could prevent certain games from being played in the country, which could push people towards unregulated modes of gambling. Officials in Malta have expressed concerns that Ireland's new gambling law could inadvertently lead to an increase in black market betting.

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