Responsible gambling teams are expected to spot players who may be heading toward harm before it becomes a crisis. The tool most regulators and standards bodies point to is the same: a defined set of behavioral markers, monitored continuously and reviewed by trained people. This guide explains what markers of harm are, which ones appear across the main frameworks, and how to turn them into a workable monitoring and intervention process.
What are markers of harm?
Markers of harm are observable changes in a player’s behavior or account activity that are associated with risky or problem gambling. They are signals for review, not a diagnosis. The UK Gambling Commission makes the same point in practice: it notes that not every customer experiencing or at risk of harm will trigger every indicator, that one indicator can be strong on its own, and that several weaker indicators can add up to a strong one (UKGC customer interaction guidance, Requirement 5).
Research supports the idea that early betting behavior carries information. A study of first-month betting data from an internet betting site used clustering to find a small high-risk subgroup, 73% of whom later closed their accounts because of gambling-related problems; that group was characterized by frequent and intensive betting, high variability in wager amounts and increasing wager size (Braverman & Shaffer, European Journal of Public Health). The authors also caution that the markers identified only a small proportion of the sample, which is a useful reminder that no marker set is complete.
The frameworks operators work with
EN 18144:2025, the European standard
EN 18144:2025, “Online gambling - Markers of harm in support of identification and prevention of risky and problem gambling behaviour”, is a published CEN standard developed by technical committee CEN/TC 456 (CEN record). The European Gaming and Betting Association, which proposed the initiative to CEN in 2022, describes it as a voluntary baseline that identifies nine core behavioral markers (EGBA):
- Changes in stake volume or frequency
- Speed or intensity of play
- Deposit frequency, size, or failed deposits
- Withdrawals and cancelled withdrawals
- Player-initiated contact
- Session duration or time-of-day play
- Use of multiple products
- Net losses or loss trajectories over time
- Changes to safety tools such as limits and self-exclusion
EGBA also notes that, as a voluntary tool, the standard complements national rules and that some markers may not apply where they conflict with national law (EGBA).
UK Gambling Commission indicators
Remote licensees in Great Britain must use a range of indicators that includes, at minimum, customer spend, patterns of spend, time spent gambling, gambling behavior indicators, customer-led contact, use of gambling management tools and account indicators. The Commission states that this is a minimum and that licensees should add their own (UKGC, Requirement 5; LCCP 3.4.3).
Ontario (AGCO)
Ontario’s regulator expects operators to monitor all players using automated and manual tools, and lists minimum sources including behavior indicators such as chasing losses and erratic betting, spend indicators, time indicators such as late-night play and binge gambling, account indicators such as failed deposits and cancelled withdrawals, customer service contact, gambling management tool use, and player background information (AGCO guidance).
United States
US requirements are set state by state. The National Council on Problem Gambling publishes Internet Responsible Gambling Standards covering policy, staff training, player assistance, self-exclusion, game and site features and payments, and has commissioned comparisons of state regulations against those standards (NCPG). Check the specific rules in each state where you hold a license.
The signals in practice
The frameworks group markers differently, but they overlap heavily. A practical way to organize monitoring is by data source.
Spend and losses
Watch for escalating deposits, deposits at set times such as payday, and net losses that grow over time. The UKGC also suggests comparing a customer’s spend with other customers while taking financial vulnerability into account (UKGC, Requirement 5).
Time and intensity
Longer sessions, binges, more bets in less time and overnight play all appear in regulator guidance. The UKGC notes that a higher percentage of overnight gamblers were found to be problem gamblers than at other times of day, and that a high number of in-play bets can indicate increased risk (UKGC, Requirement 5).
Gambling behavior
Chasing losses, erratic betting, moving to higher-risk products and gambling across multiple products are listed by both the UKGC and AGCO (UKGC; AGCO). The UKGC also flags high staking after a big win.
Account and payment activity
Failed deposits, multiple payment methods, cancelled withdrawals and regularly failing to withdraw winnings are all cited account indicators (UKGC; AGCO).
Customer contact
What players tell support teams matters: complaints about not winning, requests for bonuses after losses, expressions of distress or signs of vulnerability such as bereavement (UKGC). This signal often lives outside the betting platform, in support tooling, so it is easy to miss.
Use of safer gambling tools
Raising or removing limits, repeated time-outs, previous self-exclusion and refusing tools after an interaction are all markers (AGCO).
Turning markers into a process
Monitor every player, continuously
AGCO expects indicators to be monitored continuously or at a rate that reflects how quickly behavior changes, and expects operators to watch new players carefully rather than “delay and observe” (AGCO). The UKGC similarly asks licensees to monitor all customer activity so they can act early (UKGC).
Look across accounts and products
If a player holds more than one account, behavior should be assessed across all of them. In Great Britain, that is a license condition for linked accounts (LCCP 3.9.1).
Set realistic thresholds, and explain the flag
The UKGC asks for realistic thresholds and trigger points designed to identify those experiencing harm (UKGC). Reviewers act faster when a flag says which markers changed and by how much, rather than presenting an unexplained score.
Escalate interventions and record everything
AGCO describes tailored, escalating interventions, from information about play and self-assessment tools through personalized contact to play restrictions and account suspension, and expects operators to assess whether each intervention worked. It also expects records of all customer interactions, including decisions not to intervene (AGCO).
Train the people who talk to players
Both regulators emphasize staff training. AGCO singles out roles with direct influence on player wellbeing, such as VIP hosts and support representatives (AGCO).
How PlyrPulse fits
PlyrPulse flags changes across markers like stakes, deposits, session patterns and use of safer gambling tools from live player data, explains each flag in plain language, and keeps audit-ready records for your compliance team. It is designed to help support alignment with EN 18144:2025, but no software makes an operator compliant on its own; your policies, license conditions and trained staff decide what happens next. Learn more on the responsible gaming software page, or see how player behavior analytics works.
FAQ
Is EN 18144 mandatory?
EN 18144 is a voluntary European standard. EGBA describes it as complementing national regulatory frameworks rather than replacing them (EGBA). Your obligations come from the jurisdictions where you are licensed.
How many markers should we monitor?
At least the minimum your regulator sets, plus others relevant to your products. The UKGC and AGCO both describe their lists as minimums (UKGC; AGCO).
Does a flagged marker mean a player has a gambling problem?
No. A marker is a signal that something has changed and deserves review. Decisions should be based on the full picture and your documented procedures.
Sources
- CEN, EN 18144:2025 project record: https://standards.cencenelec.eu/ords/f?p=205:110:::::FSP_PROJECT:78114&cs=1C030BF793EE8221D40012852456713F9
- EGBA, “European Standard on Markers of Harm Now Published”: https://www.egba.eu/news-post/european-standard-on-markers-of-harm-now-published-egba-members-commit-to-alignment/
- UK Gambling Commission, Customer interaction guidance, Requirement 5: https://www.gamblingcommission.gov.uk/guidance/customer-interaction-guidance-for-remote-gambling-licensees-formal-guidance/requirement-5-customer-interaction-guidance-for-remote-gambling-licensees-sr
- UK Gambling Commission, LCCP 3.4.3: https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/3-4-3-remote-customer-interaction
- UK Gambling Commission, LCCP 3.9.1: https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/3-9-1-identification-of-individual-customers-remote
- AGCO, Guidance for iGaming Operators on Identifying and Supporting Players at Risk of Harm: https://www.agco.ca/en/lottery-and-gaming/guidance-igaming-operators-identifying-and-supporting-players-risk-harm
- NCPG, Internet Responsible Gambling Standards: https://www.ncpgambling.org/responsible-gambling/internet-standards/
- Braverman J, Shaffer HJ, “How do gamblers start gambling: identifying behavioural markers for high-risk internet gambling”, European Journal of Public Health (2012): https://pmc.ncbi.nlm.nih.gov/articles/PMC3324590/