Public policy quality should be measured by outcomes, not intentions
The Government has introduced a mechanism restricting the participation of military personnel in gambling activities during the period of martial law.
Formally, the measure is presented as a restriction. However, in substance, the proposed model constitutes a blanket prohibition on participation in gambling activities for all military personnel entered into the relevant registry, regardless of whether there are any signs of problem gambling.
The objective of this decision is understandable — to protect service members and their families from the risks associated with gambling addiction.
The National Gaming Business Council of Ukraine (NGBC) supports the state’s right to respond to socially significant challenges. However, the quality of public policy is determined not only by good intentions. It is determined by the quality of problem diagnosis, the justification of the chosen policy instrument, and the state’s ability to measure the outcomes of its decisions.
For this reason, the key question today is not whether restrictions as such are necessary. The key question is whether it has been demonstrated that this particular instrument is capable of achieving the stated objective.
The issue of problem gambling among military personnel has been repeatedly raised in the public discourse. At the same time, society has not been presented with open data regarding the scale of the problem, the criteria used to assess it, or the rationale for selecting this specific response mechanism.
Without establishing a baseline, it is impossible to assess results. If measurable indicators of the problem have not been defined today, then in one year’s time it will be impossible to objectively answer a simple question: has the policy achieved its intended goal?
Equally important is the question of success criteria.
What specific outcome will the state consider proof of the effectiveness of the new mechanism?
By what percentage should the number of problem gambling cases decrease?
How will the impact of the decision on the behavior of military personnel be assessed?
How will the state measure any potential migration of demand to the illegal gambling market?
When will the first independent evaluation of the policy outcomes be conducted?
Such questions have not been adequately addressed in regulatory policymaking before. One need only recall the situation surrounding the taxation of the gambling industry, where six years after market legalization the state has still not completed the development of a comprehensive taxation framework. This once again demonstrates the importance of a systematic approach to the design and evaluation of regulatory decisions.
NGBC is prepared to initiate a professional discussion on the criteria for evaluating the effectiveness of this decision and to propose its own framework for monitoring outcomes based on open data, independent expertise, and industry analytics.
That is why today it is important to discuss not only the substance of a particular decision but also the overall quality of public governance. Modern public policy should be based on a simple principle:
Problem → Measurement → Decision → Outcome Evaluation
If even one link in this chain is missing, the state risks evaluating its decisions by intentions rather than by consequences.
The protection of military personnel is far too important an issue to be addressed solely through the introduction of a new mechanism without subsequently evaluating its actual effectiveness.
NGBC believes that this approach should become the foundation of a new quality of dialogue between the state and the legal gambling industry.
We are convinced that a strong legal market and effective public policy are not mutually exclusive. On the contrary, both are possible only through systematic dialogue, transparent rules, and a willingness to evaluate every regulatory decision based on its real-world outcomes.