ABSTRACT

This article presents a systematic analysis of the complex relationship between tourism and gambling in Slovenia from 1995 to 2028, illuminating the dynamic evolution of this relationship through four chronologically defined developmental periods. The research analysis reveals paradigmatic changes in the perception and positioning of gambling activities within the Slovenian tourism sector and identifies key factors that influenced the transformation of sectoral connections.

KEY WORDS: gambling, tourism, strategy, integration.

INTRODUCTION

In the first developmental period (1995–2006), gambling in Slovenia was recognized as a strategic competitive advantage and constitutive element of the national tourism strategy. This phase was characterized by optimal positioning of gambling activities as a central product of the tourism offer, which enabled effective attraction of international tourists and generation of significant tourism revenues. The institutional framework during this period supported synergistic development of both sectors, whereby gambling represented the differentia specifica of Slovenian tourism identity.

The second developmental period (2007–2016) was characterized by the identification of systemic barriers that hindered optimal integration of gambling activities into the tourism offer. Among the most significant barriers, legislative limitations that restricted the operational flexibility of gambling operators and insufficient institutional embedding of gambling within the broader tourism ecosystem must be highlighted. During this period, a discrepancy manifested between the potential of gambling activities and their actual realization in tourism practice, resulting in suboptimal utilization of synergistic effects between the sectors.[1]

The third developmental period (2017–2021) was marked by the degradation of gambling to the level of a secondary tourism product, which reflected a change in the strategic priorities of Slovenian tourism policy. This paradigmatic shift was the consequence of a combination of regulatory pressures, social perceptions, and reorientation of tourism strategy toward a more diversified product structure. Consequently, gambling lost its previous status as a strategic element of the tourism offer and became marginalized in the context of national tourism ambitions.

The most recent developmental period (2022–2028) brings a revalorization of gambling’s role as an integral component of the Slovenian tourism offer. This revitalization is the consequence of recognition of the sector’s untapped potential and the need for optimization of the tourism offer from the perspective of added value. The contemporary approach to linking gambling and tourism is based on holistic conceptualization that considers both economic and social dimensions of sectoral integration.

The analysis identifies three fundamental categories of challenges that remain crucial for the future development of sectoral connections. The first set of challenges relates to structural integration of gambling into the tourism sector, which requires the development of innovative product combinations and operational synergies. The second set represents optimization of gambling’s financial contribution to tourism, including maximization of multiplicative effects and ensuring sustainable economic benefits. The third set of challenges encompasses coordination of sectoral activities with social expectations and regulatory requirements, which is crucial for ensuring social acceptability and normative compliance of sectoral development.

 

INITIAL PERIOD – GAMBLING AS A COMPETITIVE ADVANTAGE (1995-2006)

Resolution on Strategic Objectives in Tourism Development (1995)

In 1995, the National Assembly of the Republic of Slovenia adopted the Resolution on Strategic Objectives for Tourism Development, which includes a program of activities and measures for its implementation.[2] The document established that Nova Gorica was the only city with a comprehensive gambling offer. It emphasized that the attractiveness of gambling lies in the diversity of games, entertainment value, and accessibility, while maintaining competitiveness requires upgrading with an even richer and more extensive offer.[3]

Slovenian Tourism Strategy 2001-2006

The implementation of the American gambling model in Slovenian tourism infrastructure contributed to the formation of a competitive tourism product in the European space. Gambling activities, as an anthropologically constituted component of human social and cultural development, represent a stable foundation for sustainable tourism supply. Casino complexes as spaces of simulation and performative entertainment serve as key attractors that stimulate visitors’ imagination and establish new forms of spatial experiences.[4] Casino tourism is recognized in the Slovenian Tourism Strategy 2001-2006 as Slovenia’s absolute competitive advantage.[5]

In the aforementioned Slovenian Tourism Strategy from 2001, the construction of five casino-entertainment centers is envisioned as a strategic objective of Slovenian tourism, while gambling is defined as a fundamental business and entertainment orientation. As emerges from the stated strategy, gambling represented the most developed Slovenian tourism product and was Slovenia’s greatest competitive advantage as well as its greatest business development tourism opportunity.

The Strategy identified key development barriers: it was established that in recent years, the fundamental policy for gambling industry development remained distinctly restrictive rather than developmental (concession limitations and high tax burdens). In the 1990s, Slovenia was the first in Europe to develop and introduce the so-called American type of gambling (casino as entertainment space), but it did not develop appropriate entrepreneurial (ownership) and other regulatory mechanisms that would correspond to this mentioned approach or type of tourism offer.

The Strategy ranked casino tourism among the priority program orientations of Slovenian tourism and envisioned several important business directions for the development of the gambling industry for the period 2002-2006:

• privatization of the gambling industry (domestic entities and foreign strategic partners)
• increase of gambling concessions to 15 larger casino complexes, including five large casino centers
• 40 concessions for larger gambling salons with slot machines
• concessions for online gambling within both existing state lotteries
• special tax reliefs for gambling industry development
• participation of gambling companies in investments in tourism infrastructure at the local level

The Strategy anticipated that casino tourism would become the leading business program of Slovenian tourism in the period 2002-2006 and that the activity would develop as a tourism offer in all major tourism centers with traditional tourism supply.[6]

PERIOD OF RECOGNIZING SIGNIFICANCE WITH LIMITATIONS (2007-2016)

Development Plan and Guidelines for Slovenian Tourism 2007-2011

 In the strategic document Development Plan and Guidelines for Slovenian Tourism 2007-2011, the internal environment analysis identifies that the gambling and entertainment sector represents one of the key segments of the Slovenian tourism industry, however the existing legislative framework limits its development and thereby reduces competitive advantage. The document particularly emphasizes that the development of casino activities must take into account guidelines for granting concessions to gambling salons, which should be limited only to tourist areas, as entertainment and gambling are among the fundamental components of tourist offerings. The analysis shows that Slovenian gambling activity operates primarily as an export-oriented activity, with the strongest connections to the Italian market, which itself is intensively developing its own gambling offerings. Geographic analysis reveals that the most important gambling infrastructure in Slovenia is concentrated in border areas with Italy and Austria, while in other parts of the country this activity is subordinated to other tourism segments. As a key measure for improving the business environment in tourism, the document envisages amendments to the Gambling Act, whose objective is to create a more favorable regulatory environment for promoting the development cycle in gambling, primarily through the elimination of progressive tax restrictions, introduction of concession incentives for development investments, and limitation of the number of granted concessions for gambling salons.[7]

Declaration on Partnership for Sustainable Development of Slovenian Tourism (2011)

 The Declaration on Partnership for Sustainable Development of Slovenian Tourism (2011) draws attention to the insufficient integration of gambling with tourist offerings.[8] This finding is also confirmed by the Strategy ort he Development of Slovenian Tourism 2012–2016, which identifies the inadequate integration of this segment as a key limitation in strengthening the competitiveness of the Slovenian tourism sector.[9]

 Strategy for the Development of Slovenian Tourism 2012-2016

In the Strategy for the Development of Slovenian Tourism 2012−2016, gambling together with entertainment tourism forms a joint product or leisure offering package.[10] The gambling activity segment represents an important component of Slovenian tourism, which enriches and complements the country’s entire tourist offering through the organization of special games of chance. This specific tourism segment is characterized by international competitiveness and development with high added value. Among the main challenges for strengthening the competitiveness of Slovenian tourism, the insufficient integration of gambling activity into the country’s broader tourist offering stands out. Strategic documents emphasize the necessity of encouraging the development of financially stronger concessionaires for conducting special games of chance, who would be capable of establishing socially acceptable gambling complexes and investing in tourism infrastructure in individual destinations. “The specific objectives in the field of tourism-oriented gambling are to encourage the development of tourism and entertainment infrastructure through an incentive system of levies on games of chance, ensure quality and diverse casino offerings, introduce an active concession policy, create integrated gambling areas, define in detail the conditions for individual types of gambling units, and obtain the largest possible share of economic rent for the state that still allows an appropriate level of investment in the gambling-tourism product and adequate profitability for the concessionaire.”[11]

 

SHIFT IN APPROACH – GAMBLING AS A SUPPORTING PRODUCT (2017 – 2021)

 Strategy for Sustainable Growth of Slovenian Tourism 2017-2021

In the Strategy for Sustainable Growth of Slovenian Tourism 2017−2021, entertainment and gambling tourism is listed as a secondary product that supports the core products in Alpine Slovenia, Mediterranean Slovenia, Central Slovenia, and Ljubljana. The only macro-region where this does not apply is Pannonian Slovenia – there it is no longer defined as a key product.

The key/core products from the examined strategy are:

1. mountain holidays and outdoor activities
2. business meetings and events
3. health and wellness
4. nature experiences
5. gastronomy
6. culture
7. sun and sea
8. sports tourism
9. circular tours
10. rural tourism

The strategy does not propose any special measures for gambling. On the contrary, it focuses on the dramatic transformation of state-owned hotels: their restructuring is envisaged, which includes a comprehensive investment plan and management plan. The strategy openly warns about the serious situation in state tourism and gambling companies. In its view, these companies are grappling with inefficient management, long-term neglect of investments, and deteriorating hotel infrastructure, with poor prospects for a quick resolution of problems in the short term.[12]

Furthermore, the strategy warns about the excessive influence of the state in this sector. The analysis reveals “a high share and control of the public sector in hospitality hotels and gambling”:

• 38% ownership share in the 20 largest hotel companies (by revenue),
• 32% in hotel companies that also include gambling,
• 27% in hospitality and gambling combined.[13]

This dominance of state ownership is implicitly linked in the strategy to the described operational difficulties.

 

RE-EVALUATION OF THE ROLE OF GAMBLING (2022 – 2028)

Slovenian Tourism Strategy 2022-2028

The latest Slovenian Tourism Strategy 2022−2028 brings a new assessment of the state of gambling. It is established that the gambling sector had the lowest growth and that it is necessary to “more clearly define the position towards casino activities, which stagnated during the period.”[14] Furthermore, for gambling activity it is directed that “product refreshments and increased management efficiency are needed, with the goal of stopping the decline of key indicators and achieving at least moderate growth again.”[15]

Similarly, due to changed market conditions and directions of Slovenian tourism, it is directed towards re-evaluating the goals and perspective of conducting gambling activities (organizing special games of chance in casinos and gambling salons), which represents an integral part of the Slovenian tourism offering. Their contribution must be clearly directed towards creating products with higher added value and compatible with the established vision of Slovenian tourism. It is emphasized that concession fees (Article 74 of the Gambling Act) play an important role, as they are one of the main designated sources for financing tourism development and promotion – in the state budget and at the local level.[16]

Key Measure: Formation of a Model and Legislative Framework

 The strategy envisages the measure “Formation of a model and legislative framework for the development of gambling activities in Slovenia (special games of chance in casinos and gambling salons) from the perspective of gambling as a tourism-entertainment product.”[17]

Analysis of the current situation reveals that gambling activity in Slovenia has experienced marginalization within the tourism ecosystem during a period of market and social transformations, which is reflected in insufficient recognition of its potential as a constitutive element of national tourism infrastructure. The specificity of gambling activities (casinos and gambling salons) and their potential negative externalities require the implementation of a differentiated regulatory paradigm that enables the integration of the sector into a holistic tourism offering at the destination level, with key consideration of environmental sustainability principles. Identification of the risk of divergent sectoral development indicates the possibility of conflicting interests between the needs of local communities and aspirations to ensure quality gambling infrastructure. Consequently, the imperative arises to direct activities in correlation with contemporary development paradigms, the vision of Slovenian tourism, and current development policies, with the aim of complementary offerings with high added value. Given the sensitivity of the sector and the fiscal importance of concession obligations defined in Article 74 of the Gambling Act, which represent an instrumental source of financing tourism development at both state and local levels, it is directed towards preparing specialized guidelines for the development of gambling as an integral component of tourism offerings.[18]

The envisaged measure encompasses the preparation of an analytical-development document that represents the fundamental basis for guidelines for the development of gambling activities as an integral element of the Slovenian tourism offering. The realization of the measure proceeds in four sequential phases that ensure a comprehensive approach to implementing the set objectives.

The first phase envisages the preparation of an analytical-development document, whose content framework encompasses analysis of the existing situation, definition of development goals, and formulation of guidelines for the development of gambling activities with the purpose of integration into Slovenian tourism infrastructure. The document must be aligned with strategic guidelines defined in the Slovenian tourism strategy for the period 2022–2028. The Ministry of Economy, Tourism and Sport and the Ministry of Finance are responsible for preparing the document, with final approval being the responsibility of the Government of the Republic of Slovenia.

The second phase encompasses the preparation and adoption of legislative changes and amendments to the Gambling Act, where the previously prepared analytical-development document represents the conceptual basis for normative adjustments. The goal of legislative changes is to define the role of gambling activities within the framework of comprehensive Slovenian tourism offerings with emphasis on encouraging positive effects and limiting negative impacts on the quality of tourism offerings at destinations. This activity is connected with the measure “Evaluation and supplementation of conditions, model and investment management plan of state companies in tourism” and includes cooperation of the Ministry of Finance, Ministry of Economy, Tourism and Sport, Government of the Republic of Slovenia, and the National Assembly of the Republic of Slovenia.

The third phase represents implementation of the measure by conducting appropriate policies for directing and supervising gambling activities, where the latter is positioned as a gambling-entertainment product of Slovenian tourism. The Ministry of Economy, Tourism and Sport and the Ministry of Finance are responsible for executing this phase.

The fourth phase encompasses establishing a system of regular monitoring and supervision over the implementation and results of the implemented measure while ensuring inter-ministerial cooperation between the Ministry of Economy, Tourism and Sport and the Ministry of Finance.[19]

Finding

The envisaged measure from the latest Slovenian tourism strategy can be interpreted as indicating that gambling activity in Slovenia has recently experienced marginalization in the tourism ecosystem due to market transformations and social factors, which manifests itself in low institutional salience as a component element of national tourism offerings. Strategies (both gambling and tourism) consistently conceptualize gambling through the prism of »classic/traditional« organization of games of chance in physical casinos and gambling salons, while anachronistically neglecting or sidelining the paradigmatic shift towards digital platforms. The inherent characteristics of traditional gambling and its negative externalities require differentiated regulatory intervention that must also encompass the digital dimension for functional integration into a holistic tourism product portfolio. There exists critical potential for sectoral fragmentation, where divergent development, especially in light of the imbalance between physical (land-based) and online offerings, compromises local collective interests and inhibits the evolution of quality and comprehensive offerings, which necessarily requires synergistic direction in accordance with contemporary paradigms (including so-called online gambling, not to mention e-gambling), tourism vision, and development policy. The sensitivity of the subsystem (if we understand gambling within tourism as such) and the fiscal logic of concession fees that generate substantial designated fiscal flows for tourism development – legitimize the formation of specialized guidelines, but only with critical reflection on the discrepancies between regulatory focus on physical infrastructures and the exponential growth of digital gambling.

BRIEF OVERVIEW OF GAMBLING STRATEGIES

Gambling Development Strategy (1997)

The strategic document from 1997 conceptualized gambling activity as a complementary component of integrated tourism offerings, where its primary function was to stimulate the tourism industry. The strategy was based on an export-oriented model of gambling services with a requirement to maintain domestic ownership of gambling companies.

The document identified four typologies of gambling tourism products: Gambling-entertainment centers were conceived as destinations focused on international clientele with planned multi-day stays. Casinos in tourism centers were defined as a supplementary component of tourism infrastructure, primarily directed towards foreign visitors. Urban casinos were located in larger urban and border areas, while gambling salons represented a limited scope of offerings (30-100 gambling machines), intended for both domestic and foreign clientele and exclusively integrated into tourism facilities or complexes.[20] Online games of chance, where payments are transferred abroad, were not given much attention, only that they should be legally restricted.[21]

Strategy for the Development of Games of Chance in Slovenia (2010)

The strategic document from 2010 was formulated with optimistic development projections. For special games of chance, it defined development guidelines that focused on the quantitative scope of offerings rather than diversification of game types. The strategy introduced five casino categorizations with different tax regimes:

• mega gambling-entertainment center
• gambling-entertainment center
• grand casino
• casino
• gambling salon

Exceptionally, for the “mega gambling-entertainment center” category, liberalization of ownership structure was envisaged by removing the restriction of a minimum 51-percent share of the state, state enterprises, and local communities, but only in cases of public-private partnerships. Empirical analysis shows that practically none of the strategic guidelines were implemented.[22] The strategy for online games of chance envisages continuation of the existing arrangement with organizing on a limited scale, directed towards covering domestic demand.[23]

Finding

 Comparative analysis of strategic documents for the development and implementation of gambling in Slovenia reveals consistent orientation towards international clientele as the primary target group, while simultaneously maintaining domestic ownership of companies organizing games of chance (classic games, special games in casinos/gambling salons, and online games of chance).

The organization of special games of chance and offerings in gambling salons represents a departure from this pattern, as it enables private sector participation and foreign investment. The analysis identifies insufficient ambition in targeting international gambling clientele in the broader European and global context.[24]

Online games of chance are treated peripherally in strategic and regulatory frameworks, despite the fact that they have represented an established segment of the gambling industry for a long time and that intensive digitalization of society is taking place with the integration of advanced technologies. The reasons for such regulatory restraint are not clearly articulated, but are often justified by the need for preventive player protection, especially vulnerable population groups. However, the question remains open whether such restraint actually contributes to encouraging responsible player behavior or perhaps represents an obstacle to developing effective regulatory approaches.

Outside the micro-regional environment (border regions of Italy and Austria, with the exception of individual locations in the area of former Yugoslav republics), Slovenian gambling shows no discernible presence or influence. Such border gambling represents a relatively common pattern of operation on a global scale, involving the phenomenon of gambling industry development in border areas between countries or regions, where one side exploits competitive advantages, often in the form of more flexible and liberal legislative arrangements.

Additionally, it should be noted that in mid-2025, the state faces a situation where a new strategy for the development of games of chance has still not been adopted. This circumstance indicates a possible lack of clear vision and direction from competent institutions regarding the future development of this sector. The absence of a comprehensive strategy may present a challenge for effective management and direction of the gambling industry, as long-term goals and development priorities are not clearly defined.

The stated situation calls into question the state’s ability to ensure consistent and thoughtful regulation and development policy in this field. The lack of strategic direction may consequently affect stakeholder uncertainty in the industry and complicate the adoption of key decisions for the future development of the sector.

Such a situation requires careful consideration by competent authorities to ensure clear and consistent regulatory and development policy in the field of games of chance.

  

SYNTHESIS: EVOLUTION OF TOURISM SECTOR’S RELATIONSHIP TO GAMBLING

Based on a chronological review of strategic documents in the field of Slovenian tourism, we can identify a clear evolution of the tourism sector’s relationship to gambling, which can be divided into four key periods:

1. Period of Recognizing Potential (1995-2006) During this period, gambling was recognized as an exceptionally important part of tourism offerings. The 1995 Resolution identified the need to develop this segment, while the 2001-2006 Strategy placed gambling at the center of Slovenian tourism ambitions. Gambling was defined as the “most developed Slovenian tourism product” and “Slovenia’s greatest competitive advantage.” During this period, ambitions were high – five major gambling-entertainment centers were envisaged, and gambling was to become the “core business program of Slovenian tourism.”
2. Period of Disappointment and Recognition of Barriers (2007-2016) The second period was marked by the recognition that expectations had been too high and that implementation was lagging behind strategies. Although gambling and entertainment products were still recognized as “one of the most important segments of Slovenian tourism” (Development Plan 2007-2011), problems began to be emphasized: legislation limits development activities, gambling is “insufficiently integrated into tourism offerings” (Declaration 2011, Strategy 2012-2016). During this period, a paradox emerged – on one hand, recognition of gambling’s importance, and on the other hand, identification of its insufficient integration into tourism offerings as a barrier to competitiveness.
3. Period of Marginalization (2017-2021) The third period brings a »dramatic« reversal. The Sustainable Growth Strategy 2017-2021 degrades gambling from a key/core product to a secondary/supporting product. This indicates a fundamental change in understanding the role of gambling in Slovenian tourism strategy. Gambling loses its role as a primary tourism development factor and assumes a secondary function as a supporting activity. This period also highlights the problems of ineffective public management of gambling companies.
4. Period of Re-evaluation (2022-2028) The fourth period brings a pragmatic approach to gambling. The 2022-2028 Strategy explicitly acknowledges that the gambling sector had the “lowest growth” and needs “product refreshments.” However, the strategy again emphasizes that gambling represents an “integral part of Slovenian tourism offerings” and that concession fees represent an important source of tourism financing. This period focuses on “re-evaluating the goals and perspectives” of gambling activities.

Key Findings on the Tourism Sector’s Relationship to Gambling:

1. Cyclical relationship: The tourism sector’s relationship to gambling is cyclical – from high expectations through disappointment to marginalization and back to a pragmatic approach.
2. Gap between strategy and implementation: A constant theme throughout all periods is the gap between ambitious strategic plans and actual implementation. Practically none of the major strategic directions have been fully realized.
3. Changing role: Gambling has changed its role over time from an anticipated “absolute competitive advantage” to a “supporting product” and back to an “integral part of tourism offerings.”
4. Persistent integration issues: Throughout all periods, the problem of insufficient integration of gambling into broader tourism offerings appears, indicating structural challenges in connecting these two sectors.
5. Fiscal importance: Regardless of its changing strategic role, gambling is consistently recognized as an important source of tourism financing through concession fees.
6. Border character: Slovenian gambling remains largely limited to border areas with Italy and Austria, indicating limited international competitiveness.

 We can conclude that the tourism sector’s relationship to gambling in Slovenia is complex and evolving. Although gambling is always treated as part of tourism offerings, its perceived importance and strategic role have changed significantly over time. The current approach shows an attempt at pragmatic balancing between recognizing gambling’s potential and the real limitations of its development within Slovenian tourism strategy.

  

BIBLIOGRAPHY

1. Declaration on Partnership for Sustainable Development of Slovenian Tourism. (2011). Ljubljana: Ministry of Economy.
2. Komljenović, A. (2023). Slovenian gambling model in international context: proposal for changes (doctoral dissertation). Kranj: Faculty of State and European Studies.
3. Resolution on Strategic Goals in the Field of Tourism Development in the Republic of Slovenia with a Program of Activities and Measures for its Implementation (ReSCPRT). Official Gazette of RS, No. 7/1995.
4. Strategy for the Development of Slovenian Tourism 2012–2016. (2012). Ljubljana: Government of the Republic of Slovenia.
5. Strategy for the Development of Games of Chance in Slovenia 2010–2020. (2010). Ljubljana: Government of the Republic of Slovenia.
6. Slovenian Tourism Strategy 2001–2006, working abbreviated summary. (2001). Ljubljana: Republic of Slovenia, Ministry of Economy.
7. Slovenian Tourism Strategy 2022–2028. (2022). Ljubljana: Ministry of Economic Development and Technology.
8. Strategy for Sustainable Growth of Slovenian Tourism 2017–2021. (2017). Ljubljana: Government of the Republic of Slovenia.
9. Uran, M., Ovsenik, R. Development Plan and Guidelines for Slovenian Tourism 2007−2011. Portorož: UP Turistica.
10. Vesenjak, P. et al. (1997). Gambling Development Strategy of Slovenia. Ljubljana: Ministry of Economic Activities, Tourism Sector.

 

 

[1] Tourism in its broadest sense is a concept that we understand and associate with activities intended for leisure time. In this context, gambling will always be part of tourism, that is, a way of spending leisure time.

[2] ReSCPRT, 1995.

[3] Ibid.

[4] Strategija slovenskega turizma 2001−2006, 2001, p. 12.

[5] Ibid., p. 9.

[6] Ibid., pp. 16-17.

[7] See Uran, Ovsenik.

[8] Declaration on Partnership for Sustainable Development of Slovenian Tourism, 2011.

[9] Strategy for the Development of Slovenian Tourism 2012−2016, 2012, p. 34.

[10] Ibid., p. 45.

[11] Ibid., p. 53.

[12] Strategy for Sustainable Growth of Slovenian Tourism 2017−2021, 2017.

[13] Ibid. p. 172.

[14] Strategy of Slovenian Tourism 2022-2028, p. 43.

[15] Ibid., p. 49.

[16] Ibid., p. 148.

[17] Ibid., p. 149.

[18] See Ibid., p. 157.

[19] Ibid.

[20] Komljenović, 2023, p. 107-108.

[21] Vesenjak et al., 1997, p. 50.

[22] Komljenović, 2023, str. 107-108.

[23] Strategy for the Development of Games of Chance in Slovenia 2010−2020, 2010, pp. 34−35.

[24] See Komljenović, 2023.

 

Note: This text has been translated from Slovenian language with the help of artificial intelligence Claude.ai