What do they say they are doing? a mixed-methods analysis of Swedish gambling operators’ duty of care action plans

Abstract Background Accountability for gambling-related harms remains a contested issue, with debates centering on who should be responsible and how interventions should be structured. While Responsible Gambling (RG) frameworks have traditionally emphasized individual responsibility through voluntary tools, growing concerns have led regulators to introduce more robust, operator-focused duty of care requirements. This study analyzes Action Plans (APs) submitted by 52 licensed Swedish gambling operators to examine how duty of care obligations are interpreted and implemented. Method The study employed a mixed-methods approach to analyze the APs, combining qualitative and quantitative methods. The process involved a conceptual literature review, the development of a purpose-built critique instrument, rubric-based scoring, and thematic content analysis. Each AP was individually coded and scored using a five-point Likert scale (i.e., 0 – 4) across key duty of care themes. This approach enabled a comprehensive evaluation of how operators interpret, articulate, and operationalize duty of care responsibilities within the Swedish gambling regulatory framework. Results The overall alignment scores were generally low, with a median of 1.94 and 50% of documents falling within a moderately spread range of 1.15 to 2.75; only 10% scored above 3.25. While operators performed relatively well in monitoring and risk identification (mean = 2.67), their lower scores in proactive engagement (mean = 1.62) point to a reactive, response-driven focus rather than a preventive strategy. Additionally, a prevailing narrative across the APs frames harmful gambling as affecting only a vulnerable group, thereby subtly justifying minimal and narrowly targeted interventions. Conclusions The findings highlight the influence of RG frameworks, with many operators emphasizing individual responsibility rather than systemic harm reduction. In addition, there is a need for clearer, more robust guidelines, as higher compliance was linked to well-defined requirements. Instrumental templates, such as the critique tool developed in this study, can support designing measurable requirements and evaluating their implementation. Finally, duty of care directives can play a dual role: establishing harm reduction specifications and reshaping the narratives that define gambling. Framing them as both regulatory tools and narrative-making platforms can provide policymakers with a powerful means to reorient the discourse around gambling and enhance harm reduction outcomes.