Compliance Updates
Spillemyndigheden: Consultation on Updated Certification Programme for Betting and Online Casino
![Spillemyndigheden: Consultation on Updated Certification Programme for Betting and Online Casino](https://europeangaming.eu/portal/wp-content/uploads/2019/06/Spillemyndigheden-eg.jpg)
The Danish Gambling Authority (DGA) has updated the certification programme for betting and online casino because of the introduction of supplier licences from January 1, 2025.
Interested parties can comment on the update. Comments must be sent to the DGA no later than August 19, 2024. Comments must be submitted by using the contact form.
The updated certification programme for betting and online casino will come into force on January 1, 2025. From July1, 2025, it is mandatory to use the new certification programme, but it is recommended that game suppliers and game operators adopt the updated certification programme as soon as possible.
Later this year the Danish Gambling Authority will issue updated standard reports along with the final version of the certification programme.
CHANGES
The purpose with the update is to make it more clear, which requirements licence holders and game suppliers respectively shall comply with looking forward. Furthermore, it is a part of the preparation for the introduction of the DGA’s games register, which will handle RNG- and game certificates.
Several linguistic adjustments have been made throughout the documents. In addition, the following significant changes and additions should be mentioned:
- In SCP.00 ‘General requirements’ the following new definitions have been added: ‘Licence holder’, ‘game supplier’, ‘base platform’, ‘game platform’ and ‘game certificate’. Furthermore, the definition ‘Testing’ has been renamed to ‘Test’ and rephrased, and the definitions ‘inspection’ and ‘gambling system’ have been rephrased.
- Looking forward licence holders and game suppliers are responsible for their own certification. This means that each actor is responsible for having certifications done and reported to the DGA. The licence holder’s former obligation to compile reports from game suppliers has been removed, because looking forward game suppliers will have their own licence and responsibility. Licence holders must still be aware of suppliers of their base platform.
- A general change has been made to the role as supervisor, who is amongst other responsible for signing the standard reports. Looking forward the requirements for a supervisor is based on requirements for a supervisor in e.g., ISO, PCI, or CREST (see section 2.3 in SCP.00).
- Looking forward the deadline for submitting standard reports is 1 month across all documents. Today the deadline is 2 months in several certification areas. This change is made because the licence holder’s obligation for compilation of reports from supplier licences has been removed, which the DGA considers will make the documentation and reporting of the certification process less complex and time consuming.
- The testing- and inspection standards are omitted, and the following new documents are added:
- 01 ‘Requirements for RNG’ is based on requirements from the previous testing standards, but looking forward the document only contains requirements for RNG. The rest of the requirements from the testing standards are moved to SCP.07.01-03 ‘Requirements for games’, which are 3 new documents, which only contains requirements for games. See further information below.
- 02 ‘Requirements for base platform’ is based on requirements from the previous inspection standards, but looking forward the document only contains requirements for the base platform, which primarily covers handling of the player account. The rest of the requirements from the inspection standards are moved to SCP.07.01-03 ‘Requirements for games’. It is only the licence holder who shall be certified in accordance with the requirements in SCP.02.
- 07 ‘Requirements for games’ are based on requirements from the previous testing- and inspection standards, but only contain requirements for games – online betting (SCP.07.01), land-based betting (SCP.07.02) and online casino (SCP.07.03) respectively. Games suppliers shall be certified in accordance with requirements in these documents. If a licence holder produces games for their own game offer, then the licence holder is also obligated to be certified in accordance with these requirements.
- According to SCP.01 ‘Requirements for RNG’ it is possible to postpone the certification up to 1 month. This option is also added to the new documents SCP.07 ‘Requirements for games’. RNG- and game certificates shall be uploaded to the games register 1 month at the latest after the test- and inspection have been completed. Postponing the certification means, that the certification can be completed 1 month later, but the certificate shall still be uploaded to the games register within the same deadline.
- In SCP.04 ‘Requirements for penetration testing’ CREST accreditation is added as a recognized accreditation for companies, who perform penetration testing (see section 2.2.1).
- In SCP.05 ‘Requirements for vulnerability scanning’ CREST accreditation is added as a recognized accreditation for companies, who perform vulnerability scans (see section 2.2.1). Furthermore, CREST CPSA and CRT certifications are added as recognized personal certifications for personnel, who plans vulnerability scans (see section 2.2.2).
- In SCP.06 ‘Change management system’ section 4.3 about the process for approval of system changes has been changed. Since game suppliers will have their own licence looking forward, and thereby have the responsibility for their certifications themselves, they shall no longer seek approval from the licence holder ahead of making a system change. The game supplier must still be aware of situations, where it can be necessary to involve the licence holder and vice versa.
- In SCP.06 ‘Change management programme’ a new section with a requirement about system changes, which include integration between the base- and game platform, has been added. The requirement means, that the licence holder and game supplier shall establish a business process which ensures, that the base- and game platform functions correctly after integration. The DGA do not think, that this requirement will entail further burdens on the licence holder and game supplier, since it must be expected that measures have already been taken today to ensure, that the gambling system functions correctly. The business process shall be approved by the testing organisation in connection with the annual certification of SCP.06.
The DGA draws attention to, that a consequence of the update is, that the certification programme for betting and online casino no longer has the same structure as the certification programme for lotteries and land-based casino.
Compliance Updates
The Danish Gambling Authority Has Had 79 Illegal Gambling Sites Blocked
![](https://europeangaming.eu/portal/wp-content/uploads/2024/09/3-2.jpg)
On 22 August 2024, the court in Frederiksberg ruled in favour of the Danish Gambling Authority to have 79 websites blocked that offered illegal gambling to Danes.
Among the blocked websites are sites that are particularly aimed at children and young people.
Every year, the Danish Gambling Authority blocks websites that offer gambling products and services to Danes without a licence. The blocks are an important part of the Danish Gambling Authority’s work to protect the players and at the same time ensure a fair and legal gambling market in Denmark.
In 2024, the Danish Gambling Authority has blocked the access to a total of 162 illegal websites that offer gambling to Danes. This is the highest number of blocks in a year so far. Since 2012, a total of 438 websites have been blocked so that they cannot be accessed via a Danish telecommunications provider.
The decision to block websites is made by the courts, and the Danish Gambling Authority has been in court twice this year to have illegal gambling sites blocked. In February, 83 pages were blocked.
The Danish Gambling Authority’s option to block access to the illegal sites is done via a so-called DNS block. This means that the connection between the player and the gambling provider’s website is blocked by the player’s telecommunications provider. If the user tries to access a blocked website, they are greeted by a page stating that the site is illegal and blocked by the Danish Gambling Authority.
“We know that some players will try to bypass the DNS blocks. Therefore, it is very important to us that the information you come across is clear and makes the players aware that they are trying to access a site without a licence. These sites do not have the same level of consumer protection and it can be very risky for a player to use them,” Anders Dorph, Director of the Danish Gambling Authority, said.
Sites without a licence from the Danish Gambling Authority do not necessarily meet the same requirements as sites with a licence, and therefore players do not get the same consumer protection and security on the illegal sites.
It is, for example, impossible to play on a site with a licence if you are under 18 or if you are registered with ROFUS (Register of Voluntarily Excluded Players).
The blocked sites offer different types of gambling such as online casino, online betting and skin betting.
In the latest block, three of the 79 sites contained a new type of skin betting. Here, players can, among other things, use “Robux” as stakes as well as win Robux which is the virtual currency in the computer game Roblox.
“We pay particular attention to this new type of site. Roblox is a game that is very popular among children and young people under the age of 18. Our children should not be introduced to gambling when they play video games, so I am very pleased that we have blocked access to these sites,” said Anders Dorph.
When the Danish Gambling Authority assesses that a website offers gambling illegally without a licence, the Danish Gambling Authority asks the gambling provider to stop the illegal offering. If they do not stop the offer, the telecommunications providers are asked to block their customers’ access to the websites. If this does not happen, the Danish Gambling Authority will proceed with the case and ask the district court to order the Danish telecommunications providers to block the websites.
In the past, only telecommunications providers with membership of the Teleindustrien have been involved in the Danish Gambling Authority’s blocking processes.
In this round of blocking, however, three telecommunications providers who are not members of the Teleindustrien have also blocked access to the illegal sites.
All three telecommunications providers have blocked access to websites with illegal gambling offerings that were part of this blocking process as well as websites covered by previous rulings.
“We are very happy that three more telecommunications providers have closed access. This ensures that even more players are protected from being able to access the illegal sites,” said Anders Dorph.
Compliance Updates
Google Updates Gambling Ad Policy for Germany
![](https://europeangaming.eu/portal/wp-content/uploads/2024/09/5-2.jpg)
Google has announced significant changes to its Gambling and games policy specifically for the German market. The update, set to take effect on September 25, 2024, introduces stricter requirements for gambling operators and brokers seeking to advertise on Google’s platforms in Germany. This policy revision aims to align Google’s advertising practices with German regulations and ensure compliance with local gambling laws.
According to the announcement, which came exactly one month before the implementation date, only gambling operators and brokers licensed by the Gemeinsame Glücksspielbehörde der Länder (GGL) will be eligible to apply for advertising certification for gambling products outlined in Google’s Gambling and games policy. The GGL, which translates to the Joint Gambling Authority of the German Federal States, is the central regulatory body overseeing gambling activities in Germany.
This policy update represents a significant shift in Google’s approach to gambling advertisements in the German market. Previously, a broader range of gambling-related services could potentially advertise on Google’s platforms. However, with the new policy, applications from advertisers of online gambling services who do not meet the GGL licensing criteria will no longer be accepted. This change extends to services offering gambling aggregation, such as websites that link to multiple offers from different operators on their landing pages.
The implications of this policy update are far-reaching for the online gambling industry in Germany. Existing certifications for services that do not meet the new criteria will be revoked on the policy’s effective date, September 25, 2024. This revocation will prevent these services from running gambling ads targeted at the German market through Google’s advertising platforms.
To understand the full impact of this policy change, it’s essential to delve into the technical aspects of Google’s advertising ecosystem. Google Ads, the primary platform for advertisers to reach Google’s vast user base, operates on a complex system of policies and certifications. The Gambling and games policy is a crucial component of this system, designed to ensure that gambling-related advertisements comply with local laws and regulations.
The certification process for gambling advertisers on Google involves several steps. Advertisers must first ensure they meet the eligibility requirements for their specific country or region. With the new policy update, this eligibility in Germany will be directly tied to GGL licensing. Once eligibility is confirmed, advertisers must complete an application process, which includes providing detailed information about their gambling operations and licenses.
Google’s policy update reflects the evolving regulatory landscape of online gambling in Germany. The country has implemented stricter controls on online gambling in recent years, culminating in the establishment of the GGL as a centralised regulatory authority. This move towards centralised regulation aims to create a more consistent and controlled environment for online gambling across all German states.
The policy change also highlights the challenges faced by multinational technology companies in navigating diverse regulatory environments across different countries. Google, as a global platform, must balance its business interests with compliance with local laws and regulations. This often results in country-specific policy updates, as seen in this case for Germany.
For gambling operators and advertisers, the policy update necessitates a reevaluation of their digital marketing strategies in the German market. Those without GGL licensing will need to explore alternative advertising channels or pursue licensing if they wish to continue advertising on Google’s platforms. This could potentially lead to a shift in the competitive landscape of online gambling advertising in Germany.
It’s worth noting that Google’s policy update aligns with broader trends in digital advertising regulation, particularly in sensitive sectors like gambling. Regulatory bodies and technology platforms are increasingly focused on ensuring that online advertisements for gambling services are responsible and comply with local laws.
The timing of this announcement, coming exactly 30 days before the implementation date, provides a window for affected advertisers to adjust their strategies. However, given the complexity of obtaining gambling licenses, this timeline may pose challenges for operators not already in the process of securing GGL licensing.
Google’s policy update also raises questions about the future of gambling advertising on other digital platforms. As major tech companies often follow similar regulatory trends, it’s possible that other advertising platforms may implement comparable policies in the German market or other jurisdictions with strict gambling regulations.
From a technical standpoint, the implementation of this policy will likely involve updates to Google’s ad review systems.
Compliance Updates
Swedish Regulator Gets Increased Powers for Online Gambling Intervention
![](https://europeangaming.eu/portal/wp-content/uploads/2024/09/5-1.jpg)
The Swedish government has confirmed that its gambling regulator, Spelinspektionen, has been granted further control over licensees.
As a result of the intervention, the Spelinspektionen will be enabled to directly step in when it feels necessary with cases of excessive online gambling.
The government in the region said: “This decision represents a tightening of efforts against gambling problems and strengthens consumer protection.”
It enhances the control and governance of the regulator as it can now set the license holders’ action plans aimed at combating excessive gambling.
Starting from 1 October, Spelinspektionen will have the authority to modify the action plans of individual licensees to meet duty of care requirements.
The Gambling Act requires Swedish online gambling operators to have an action plan that outlines their duty of care procedures, protocols and routines.
However, Spelinspektionen informed the government that its oversight revealed significant differences in how licensees’ action plans protect customers from excessive gambling.
In response, Spelinspektionen requested the power to set specific requirements for these action plans. It emphasised that “all license holders should clearly describe in their action plans their guidelines for gambling responsibility and how these are to be implemented.”
Minister of Financial Markets Niklas Wykman, supporting the expanded powers for Spelinspektionen, added: “There must be order in the gaming market. The new requirement should lead to more detailed action plans, making it clear how gambling companies take responsibility for counteracting gambling-related risks.
“This strengthens Spelinspektionen’s ability to prevent people from being affected by the negative aspects of gambling.”
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