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Poker Sites UK - systems, regulation and audits


I (REDACTED) want to understand more about the algorithm systems that the poker sites in the UK use.
I am aware that the UK gambling commission has approved the use of these sites in the UK and my question doesn’t relate to the specifics of the algorithms for the card shuffler etc, but it relates to the regulation of these entities.
I understand that the gambling commission does not audit these sites specifically and a third party regulator audits the sites to ensure that they act fairly. My question relates to these audits specifically.
We know after the downfall of UltimateBet that poker sites are prone to manipulating algorithms in various ways so that the house benefits.
This has included being able to see all players hole cards in what the coders called “god mode”, using bots, ensuring there are no winning players over time to keep as many players in the game as possible in what coders called “equitable distribution”, something which is very difficult to spot for an auditor if they don’t know what they’re looking for but is clear to see for playing professionals on the site.
We also know that this site was audited regularly and by separate third party auditors who clearly missed what was substantial deliberate fraud in the algorithm.
Algorithms for shuffles and poker sites in general are incredibly complex and at the time it was no wonder that some things were missed. The most important lesson from the UltimateBet saga is that we ensure that auditing of these companies and specifically these algorithms are done by professionals who fully understand the code.
My question is what specifically do the auditors of these sites look for when they are auditing?
There is a minimum that we should know as a player on these sites, and while we don’t need to know specifics about the algorithms, at the minimum we need to understand what specifically the auditors are looking at from a high level or at least what the gambling commission are looking at from a high level.
There are a substantial amount of professional poker players who have lost trust in the online sites and stick to playing live poker, most of whom don’t believe that the online sites are random at all. There are active poker sites in the UK that have recently been fined by the European Commission for breaking various rules, we know that these companies are not afraid to bend the rules if they can get away with a small fine.


Thank you for your request which has been processed under the Freedom of Information Act 2000 (FOIA).

In your email you have made reference to the algorithm systems that the poker sites in the UK use. You have specifically requested information relating to the third party regulator who audits the sites to ensure that they act fairly.

Section 21 of the FOIA provides that information is exempt where it is reasonably accessible elsewhere. Games, including poker, must be independently tested by one of the Commission’s approved test houses before they are made available to the public. Details can be found in our testing strategy and Remote gambling and software technical standards (RTS). Our testing strategy sets out a requirement for an annual audit to be conducted by an approved test house to review updates and RTP monitoring. Part of the requirement for RTP monitoring is to investigate any customer complaints that indicate an issue and provide an explanation.

As well as our testing requirements for games the Commission also conducts compliance assessments of licensees. This is following numerous checks of the company and ultimate beneficial owners at licensing stage. Further details on the licensing and compliance of gambling operators can be found on our website, such as Licensees Hub (

The Commission also monitors complaints received directly as well as those that are sent to alternate dispute resolution (ADR) services. This will include any complaints that are escalated after contacting a gambling operator. If we have sufficient information about an issue with an operator that we feel needs to be pursued, we will commence a dialogue with the operator and determine whether any action may be necessary.

Review of the decision

If you are unhappy with the service you have received in relation to your Freedom of Information request you are entitled to an internal review of our decision. You should write to FOI Team, Gambling Commission, 4th floor, Victoria Square House, Victoria Square, Birmingham, B2 4BP or by reply to this email.

Please note, internal review requests should be made within 40 working days of the initial response. Requests made outside this timeframe will not be processed.

If you are not content with the outcome of our review, you may then apply directly to the Information Commissioner (ICO) for a decision. Generally, the ICO cannot make a decision unless you have already exhausted the review procedure provided by the Gambling Commission.

The ICO can be contacted at: The Information Commissioner’s Office (opens in a new tab), Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

Information Management Team
Gambling Commission
Victoria Square House
Victoria Square
Birmingham B2 4BP

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