Test Houses
Request
SECTION 1 - APPROVED TEST HOUSES AND CERTIFICATION STRUCTURE
Please provide a complete list of all approved test houses authorised by the Commission to certify remote gambling software during the requested time period.
Please provide the criteria, standards, or regulatory requirements that an organisation must meet in order to become an approved test house.
Please provide documentation outlining the Commission's process for approving, monitoring, auditing, and renewing approval for test houses.
Please confirm whether gambling operators and/or gambling software suppliers are permitted to select and appoint their own approved test house for the certification of their gambling software.
Please confirm whether approved test houses are paid directly by the gambling operator or software supplier whose product they are testing.
Please confirm whether the Commission provides any funding or financial contribution to test houses for the purpose of testing gambling software.
Please confirm whether gambling operators or software providers are permitted to submit the same software product to multiple approved test houses if certification is not obtained from a previous test house.
Please confirm whether approved test houses operate on a commercial basis competing for testing contracts from gambling operators or software providers.
SECTION 2 - TESTING AND CERTIFICATION PROCEDURES
Please provide documentation describing the testing and certification procedures required for remote gambling software prior to release to the public.
Please provide documentation describing the methods used by approved test houses to verify:
Random Number Generator (RNG) integrity
Return to Player (RTP) accuracy
Game fairness and statistical distribution
Game logic and outcome probabilities
Please confirm whether approved test houses review the full source code of gambling software during testing, or whether testing is performed using compiled binaries, simulation output, or other methods.
Please confirm whether the Commission independently replicates or verifies the testing results submitted by approved test houses.
Please confirm whether the Commission conducts any independent technical testing of gambling software separate from approved test houses.
If independent testing is conducted, please provide the number of such tests performed during the requested period.
SECTION 3 - SOFTWARE VERSION CONTROL AND DEPLOYMENT VERIFICATION
Please provide documentation describing the mechanisms used to ensure that the version of gambling software deployed to production environments is identical to the version tested by the approved test house.
Please confirm whether the Commission requires any of the following mechanisms to verify software integrity after certification:
cryptographic hashing
version control verification
digital signatures
production environment audits.
Please confirm whether the Commission conducts any post-deployment verification to ensure certified software has not been altered after approval.
SECTION 4 - TEST HOUSE AUDITS AND DISCIPLINARY ACTIONS
Please provide the number of audits conducted by the Commission on approved test houses during the requested period.
Please provide the number of disciplinary actions taken against approved test houses, including warnings, suspensions, or removal from the approved list.
Please provide any policies or guidance used by the Commission when determining whether a test house has failed to meet regulatory standards.
SECTION 5 - COMPLAINTS RELATING TO GAMBLING SOFTWARE
Please provide the total number of complaints received by the Commission relating to the fairness or integrity of remote gambling software during the requested period.
Please provide the number of complaints specifically relating to live dealer casino games.
Please provide the number of complaints alleging:
manipulation of game outcomes
incorrect RTP behaviour
RNG irregularities
software malfunction affecting payouts.
Please provide the number of these complaints that resulted informal investigations by the Commission.
SECTION 6 - INVESTIGATIONS AND ENFORCEMENT
Please provide the number of investigations opened by the Commission relating to the fairness, integrity, or functionality of remote gambling software.
Please provide the number of investigations relating specifically to live dealer casino systems.
Please provide the number of enforcement actions taken against licensees relating to unfair games, incorrect RTP, or software malfunctions affecting player outcomes.
Please provide a breakdown of enforcement outcomes including:
financial penalties
licence conditions
licence suspensions
licence revocations.
SECTION 7 - RTP MONITORING AND DATA ANALYSIS
Please confirm whether the Commission monitors actual live RTP data from operators to verify that real-world pay out behaviour matches the theoretical RTP certified during testing.
If such monitoring occurs, please provide documentation describing the methods used to detect anomalies or irregular pay out behaviour.
If such monitoring does not occur, please confirm that the Commission relies solely on pre-deployment certification testing to determine game fairness.
SECTION 8 - REGULATORY CAPABILITY AND TECHNICAL STAFF
Please provide the number of Commission staff responsible for technical compliance and gambling software oversight, including roles relating to:
software auditing
RNG analysis
statistical analysis of game outcomes.
Please provide a high-level description of the technical qualifications required for these roles.
SECTION 9 - FINANCIAL STRUCTURE AND REGULATORY FUNDING
Please provide the total amount of regulatory fines issued by the Commission each year during the requested period.
Please provide a breakdown describing how funds received from regulatory fines are allocated or distributed.
Please provide a breakdown of the Commission's total income by source, including:
licence fees
regulatory settlements
fines
government funding
levies.
SECTION 10 - CONFLICT OF INTEREST AND RISK ASSESSMENTS
Please provide any internal reports, policy reviews, or risk assessments conducted by the Commission regarding potential conflicts of interest arising from the operator-funded testing model used for gambling software certification.
Please confirm whether the Commission has conducted any analysis regarding the independence of approved test houses when they are paid directly by the operators whose software they are testing.
Response
Thank you for your request which has been processed under the Freedom of Information Act 2000 (FOIA).
In your email you have requested information regarding approved test houses for the period 1 January 2018 to the present date (13/03/2026).
The FOIA gives individuals the right to request only recorded information held by public authorities, such as the Gambling Commission. It does not provide an avenue for individuals to gain views or opinions of public authorities or information not held at the time the request is made. It also does not require us to create information.
Therefore, where you have not requested specific recorded information, we are unable to provide response with the remit of the FOIA. However, to be of assistance, where possible the Commission have provided a response.
The Gambling Commission can confirm as follows:
SECTION 1 – APPROVED TEST HOUSES AND CERTIFICATION STRUCTURE
- Please provide a complete list of all approved test houses authorised by the Commission to certify remote gambling software during the requested time period.
The Commission can confirm that a total of 34 test houses have provided testing services prior and since 2018. Currently, 14 test houses are approved by the Commission and appear on our website: Approved Test Houses.
- Please provide the criteria, standards, or regulatory requirements that an organisation must meet in order to become an approved test house.
Section 21 of the FOIA provides that information is exempt from disclosure if it is reasonably accessible elsewhere. In order to be of assistance, please see the following information published on our website:
- Please provide documentation outlining the Commission’s process for approving, monitoring, auditing, and renewing approval for test houses.
Section 21 of the FOIA provides that information is exempt from disclosure if it is reasonably accessible elsewhere. In order to be of assistance, please see the following information published on our website: Test House information reporting.
- Please confirm whether gambling operators and/or gambling software suppliers are permitted to select and appoint their own approved test house for the certification of their gambling software.
The Commission can confirm that licensees are free to engage a test house from the Commission’s approved list only.
- Please confirm whether approved test houses are paid directly by the gambling operator or software supplier whose product they are testing.
The Commission can confirm that approved test houses are paid by whichever licensee they are testing the product for. This could be any type of licensee.
- Please confirm whether the Commission provides any funding or financial contribution to test houses for the purpose of testing gambling software.
The Commission does not provide any funding or contribution to test houses. The Commission does not endorse or favour any test house.
- Please confirm whether gambling operators or software providers are permitted to submit the same software product to multiple approved test houses if certification is not obtained from a previous test house.
Licensees are able to submit software products to multiple test houses, however in practice testing remains with one test house, including any software re-testing, due to the cost and scheduling of a software test.
- Please confirm whether approved test houses operate on a commercial basis competing for testing contracts from gambling operators or software providers.
The Commission approves test houses to then provide services to licensees. Test house are businesses and act as such.
SECTION 2 – TESTING AND CERTIFICATION PROCEDURES
- Please provide documentation describing the testing and certification procedures required for remote gambling software prior to release to the public.
The Commission provides technical standards and testing strategy (which is available on our website) and UKAS has built a framework for the test houses to adhere to. UKAS advised within the development stages of the Test House Framework and the required ISO standards).
- Please provide documentation describing the methods used by approved test houses to verify:
- Random Number Generator (RNG) integrity
- Return to Player (RTP) accuracy
- Game fairness and statistical distribution
- Game logic and outcome probabilities
Section 21 of the FOIA provides that information is exempt from disclosure if it is reasonably accessible elsewhere. In order to be of assistance, please see the following information published on our website: Testing strategy for compliance with remote gambling and software technical standards - Procedure for testing.
- Please confirm whether approved test houses review the full source code of gambling software during testing, or whether testing is performed using compiled binaries, simulation output, or other methods.
The level and scope of testing required by the Commission includes review of source code to verify the implementation of RNG is in accordance with the RNG documentation.
More information on the requirements for the timing and procedures for the testing of remote gambling products can be viewed here: Testing strategy for compliance with remote gambling and software technical standards - Procedure for testing.
- Please confirm whether the Commission independently replicates or verifies the testing results submitted by approved test houses.
The Commission reviews test reports and annual games testing audits for outcomes, however we do not replicate or verify testing results.
- Please confirm whether the Commission conducts any independent technical testing of gambling software separate from approved test houses.
The Commission will assess controls that an operator has for elements of technical standards not covered by test houses.
- If independent testing is conducted, please provide the number of such tests performed during the requested period.
The Commission does not undertake its own independent technical testing of gambling software. We understand that the Games Register is a repository for tested games and associated details, including game certificates and game version from those who develop games and those that make them available to consumers.
SECTION 9 – FINANCIAL STRUCTURE AND REGULATORY FUNDING
- Please provide the total amount of regulatory fines issued by the Commission each year during the requested period.
We publish a list of regulatory actions taken by the Commission for the last three years. Section 21 of the FOIA provides that information is exempt where it is reasonably accessible elsewhere. As such, part of the information you have requested can be viewed on the Gambling Commission website: Regulatory actions
This information is collated on a rolling basis as the sanctions are removed from the Commission website, following the three-year period.
Please also see the following response to a previous freedom of information request, which links a spreadsheet containing more historic information falling within the scope of your request: Concluded enforcement cases.
In 2018, we can confirm that 11 regulatory fines were issued by the Commission. For 2018, please note:
- Not all cases in 2018 will have had a public statement published, so there will inevitably be gaps
- Public statements were generally not published for fines; they were mainly done for settlements
- Other sanctions, such as warnings, revocations, and suspensions, will not have had public statements published – these would have been on our register at one point, but will have dropped off after 3 years.
- Please provide a breakdown describing how funds received from regulatory fines are allocated or distributed.
Funds received from financial penalties imposed by the Commission under section 121 of the Gambling Act 2005 are paid to the Treasury’s Consolidated Fund.
Funds from regulatory settlements as described in Part 5 of the Licensing, compliance and enforcement under the Gambling Act 2005 - 5 - Regulatory enforcement can include an approved payment in lieu of financial penalty.
Further information relating to the destinations of regulatory settlements to be applied for socially responsible purposes can be viewed on the Gambling Commission website: Regulatory settlements applied for socially responsible purposes.
- Please provide a breakdown of the Commission’s total income by source, including:
- licence fees
- regulatory settlements
- fines
- government funding
- levies.
The Commission is an independent public body. We are funded in 2 ways. We are funded by application and licence fees set by the Secretary of State for Culture, Media and Sport, approved by Parliament and paid by the gambling industry. These fees fund all gambling regulation except for the National Lottery.
We are also funded, in respect of National Lottery functions, by Grant-In-Aid (GIA) from the National Lottery Distribution Fund.
Section 21 of the FOIA provides that information is exempt where it is reasonably accessible elsewhere. In order to be of assistance, please see the following information published on our website: Annual reports.
SECTION 10 – CONFLICT OF INTEREST AND RISK ASSESSMENTS
- Please provide any internal reports, policy reviews, or risk assessments conducted by the Commission regarding potential conflicts of interest arising from the operator-funded testing model used for gambling software certification.
The test house approval process requires applicants to declare any potential conflicts involving senior or testing staff. Once approved, test houses must report any staff changes and related responsibilities to the Commission.
- Please confirm whether the Commission has conducted any analysis regarding the independence of approved test houses when they are paid directly by the operators whose software they are testing.
The Commission does not test or analyse a Test Houses independence other than at application stage. However, National Accreditation Bodies may test independence within the ISO accreditation standards and cycle of each test house in the country in which they reside.
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.
It should be noted that if you wish to raise a complaint with the ICO about the Commission’s handling of your request for information, then you are required to do so within six weeks of receiving your final response or last substantive contact with us.
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