Consultation on remote key equipment - responses
Consultation responses - April 2020
Executive summary - Consultation on remote key equipment - responses
A piece of equipment is remote gambling equipment if it is "used in the provision of facilities for gambling" and the components deployed on it perform one or more of the functions set out in section 36(4)(a) to (d) of the Gambling Act 2005 (opens in a new tab). These functions include storing information in relation to a person’s participation in gambling determinations and information relating to a result. It is used only by online operators and is also known as "key equipment".
Licence condition 2.1.1 requires an operator to make an application to vary their licence every time they wish to add or move key equipment to a different jurisdiction. In addition, moving key equipment within a jurisdiction must be reported to us via key event 22.214.171.124.
Over time it has become apparent that physical inspection of key equipment is not necessary as it is the data held on the equipment that is required. We will retain the ability to request the data via licence condition 2.1.2. In an outcome focused regulatory environment we look initially for assurance rather than undertaking physical checks and therefore do not need to know the number of pieces of key equipment or where they are located. Further, technology continues to develop since the creation of these conditions and there is increasingly a move away from physical remote gambling equipment to storage in the cloud.
The consultation proposed the removal of the condition, 2.1.1. If this approach is adopted, we would also no longer require licensees, under notification requirement 126.96.36.199, to tell us when they add or relocate key equipment within the same country.
Licence condition 2.1.1:
All remote casino, bingo and betting licences other than ancillary licences and remote betting intermediary (trading room only) licences
1. Licensees must not add to any of the remote gambling equipment listed in Schedule R to their licence or relocate any of that equipment from the jurisdiction stated in the Schedule without first obtaining a variation of that detail of the licence on application pursuant to section 104(1)(b) (opens in a new tab) of the Act.
2. For the purposes of this condition, in the case of geographical areas which are subject to the laws of both a state or provincial government and a federal government ‘jurisdiction’ means the area of the state or province; but England, Wales and Scotland are to be treated as a single jurisdiction.
If key equipment is moved within a jurisdiction, a licensee must advise of this via key event 188.8.131.52:
The entering an arrangement whereby a third party provides services to, or grants any licence concession or permission to, the licensee other than for full value: full details of the arrangements must be supplied.
We received 35 responses
- 30 from operators
- 1 from a trade association
- 4 from other organisations – one law firm, two gambling consultants and one supplier of connectivity and infrastructure.
There was significant support from respondents to the consultation proposals. Following consideration of the responses we intend to implement both proposals. Removal of this licence condition and notification requirement will result in increased efficiency and a reduction in regulatory burden.
Remove licence condition 2.1.1:
We will implement this change in full
The Commission will remind operators that access to data is a requirement under licence condition 2.1.2.
Not to require notification via key event 184.108.40.206 of any changes to the location of key equipment within a jurisdiction:
We will implement this change in full
Key event 220.127.116.11 will be retained as there are other matters that need to be reported against it such as, a real events betting operator signing up with Opta to use their sport analytics software on their websites.Previous section
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Our approach - Consultation on remote key equipment - responses
Last updated: 13 April 2021
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