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Consultation response

Test House framework development

A summary of our response to the Test House Framework development consultation. Includes consultation questions, responses, and our position on these questions.

Our approach

Consultation proposal

The proposed framework would initially be introduced on a voluntary basis. We will monitor and review the impact of this and if necessary, take additional action to enforce the framework.

Summary of responses

Consultation questions

  • Q1. To what extent do you agree with the Commission’s proposed approach to enhancing the test house framework?
  • Q2. Should any other parties be included to work with the Commission in defining the detail of the framework? If so, why?
  • Q3. To what extent do you agree with our proposal to take additional action to enforce the framework?

The majority of the 20 respondents agreed or strongly agreed with the proposals that we should enhance the framework and that we should take action to impose the framework, if test houses do not do this on a voluntary basis.

Test houses will be given until the beginning of October 2020 to demonstrate that they are committed to working to the enhanced framework. Should test houses not agree to do this voluntarily, we will seek to change the LCCP to require operators to only use a test house that meets the enhanced standards. This is a similar approach to that taken with Alternative Dispute Resolution entities.

12 respondents wanted us to include other parties in the development of the framework, this includes the Financial Conduct Agency, (FCA) The Betting and Gaming Council (BGC)(previously RGA and ABB) and other regulators, such as the Danish or Swedish regulators.

Where there are relevant lessons to be learnt from external bodies and other regulators, the Commission will seek to integrate them into any new framework. However, we recognise that some regulatory regimes are very different to ours and therefore it is simply a matter of integrating what they do within our regime. For example, both Danish and Swedish regulators do not regulate business to business (B2B) operators. Instead they require oversight to be conducted at a business to customer (B2C) licensee level. The Danish regime requires accreditation of test houses to be conducted by another body, not the gambling regulator.

Our Position

We have considered involving other parties as suggested. We looked at the work of the FCA and other regulators before embarking on the consultation and remain of the view that the development of the framework should remain with the United Kingdom Accreditation Services(UKAS). We will liaise with other regulators such as the FCA, wider jurisdictions and trade bodies. We have considered other regimes and will look to ensure that, where relevant best practice will be incorporated.

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Executive Summary - Test House framework development
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Accreditation - Test House framework development
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