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Testing strategy for compliance with remote gambling and software technical standards

Annual games testing audit 

The requirement for an annual games testing audit applies to those licensees that hold a gambling software licence and a remote bingo operating, remote bingo (game host), remote casino, remote casino (game host), remote general betting (standard) (virtual events) or remote betting host (virtual events). Generally this will include those licensees that have assumed responsibility for games testing (eg from a software supplier or content developer). The audit must be carried out by a Commission approved test house and will:

  • check a randomly selected sample of major and minor updates (to confirm that they did or did not require external testing). Section 3 and Annex A provide further detail of major/minor updates
  • confirm that licence holders have adhered to required change controls (applicable elements as contained in Section 6 of the testing strategy) 
  • confirm the list of games made available to consumers served in reliance of a Commission licence
  • confirm licensees have in place effective live RTP monitoring processes. 

The above requirements set the minimum scope of the audit. The Commission may broaden the scope in certain cases to address specific concerns (eg evidence of non-compliance with other aspects of the RTS/LCCP). 

Where issues are identified by the audit these may be corrected by licensees, however the identified and corrected issues must still be included in the final audit report to the Commission. 

The results of the audit must be counter-signed by the relevant PML holder or specified person and submitted to the Commission directly or via the approved test house that conducted the audit. It remains the responsibility of the licence holder to ensure that the audit report is submitted to the Commission. The final audit should be submitted via the eServices portal.

The audit submission dates will be staggered in order to avoid all audits being performed within a similar period and therefore putting pressure on test houses. Licensees will be assigned to a submission pool, as illustrated in Table 2 below. The Commission may be able to accommodate certain requests from licensees to be assigned to a specific pool, though this cannot be guaranteed if the allocation of the preferred audit submission pool is oversubscribed.

The Commission expects those licensees that are exempt from the annual audit requirement to seek assurance that games and updates have been tested in accordance with the testing strategy prior to release. 

Table 2: Annual games testing audit submission pools

Submission pools

Audit period

(previous 12 months)

Deadline for submission of annual audit to Commission

Pool 1

1 July – 30 June following year

Four weeks after audit period end date

Pool 2

1 October – 30 September following year

Pool 3

1 January – 31 December full calendar year

Pool 4

1 April – 31 March following year


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Testing strategy for compliance with remote gambling and software technical standards

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Annual games testing audit template

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