Testing strategy for compliance with remote gambling and software technical standards
Licensees must ensure sufficient RTP monitoring is in place for both under and overpayments. The Commission expects the main form of monitoring to calculate the actual RTP and compare that figure against the expected (advertised) RTP (if the mathematical design of a game results in a theoretical RTP of 95% then a simple calculation performed using the ‘win’ and ‘turnover’ amounts generated by the game will yield the actual RTP% (win/turnover).
Measurement frequency should be based on the volume of play (volume of play may be calculated based either on the number of games or amount of turnover). Relying on, for example, one measurement per month will not account for particularly popular games which will accrue a high volume of play in a short time. Wherever possible measurements should be an automatic backend process that would raise alerts if actual measurements are outside the expected tolerance. One acceptable method would be to setup daily measurements based on the last 30 days of play (or other set volume(s)), in this way measurements are performed over a rolling volume of play.
Volatility is vital to these calculations regardless of volume of play and will be a key parameter to include when establishing the allowable tolerance for each game.
Monitoring must not be so aggregated that it hides errors at a lower level. For example, errors that only exist in the mobile version of the game might be less visible if monitoring aggregates all markets and channels into one calculation.
Consumers are concerned with the fairness of games and often game faults are identified as a result of their complaints. Monitoring processes should include adequate investigation of consumer complaints (especially where a game attracts more than the normal level of complaints about fairness) and ensure consumers can be provided with clear, detailed explanations of how their performance compares with the game’s expected behaviour. It is not sufficient to notify players that the games have met the required testing standards as this does not acknowledge that errors can evade testing.
In scenarios where a B2B provides the games on behalf of B2Cs then live RTP monitoring would likely be performed by the B2B who holds the aggregated gaming transactions for all B2Cs. B2Cs must be made aware when incidents arise which require games offered under their licence are taken offline. New and amended contracts must make clear who is responsible for live RTP monitoring. RTP monitoring processes will be subject to the annual games testing audit. Further information of the audit is provided in Section 4 above.
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