Remote gambling equipment
Introduction
This guidance sets out our interpretation of which elements of a gambling system will meet the definition of remote gambling equipment (‘key equipment’) set out in the Act. It provides additional guidance for those completing the Gambling Commission’s application forms and for those considering locating remote gambling equipment in Great Britain.
The information is intended to provide guidance to operators on identifying key equipment; it is not intended in any way to replace the definition set out in the Gambling Act 2005 (the Act) (opens in a new tab).
Important note
This guidance is concerned with circumstances where a licence is required by virtue of Section 36(3)(a) of the Gambling Act (opens in a new tab). It sets out the Commission’s interpretation of what constitutes remote gambling equipment, which if located in Great Britain will trigger the need for a remote gambling operating licence. This guidance is less central when considering circumstances post 1 November 2014 in which operators are required to hold a form of remote operating licence from the Commission because they provide facilities for gambling to consumers in Great Britain, regardless of where their remote gambling equipment is located. However, it remains relevant as informing what the Commission means when it uses the term 'remote gambling equipment', for example in LCCP condition 2.1.
Background - remote gambling equipment
If an operator providing facilities for remote gambling locates any ‘remote gambling equipment’ (sometimes referred to as ‘key equipment’) in Great Britain that operator is required to hold a form of remote gambling licence whether or not those facilities are provided for use wholly or partly in the United Kingdom.
The Act defines remote gambling equipment in Section 36(4) and sets out some specific exclusions in 36(5):
(4) In this Act ‘remote gambling equipment’ means, subject to subsection (5), electronic orother equipment used by or on behalf of a person providing facilities for remote gambling:
(a) to store information relating to a person's participation in the gambling
(b) to present, to persons who are participating or may participate in the gambling, a virtual game, virtual race or other virtual event or process by reference to which the gambling is conducted
(c) to determine all or part of a result or of the effect of a result
(d) to store information relating to a result
(5) In this Act ‘remote gambling equipment’ does not include equipment which:
(a) is used by a person to take advantage of remote gambling facilities provided by another person
(b) is not provided by that other person.
Reading this document
In this document we use the term ‘component’ to refer to software that is run by (executed) or data that is stored on a piece of equipment. A component fulfils a specific purpose (for example, an RNG is a component that generates random numbers); a piece of equipment may host one or more components.
Under the heading “Facilities for gambling and remote gambling equipment” we provide guidance on and specific examples of the Commission’s interpretation of whether equipment storing certain components or data is used in the provision of facilities for gambling.
Under the heading ‘Remote gambling equipment’ we provide a table and list those components and data that are stored on equipment that we believe meet the definition set out in the Act.
In order to set the components into context this document also contains a gambling system overview, a component glossary and a number of high-level diagrams.
The diagrams are not intended to describe any particular gambling system nor do they define the way a gambling system should be implemented.
Facilities for gambling and remote gambling equipment
Based on our interpretation of the Act 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 36(4)(a) to (d) (opens in a new tab).
In order to assist operators to identify their key equipment this section provides guidance on our interpretation of "used in the provision of facilities for gambling" in the context of remote gambling equipment. Under the heading ‘Remote gambling equipment’ we list those components and data that are stored on equipment that we believe meet the definition set out in the Act.
We read "used in the provision of facilities for gambling" as relatively narrow and not extending to all equipment used by a remote gambling operator generally in connection with, or incidentally to, the provision of the gambling. For example we do not consider equipment used for integrity testing, money laundering compliance and monitoring, complaints handling and responsible gambling analysis to be “used in” the provision of the gambling activity because they are not used by the customer or operator as part of that gambling. Specific examples will be set out in the following paragraphs.
Marketing, bonuses and incentives
Operators typically keep some data about customers and their previous gambling activities for the purpose of marketing, including offering bonuses and other incentives related to the amount that a customer has gambled with the operator. This data may be stored separately from similar data stored in other parts of the operator’s infrastructure.
In the case of equipment which stores information relating to customers’ participation in the gambling and which is used for bonus and reward calculations, we consider only the core system whose principal function is to offer, operate and settle the gamble to be “used in” the provision of facilities for gambling.
We would consider systems used to calculate bonuses or other rewards or incentives which are awarded or determined during the course of a single gambling transaction or session of “play” (whether the activity is betting, gaming or participating in a lottery) to be remote gambling equipment. We would not take the same view of systems that only operate to calculate rewards and incentives based on a customer’s historic play. The latter we would normally regard as an aspect of marketing and not as tantamount to a prize related to specific gambling.
Table 1 provides examples of types of bonus and incentives. In the following examples set out, numbers 1 to 5 are linked to the current gamble or session and equipment which stores or processes the relevant data would therefore be remote gambling (key) equipment. Examples 6 – 13 are not linked to the current gamble or session and only operate to calculate rewards and incentives based on a customer’s historic play.
Table one
Linked to current gamble or current session (gaming)
| Reference | Type | Linkage to gamble | Qualification for bonus | Reward example |
|---|---|---|---|---|
| 1 | Game feature (random) | Current game (random) | Triggered by random event | Get 3 cherries on any TootyFruity game and win a free spin |
| 2 | Game feature (random) | Current game (random) | Triggered by random event | Pineapple feature doubles the win on your TootyFruity winning line |
| 3 | Winnings multiplier | Current bet | Triggered by random event | Place a £10 bet on this match and we'll double your winnings |
| 4 | Free game (spend based) | Current session/game (accumulated spend) | Cumulative consecutive spend on single game | Stake £10 over any number of consecutive TootyFruity games and you'll earn a free £1 spin |
| 5 | Session spend | Current session (accumulated spend) | Spend in a single session | Stake £50 in this gaming session and we'll put £10 in your account (or give you £10 worth of free credits to spend in the game) |
Not linked to current gamble or current session
| Reference | Type | Linkage to gamble | Qualification for bonus | Reward example |
|---|---|---|---|---|
| 6 | Loyalty scheme (point) | Current bet / accululated spend | Accumulated amount spent/staked converted to loyalty points | For every whole £1 staked we'll give you 1 loyalty point - 100 pts may be redeemed for £10 (or a £10 free bet) |
| 7 | Loyalty scheme (cash / free bet) | Accumulated spend | Amount staked | Once you reach a total staked of £50 we'll put £10 into your account (or give you a free £10 bet) |
| 8 | Loyalty scheme (commission) | Accumulated activity over time-period | Amount regularly spent (peer to peer) | Varied commission bands depending on customer spend |
| 9 | Monthly loyalty bonus | Accumulated activity over time-period | Amount spent in specific timeframe | For every whole £20 staked in August, we'll give you a £10 free bet (or put £10 in your account) |
| 10 | Playing time | Accumulated duration of play | Amount of time spent playing | We’ll put £5 into your account for every hour you play at poker |
| 11 | Deposit matching | Unrelated / accumulated spend | Registration, deposit amount and total amount staked | Register and deposit £30 and we'll put £30 into your account after you're total stakes have exceeded £50 |
| 12 | Deposit matching | Unrelated | Registration, deposit amount | Register and deposit £10 and we'll add another £10 to your account |
| 13 | Good will campaigns | Unrelated to gambling activity | Non-gambling customer attribute | Happy birthday … we've put £10 in your account (or have a free £10 bet on the tennis) |
Client application download servers
Games may be deployed using a “client application”, that is, a piece of software that is downloaded by and installed on the end-user’s device to present a rich graphical and auditory interface that represents the game. Client applications are designed for a range of end-user devices including PCs, mobile phones or set-top boxes (interactive digital TV).
Operators may deploy specific equipment to make client applications available for download. To improve the speed with which the customer is able to download the application, such equipment may be placed in a number of geographical locations. Typically the equipment is also used to download patches and upgrades to the application and to verify the integrity of the installed application, that is, to check that the client software has not been tampered with before permitting access to gaming.
In the context of download servers, the Commission would not normally consider equipment that is used as previously described as being used in the provision of facilities for gambling, as long as that equipment is only being used as a means of distributing, updating and checking applications to be installed on the end-user’s device and is not involved once the gambling commences. To meet this distinction the same equipment must not be used to determine the results of virtual events, pass on the contents of gambles from the client application to the server, nor pass results from the server to the client.
For example, an offshore operator may choose to place a server in Great Britain that is used for downloading game applications but once the client application has been installed and the gaming has commenced the equipment is no longer involved. In that case the operator would not require a licence (unless providing facilities for gambling to customers in Great Britain).
If however, an operator located a download server in Great Britain that was also used during gaming to exchange information about the content of the customer’s gamble and the results of the virtual event, this equipment would, under our interpretation, be used in the facilities for gambling. We would consider such equipment as being used “to present, to persons who are participating or may participate in the gambling, a virtual game, virtual race or other virtual event or process by reference to which the gambling is conducted” (Section 36(4)(b)) (opens in a new tab).
Therefore, in this example, the operator would have to hold a remote casino licence by virtue of having remote gambling equipment in Britain notwithstanding where their customers happened to be located.
Business continuity arrangements / disaster recovery
Organisations will have in systems and technologies in place that are intended to reduce the likelihood of operational downtime, prevent data loss, and to provide business continuity in the event of equipment failure, scheduled maintenance or loss of an operational data centre.
The equipment used for these purposes is likely to contain components and data set out in Table 2. In considering whether such systems contain remote gambling equipment, the Commission draws a distinction between equipment used to store a backup of operational data for a gambling system and equipment that is used as a standby or disaster recovery system.
The Commission defines standby and disaster recovery equipment as equipment that the operator intends to use in, or as a replacement for, the ‘live’ system in the event that the equipment normally used is unavailable. Standby and disaster recovery equipment is, therefore, intended to be used in the provision of facilities for gambling and any such equipment used to deploy the components identified in Table 2 would be remote gambling equipment, which if sited in Great Britain would require the operator to hold the appropriate remote gambling licence from the Commission for the activities for which they will be using the equipment.
For example, an operator, which does not provide facilities for gambling to consumers in Britain nor have its primary remote gambling equipment in Britain does not require a licence from the Commission. But if that operator chooses to have a disaster recovery facility in Great Britain, which would become its live gaming system in the event that its primary remote gambling equipment became unavailable, that disaster recovery facility is equipment intended to be used in the provision of facilities for gambling and the operator would therefore require a remote operating licence.
The Commission has also considered whether equipment that stores back-up data for gambling systems is remote gambling equipment. We define equipment used to store back-up data as equipment that holds a copy of operational data but which will not itself be used as part of the 'live' gambling system. The data will instead be restored onto 'live', standby or disaster recovery equipment. We would not normally consider such equipment to be "used in the provision of facilities for gambling".
Remote gambling equipment
Whether or not any piece of equipment that is used in the provision of facilities for gambling will be classified as ‘remote gambling equipment’ is determined by the components that reside on it. If any of the components perform the functions listed in section 36(4) of the Act (opens in a new tab), then that piece of equipment is remote gambling equipment, regardless of what other components may be deployed on the equipment. Table 2 summarises the components that meet our interpretation of the definition set out in the Act where they are used in the provision of facilities for gambling. The equipment they are stored on would therefore meet the definition of remote gambling equipment. A more detailed description of the components can be found in Component Glossary.
Table 2 identifies components that meet our interpretation of the definition set out in the Act.
Cloud servers
If remote gambling is to be facilitated from equipment in Great Britain, then a remote gambling operating licence will be required; the same premise applies when the remote gambling equipment, such as cloud servers, are provided by a third party.
Licence holders will need to establish with the external provider how the cloud system works and if the requirements of an operator regarding the location of their remote gambling equipment can be satisfied. Any service level agreement with an external provider must have capacity to meet these requirements and achieve compliance with the LCCP.
Table 2
Presentation components
| Equipment which contains | Act ref | Brief description |
|---|---|---|
| Virtual Event and game “Pages” | Section 36 (4)b | Software that serves ‘pages’ or other media that present virtual events on which people may gamble, including:
|
Application components
| Equipment which contains | Act ref | Brief description |
|---|---|---|
| Virtual Event Controller | Section 36 (4)c | Software that determines the result of a virtual event based on an RNG output |
| Settling | Section 36 (4)c | Software that marks up (as winner or loser) and settles (determines) the amount to be paid of gambles |
| Random Number Generator | Section 36 (4)c | Software or hardware that generates random data to be used by games / events |
Data
| Equipment which contains | Act ref | Brief description |
|---|---|---|
| Gambling Transaction Records | Section 36 (4)a and d | Stored information about: An individual’s gambling transactions (e.g. £10 single on Trap 3 in the 4.37 at Monmore, 01/12/06), bet logs, game logs. The results of an individual’s gamble, e.g. win/loss amounts, including summarised information about an individual’s wins or losses, where this is used in the provision of facilities for gambling (see paragraphs 8 to 10 on Facilities for gambling and remote gambling equipment) |
| Virtual Event State | Section 36 (4)a and d | Information stored in order to keep track of the last known state of a virtual event or virtual game that an individual participated in |
Any equipment on which any of the above components or data reside is considered to be remote gambling equipment.
Gambling systems overview
For the purpose of this advice, gambling systems have been logically separated into 5 layers:
End-user devices:
The device used by the customer to access the gambling facilities. Some devices may be used in different ways, for example a mobile phone could access via specialised Java applications (‘client application’) provided by the operator or via the phone's built-in browser.
Presentation and formatting:
Components concerned with the presentation and formatting of information that will be displayed on the end-user device and components that provide specialised interfaces for client applications (eg Betting Exchange Client, Casino Client).
Applications:
The software components that process incoming or outgoing information, each providing a particular function, such as settling, or account management.
Data storage:
Where data is physically stored after it has been processed by applications.
External interfaces:
Components that handle communication with external systems, for example, between a sportsbook and a card processing service or Poker Room.
Traditional betting (eg sportsbook) and virtual event gambling (such as casino gaming, arcade, poker, virtual horse racing) systems have been considered separately for several reasons. Virtual event and betting systems use different terminology and have distinct technical impacts on the systems required to support them.
Virtual event systems require random inputs in order to determine the outcome of games, which are normally provided by internal or external Random Number Generators. Virtual event systems may also support multi-player games where multiple players ‘sit’ at the same table (whether they play against each other or against the house) and require systems to support multi-player tables.
Betting systems rely on external sources of information to determine the outcome of bets (e.g. sporting results), which are provided automatically through electronic ‘data feeds’ (e.g. from SIS or PA) or are entered manually.
Many operators offer betting (‘sportsbooks’ or exchanges) and virtual event gambling (such as online ‘casinos’, ‘arcades’, poker). Such operators may have different product offerings hosted by different third party providers. These third party providers may host ‘virtual’ casinos or shared poker rooms for several different operators on the same equipment. The operator allows the customer to purchase chips or tokens to take to the casino. The third party host provides a ‘shadow’ account and transactional systems that keep track of the customer’s chip/token balance and gambling activity (‘bet record’ or ‘game log’).
Shared poker rooms are managed by a provider on behalf of a number of their licensees. As with integrated casinos, players normally purchase tokens/chips, which are transferred to the poker room and held in a shadow account.
The following pages present some simplified diagrams intended to represent the sort of components found in various types of gambling system. Items highlighted with bold text and cross-hatching fulfil our interpretation of remote gambling equipment.
Software can be deployed within remote gambling infrastructures in any number of ways. Although some operators will have dedicated presentation, application, data and interface servers, many operators will not. These logical diagrams do not, therefore, necessarily map directly onto any particular server infrastructure.
Simplified Sportsbook / Betting exchange model
Model to come
Simplified Stand-Alone Virtual Event (Casino/Arcade) Model
Model to come
Simplified Integrated Virtual Event & Sportsbook Model
Model to come
Component Glossary
Browsers
Browsers are non-specific applications that can be used to view any web page and may be on any supported device, such as a PC, mobile phone or other portable device.
Client applications
Client applications have been developed specifically by operators or software developers to communicate with the core gambling system. Client applications typically provide a ‘richer’ visual and functional environment than can be achieved using a web browser. Importantly (for security) client applications do not contain any software that determines the result of a bet.
Devices
Many client devices can be used to interact with the gambling systems. The devices themselves may utilise different methods to interact with the gambling system. The software tool or application the customer actually interacts with is known as the ‘user interface’; the three most common types of which are outlined below. Customer’s devices are explicitly excluded from being classified as gambling equipment by the Gambling Act1 .
Telephones
Telephones may be used to interact directly with the gambling system using touch-tone, Intelligent Voice Recognition (IVR) systems or via a telephonist.
Presentation and formatting
It is common practice to deploy those software components concerned with the presentation or formatting of content (e.g. web pages) and direct connection to end-user devices (e.g. interfaces) on separate dedicated servers. These servers communicate with the rest of the infrastructure over communications networks which may be local or remote.
Web pages (content)
Web pages present text or graphical information to customers. The web page allows the customer to interact with a gambling system and brings together various sources of information allowing them to view their account history, gambling history, movement of funds between systems (e.g. sportsbook to casino) and to amend (permissible) details. For a betting operator these pages would normally be referred to as their ‘sportsbook’. Web pages are also commonly used to display marketing, help or contact information. Web pages that contain animated or video content for virtual events are considered separately (see ‘virtual event web pages’).
Virtual event web pages
Virtual event web pages contain graphics, animation, text and sometimes sound that represents a game or other virtual event and displays results via the customer’s browser.Several technologies are used including flash, java, shockwave, and mpeg-4.
Exchange/casino/arcade/sportsbook/digital TV application interfaces
Application interfaces provide a way for remote client applications to interact with the core gambling system. The interface typically handles formatting and exchange of messages. Betting Exchanges typically use a dedicated client application in order to support the relatively rich content that the customer needs in order to be able to interact with the betting exchange. Similarly casino, arcades, sportsbook and digital TV interfaces are used to manage communication with specific client applications.
Download manager
Download managers store client applications and make them available for customers to download to their device (mobile phone, PC, etc). They may also keep track of versions and intelligently download newer versions or patches to existing client applications.
Telephonist user interface
The operator user interface provides a means for the telephonist to capture customer details, bets, financial transactions and queries.
Applications
Applications may be deployed on a one-to-one basis (one application per server) however it is more common for multiple applications reside on the same physical piece of equipment for reasons of economy and performance.
System monitoring tools
Monitoring tools are frequently used to monitor the technical aspects of the gambling system including performance, resource utilisation, or the performance or interaction with external systems.
Reporting
Reporting applications gather and summarise information from the system, providing reports on most aspects of the system including ongoing liability, virtual event statistics, account activity (for example, large bets, large wins, summarised information) and profit/loss reports. Reports may be scheduled to run at particular times of day, run manually or triggered by unusual activities ('alerts').
Bet capture/bet matching
The capture component processes the information about the customer's gamble, validating the selections against the rules of the particular bet type, game or event/market before it is stored in the gambling transaction record. For a betting exchange this component would be the 'bet matching' component.
Customer management
Customer management applications provide facilities for customers to register their details, deposit funds, update account details and view their account history. Customer Support personnel use the same or similar components to manage aspects of customers accounts.
Settling
Settling is sometimes referred to in two parts, ‘marking-up’ (ie identifying individual gambles as winners or losers) and ‘settling’, the term settling is used here to represent both parts. Settling determines whether or not a customer has won based on the outcome of some real or virtual event. If the customer has won, the settling component calculates the value of the return to the customer and corresponding adjustments are made to the customers account balance.
Random number generator (RNG)
Random number generators use specialised hardware and software to generate sequences of numbers that are unpredictable, that is, numbers that do not have a detectable pattern. Virtual events always require one or more numbers within a specific range (for example a roulette game may request 1 number between 0 and 36). The output of the RNG must be 'scaled' to fit into this range. The scaling component may be part of the RNG, a separate component or part of the game depending on the deployment.
Virtual event control
Each virtual event has its own rules and behaviour. Virtual event control is used here as a generic term for components that handle:
- placing a request for random numbers and/or receiving random numbers
- the determination of the virtual event result using the random number input
- issuing instructions to the client application to display the result of the event and the result of the customer's gamble.
Some virtual event gambling may also require components that coordinate activities in multi-player scenarios.
Back-office tools
Back-office tools provide a variety of functions that aid the smooth running of the system or allow operational personnel to perform tasks such as pricing and setting limits on betting opportunities, adjusting customer balances (for example, in the case of settlement errors), and changing event configurations.
Security
Security, for example authorisation and authentication (user-name, password, access rights, etc), and audit trails may be deployed within other components or applications, but may also be deployed as a separate component.
Data
Data storage is frequently separated from applications and from presentation onto specialised ‘database’ (DBMS) servers, however, some application or processing may occur on database servers and some operators deploy data and applications on the same equipment. The deployment of databases is further complicated because server hardware and the disks that physically store the data may be separate devices. Dedicated (and expensive) data storage equipment is often used by larger operators for performance and management purposes. Operators normally have some form of back-up or archiving that keeps a copy of data that will be used in the event of loss of the main source of data, either directly or following restoration to the production system.
Customer details
Customer details include information about the customer, such as name, address, credit and debit cards and other payment-type information and account number(s). Customers may register their details whether they intend to gamble or not.
Customer account (wallet)
The customer account keeps track of the customer’s balance and the transactions into and out of the account. The balance is amended by other components following deposits/payments, withdrawals, gambling transactions, etc. The information stored may also include monies taken to and from other wallets and/or shadow wallets. The account will be linked in some form to customer’s gambling transaction records and may also be linked to external shadow wallets via a reference number or other identifier.
Shadow account (shadow wallet)
The shadow account or token/chip wallet is only relevant for integrated gambling systems where monies are moved from one product to another. Essentially the shadow account contains the customer's chip/token balance and a reference ID from the originating system.
Gambling transaction record (game/bet history)
This data store may be referred to as a virtual event log, game log, game history, bet log, bet record, or bet history. The gambling transaction record contains the details of the customer's gambling transactions such as selection, stake, odds, and bet type. The gambling transaction record also stores the result (win/loss) of the individual gambling transactions. Gambling transactions are linked to customer accounts, normally via the customer's account number so that account balances may be updated following settling processes. Summarised information about amounts staked, amounts credited as winnings and amounts taken as losses would also be classed as gambling transaction records.
Events and markets
Information about sporting or other 'real events, such as location, time and date, competitors, etc, for example, Arsenal (home) vs Man Utd (away), on the 5th June, at 3pm, are stored along with associated betting markets, (if they exist, eg win/lose/draw) and the current and previous odds (where they exist). This information is commonly received from external sources, such as the Press Association or Satellite Information Services in Britain, and is stored by other non-gambling organisations.
Virtual event state
Gambling systems may need to maintain a record of the event state in order to be able to recover interrupted gambling where, for example, a customer loses connectivity to the server part way through a multi-stage game.
Management and marketing information
Management information is non-production data, that is, data that is not intended to be used in 'live' systems in the provision of facilities for gambling. Management information is normally stored separately to be examined at a later point in time. Management information is used to explore trends, betting patterns, popularity of games or types of betting, successful promotions, etc. This may include data for marketing purposes or for the calculation of bonuses or incentives based on customer’s accumulated gambling activity.
External interfaces
Interfaces to external systems (often referred to as APIs or Application Programming Interfaces) could be deployed anywhere within the infrastructure, though larger operators will often have dedicated equipment. Interfaces support the exchange of information with other organisations or other systems. Gambling systems have a variable number of external interfaces depending on the size and scope of the operation. As noted earlier, many operators offer sportsbook and virtual events including ‘casinos’ and ‘poker rooms’ often hosted/managed on their behalf by third parties. To gamble using these systems the customer purchases chips/token; the Interfaces are used to exchange information about the value of these and minimal information about the customer's identity (often just a reference ID).
Disaster recovery & backup data
Disaster recovery
Most large operators and many of the smaller ones have some kind of disaster recovery (DR) facility. DR facilities require data to be copied from the production infrastructure over to DR infrastructures, which may be identical to or be a trimmed down versions of the production infrastructure. DR facilities are normally only invoked after a significant failure event occurring in the production infrastructure. However, operators may also ‘test’ their disaster recovery processes and infrastructures by transferring live operations to them for short periods.
Backup data
Backup data is distinct from DR data since it is not intended to be used directly as a live source of data. Instead this data is used to restore information to a production facility (or a DR mirror).
Footnotes
1By virtue of Section 36(5) (opens in a new tab), the Act excludes client devices, such as home PC’s or mobile phones unless these devices are provided by
an operator to enable a person to take advantage of facilities for gambling provided by that operator.
Last updated: 29 April 2021
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