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Test Houses

information about Test Houses

Published: 11 December 2023

Last updated: 11 December 2023

This version was printed or saved on: 11 May 2024

Online version: https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/test-houses

Overview: To ensure fairness for consumers, some gambling products must be tested by an approved Test House before they are released to the market. The Gambling Commission issues a list of approved Test Houses and all operators who are manufacturing gaming machines, gaming machine software, and remote gambling software, must use an appropriately accredited Test House.

Background

Licence condition 2.3.1 - Licensees must follow the Commission's technical standards and with requirements set by the Commission relating to the timing and procedures for testing.

Test Houses are approved to test compliance against our requirements and the technical standards, including:

Not all Test Houses will have been approved in every area and it is the responsibility of the Licensee to ensure that the Test House they appoint is approved for the gambling facilities they are seeking to provide.

Test Houses play a vital role in ensuring games are fair to consumers and must have full accreditation to BS EN ISO/IEC 17025 standards (opens in new tab) and selected requirements from ISO/IEC 17065 and ISO/IEC 27002.

Approved Test Houses

Where third party testing is required by the testing strategy, Licensees must appoint an approved Test House from the following list.

Test Houses approved by the Gambling Commission as of 11 December 2023.

Test houses and details
Test House (Trading Name) Website address
(opens in new tab)
Remote Technical Standards Categories of gaming machines Requirements for bingo and casino equipment
BMM Testlabs (South Africa) www.bmm.com Yes All categories (except cat B3a and compensated versions) No
BMM Spain Testlabs SL www.bmm.com Yes All categories Yes
eCOGRA Limited www.ecogra.org Yes None No
Gaming Associates Europe Ltd www.gamingassociates.eu Yes None No
Gaming Laboratories International (GLI), LLC www.gaminglabs.com Yes All categories Yes
GLI Europe BV www.gaminglabs.com Yes All categories Yes
GLI Austria GmbH www.gaminglabs.com Yes All categories Yes
GLI Africa (Pty) Limited www.gaminglabs.com Yes All categories Yes
GLI UK Gaming Limited www.gaminglabs.com Yes All categories Yes
Global Lab Limited www.global-lab.eu Yes None No
iTech Global Pty Limited (iTech Labs) www.itechlabs.com Yes None No
Quinel Ltd www.quinel.com.mt Yes None No
RiskCherry www.riskcherry.com Yes None No
SIQ Gaming Laboratories Ltd www.siqgaminglabs.com Yes All categories Yes
Trisigma B.V. www.trisigma.com Yes All categories Yes

Applying for Test House approval

The Gambling Commission has worked with the United Kingdom Accreditation Service (UKAS) to develop a Test House Framework that will ensure all Test Houses are operating consistently to the same high standards.

The Commission issues a list of approved Test Houses on our website and all operators who are manufacturing gaming machines, gaming machine software, and remote gambling software, must use an appropriately accredited Test House. The information on this page is to explain how a Test House can seek approval as a Test House and be added to the approved list.

Does the Commission publish a copy of the Framework document?

Accreditation to ISO/IEC 17025, and selected requirements from ISO/IEC 17065 and ISO/IEC 27002, is mandatory for a Test House. Because the Framework contains copyrighted details relating to these standards, it is a British Standards Institute (BSI) requirement that the copyright material is protected. Therefore, the Commission is unable to post a copy of the Framework on our website. Read a summary of our response to the Test House Framework development consultation for information including consultation questions, responses, and our position on these questions.

How does a Test House apply for Approval?

For Test Houses interested in becoming an approved Test House the first step is by emailing testhousesubmission@gamblingcommission.gov.uk expressing interest.

The Commission will send a Non-Disclosure Agreement (NDA) to the Test House to complete. The NDA requires the names of one to three individuals who are employed by the legal entity seeking to be approved as a Test House. These individuals must sign and date the NDA. The conditions of the NDA require that the named individual(s) are the only ones who have access to the Framework and that they agree to use all reasonable endeavours to prevent the unauthorised duplicating, copying or pirating of the Framework.

The signed and dated NDA must be returned to the Commission by emailing testhousesubmission@gamblingcommission.gov.uk

Once the NDA is received, the Commission will issue a copy of the Framework, watermarked with the name of the legal entity, together with an application form and guidance notes. To proceed with an application, the application form must be completed and returned by emailing testhousesubmission@gamblingcommission.gov.uk

What if the Test House decides not to apply for Approval?

If the Test House decides not to proceed with an application for approval from the Commission, it should destroy all copies of the Framework, printed and electronic. There is no need to notify the Commission of the decision.

How We Process Test House Applications

Our Statement of principles for licensing and regulation underpins all of our work, including how we assess Test House applications.

Assessing suitability

When considering suitability to become a Test House, we want to see evidence to support an assessment of the following areas.

Identity and ownership

We need to understand the identity of the legal entity that is applying to be approved, if the entity is part of a larger group structure, and who ultimately owns the entity. All individuals owning 10 percent or more of the applicant company must be identified. If a Test House is providing facilities at several different laboratory locations, we need to understand the governance arrangements, for example who is ultimately responsible for overseeing the work at all the locations.

We need assurance that the Test House is independent from any licensed gambling operators or any other Test Houses outside of the group.

Finances

We need to understand the source of funding for the Test House and whether there are sufficient financial resources to enable the Test House to deliver testing for operators. Test Houses must be financially independent from any operators or other Test Houses.

Integrity

We need to establish the honesty and trustworthiness of the applicant and that of the people relevant to the application, which we do through a variety of external checks.

Competence

The people who are relevant to the application, in addition to the owners of the business, are those who hold the following key positions:

It may be that some of the above roles are combined but there must be someone who has responsibility for each of these areas. We need to see a management structure to understand who occupies the roles and the lines of reporting. All relevant people must sign the application form.

Criminality

We need to check the criminal record of the applicant and any people relevant to the application. Those born outside of England, Wales or Scotland, or those who have lived overseas in the last 5 years, will need to obtain certified copies of an overseas police report from their local police force, translated into English (if necessary). This is not required for those who left their country of birth as a child.

Provision

We need to understand what areas the Test House is seeking approval for and whether it has the necessary ability and resources to be able to provide these testing services to the required standards:

The Test House must have policies and procedures in place. These should cover areas such as:

There can be no outsourcing of testing to other Test Houses that are not part of the same Group.

Changes to Approved Test Houses

Any currently approved Test House wanting to make changes to their approval should contact us by emailing testhousesubmission@gamblingcommission.gov.uk requesting an application form and guidance notes.

Refusal of an Application

If we decide to refuse your application for approval as a Test House, we will let you know the reasons why. We will provide you with an opportunity to make additional representations, and supporting documentation if appropriate, before a final decision is made. There is no appeal process, but if you can resolve the issues that led to the refusal, you can resubmit an application immediately.

Documents Needed to Support a Test House Application

This is a list of documents that you will need to submit to support your application for Test House approval.

Application form

This must be fully completed and signed by all key people, as named in the application. It is not a valid application without all necessary signatures.

Accreditation

Applicants must obtain BS EN ISO/IEC 17025 certification (opens in new tab) accreditation from the United Kingdom Accreditation Service (UKAS) or an equivalent recognised international organisation. The accreditation certificate must confirm that the scope of the accreditation is sufficient to allow the Test House to test to the Gambling Commission’s standards.

Indemnity Insurance Certificate

The certificate must be in date and must name the entity that is conducting the Test House work and cover all locations where the work is conducted and all areas the Test House is seeking approval for.

Ownership structure diagram

This should clearly show:

  1. the full group structure with equity percentages
  2. all individuals owning 10 percent or more of the applicant company
  3. shares held by investment companies/investment funds, and the ultimate beneficiaries of the investment funds.

Share certificates

These must be provided for all the companies in the direct line of ownership.

Certificate of incorporation

These must be provided for all the companies in the direct line of ownership.

Management structure diagram

This must show all the key positions, as set out in the application form, and the lines of reporting.

Business plan

This should include information on the testing services that the Test House wants to provide, a commentary on the management structure and the group structure (where applicable), and details of business continuity arrangements, future plans, funding and forecasts.

Policies and procedures

These should cover anti-money laundering and how to avoid terrorist financing; the Know Your Customer checks used to establish that an operator is licensed to provide gambling facilities in the Great Britain (GB) market; back-up procedures.

Operational Model Map

This should demonstrate the process flow, from onboarding a new customer to providing them with their test certificates.

Bank statements for last 3 months

These should be for the entity that is applying for approval.

Audited accounts

These may not be available if the business has been incorporated for only a short period of time.

Management accounts

These should be provided by a new business where there are no audited accounts and by an established business where the audited accounts are more than 3 months old.

Proof of funding

The evidence required will be dependent on the source of funding. If funding is from existing profits, audited accounts, management reports and bank statements will probably be sufficient. If a loan is being used to fund the business, we want to see a copy of the loan agreement.

Profit and loss projections for next 3 years

This should include a commentary on the assumptions made in preparing the projections.

Test House information reporting

Approved Test Houses are required to report to the Gambling Commission any incident or change that could have a significant impact on the structure of their business, and their ability to deliver and uphold the testing framework.

Key events (Test Houses)

Approved Test Houses must notify us of the occurrence of any reportable changes or incidents. They must do this as soon as reasonably practicable and, in any event, within five working days of becoming aware of the event. Details of the events to be reported are set out in the list on this page.

The Test House must notify us of such changes or incidents by emailing testhousesubmission@gamblingcommission.gov.uk

Emails should be sent using the following format:

On receipt of an email relating to a reportable change or incident, we will review the information provided and we may request additional information.

Test Houses should also report changes or incidents they believe the Commission would reasonably expect to know, even if they are not specified key events. Such reports should be made in the same way as key events.

Reportable Incidents

Key event (Test Houses) 1: Winding up of companies

Description: A Test House must submit a key event report to us if it becomes aware of a petition for the winding up of a company that has a controlling interest in an approved Test House or if the entity with a controlling interest enters administration or receivership.

Guidance: Provide the reasons behind the events and a copy of the petition, if relevant. Give details of any administrators acting on the company’s behalf. Tell us if the business is continuing to trade, what information that company has provided to its customers, and who is now running the business, or if the company is looking for a buyer, if relevant.

Key event (Test Houses) 2: Changes to shareholders

Description: A Test House must submit a key event report to us if any person who (whether or not already a shareholder or member) becomes a shareholder or member holding 10 percent or more of the issued share capital of the company or its holding company.

Guidance: Provide the name, date of birth and address of any new shareholders or members with 10 percent or more of the issued share capital.

Key event (Test Houses) 3: Changes to key positions

Description: A Test House must submit a key event report to us if a person is appointed to, or a person ceases to occupy, a key position.

Guidance: A key person in a Test House includes all directors, board members or anyone with influence who hold key positions with overall authority and responsibility (including, but not limited to) CEO, COO, Head of Finance, Head of Quality Control, Head of Compliance, Technical Director, or equivalent positions. Tell us who has been appointed, or who has left their position. Provide the name, address, and date of birth of the individuals concerned, along with the data of the change. If someone has left a position and has not been replaced, explain how this position will be covered.

Key event (Test Houses) 4: Organisational changes

Description: A Test House must submit a key event report to us if there is any material change(s) in the Test House structure or the operation of its business, specifically linked to gambling related testing.

Guidance: A ‘material change’ includes (but is not limited to) acquisitions, mergers and significant restructures or redundancies. Provide details of the change and the new arrangements.

Key event (Test Houses) 5: Address changes

Description: A Test House must submit a key event report to us if it changes its Head Office or Registered address.

Guidance: Provide details of the new address and date of the change.

Key event (Test Houses) 6: Regulatory investigations

Description: A Test House must submit a key event report to us if it is subject to an investigation by a professional, statutory, regulatory, or government body into its activities which could reasonably be expected to raise doubts about the Test Houses continued suitability to test gambling products.

Guidance: Tell us the name of the professional, statutory, regulatory, or government body conducting the investigation and details of the investigation and any adverse report, penalties, fines, or sanctions imposed. You need to inform us at the outset of the investigation, when there are initial findings, and at the conclusion of the investigation. Provide copies of reports received from the investigating body. You must tell us about investigations by UK and overseas bodies, but you do not need to inform us of investigations initiated by us.

Key event (Test Houses) 7: Criminal investigations

Description: A Test House must submit a key event report to us if it is subject to a criminal investigation which may reasonably cause us to question whether the Test House’s measures to keep crime out of gambling had failed.

Guidance: Tell us the name of the investigating body and details of the investigation and any convictions, sentences, penalties, fines, or sanctions imposed. You need to inform us at the outset of the investigation, when there are initial findings, and at the conclusion of the investigation. Provide copies of reports received from the investigating body. You must tell us about investigations by UK and overseas bodies, but you do not need to inform us of investigations initiated by us.

Key event (Test Houses) 8: Loss, suspension or relinquishment of BS EN ISO/IEC 17025 accreditation

Description: A Test House must submit a key event report to us if it loses its BS EN ISO/IEC 17025 accreditation, that accreditation is suspended, or it ceases to be accredited.

Guidance: Tell us the date the accreditation was lost, suspended, or relinquished. Explain the reasons for the loss, suspension, or relinquishment of the accreditation. Identify if this change will this affect any licensees testing and, if so, have they been informed. Provide a copy of any applicable reports or correspondence (for example, notification of loss accreditation from the accreditor).

Key event (Test Houses) 9: Customer data security breach

Description: A Test House must submit a key event report to us if any security breach to its environment has an adverse effect on the confidentiality of customer data.

Guidance: Tell us the nature of the security breach, how many customers it affected and the impact or potential impact of the breach. If the breach is one which is reportable to the Information Commissioner’s Office, tell us the date you reported it to them. Further details on notifying security breaches are on our website.

Revocation of Test House approval

If the Gambling Commission has concerns about a Test Houses’ ability to meet the requirements we will investigate and potentially suspend or revoke approval. We will provide the Test House with an opportunity to explain their circumstances, and provide supporting documentation if appropriate, before a final decision is made.

The criteria which might result in suspension and/or revocation are:

References

1Examples of a person of influence include a person who is employed by the Test House in one of the key positions identified by the Commission, and an owner of the Test House.