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Guidance

Guidance to licensing authorities

The Gambling Commission's guidance for licensing authorities.

Published
1 April 2021

Last updated
27 January 2021 - Changes

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Contents

RTS 16 – Use of third party software

Applies to:

Peer-to-peer gambling

RTS aim 16

To make customers in peer-to-peer gambling aware that they may be gambling against a software program (designed to automatically participate in gambling within certain parameters, sometimes referred to as a bot), or a human aided by third party software.

RTS requirement 16A

Where peer-to-peer customers may be gambling against programs deployed by other customers to play on their behalf, or customers assisted by third party software, information should be made available that describes that this is possible, and if it is against the operator’s terms and conditions, how to report suspected use.

RTS implementation guidance 16A

  1. The warning and information about how to complain should be included in game descriptions, rules, terms and conditions, ‘help’, ‘how to play’ or other general product information pages.
  2. The warning should also inform customers that if they use a program to gamble on their behalf, other customers may be able to exploit it.

RTS requirement 16B

Operators must make it clear to players whether the use of third party software is permitted and if so which types. Operators that prohibit certain types of third party software must implement measures intended to deter, prevent, and detect their use.

RTS implementation guidance 16B

Clear, accessible information about the types of software that are permitted or prohibited should be included within terms and conditions and the players guide3 , as a minimum. This does not have to be an extensive list but could be a description of the key features of the software.

RTS requirement 16C

Where operators use programs to participate in gambling on their behalf in peer-to-peer gambling, easily accessible information must be displayed, which clearly informs customers that the operator uses this kind of software.

RTS implementation guidance 16C

  1. Peer-to-peer gambling operators that use software to gamble on their behalf (for example, poker robots) should display a notice to customers on the home pages or screens and in the game description, ‘help’ or ‘how to play/bet’ pages or screens.
  2. As a minimum, restricted display devices should provide a link to further information on gambling pages/screens or in ‘help’, ‘about’ or ‘how to bet/play’ pages or screens.

References

3LCCP Social responsibility code 4.2.3

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