Stakelogic BV Public Statement
Our public statements make reference to breaches of the Licence Conditions and Codes of Practice (LCCP) requirements which were in effect at the time of the breach. In some cases, the requirements have since been updated.
Operators are expected to consider the issues outlined below and review their own practices to identify and implement improvements in respect of the management of customers’ accounts.
Introduction
Licensed gambling operators have a legal duty to ensure that their gambling facilities are provided in compliance with the Gambling Act 2005 (opens in new tab)(the Act), the conditions of their licence and in accordance with the licensing objectives, which are to:
- prevent gambling from being a source of crime or disorder, being associated with crime or disorder or being used to support crime
- ensure that gambling is conducted in a fair, safe and open way
- protect children and other vulnerable people from being harmed or exploited by gambling.
Operators are expected to consider the issues outlined below and, if applicable to their licence, review their own practices to identify and implement improvements.
Stakelogic BV Executive Summary
An investigation was commenced, outside of a section 116 licence review, following the submission of a Key Event by Stakelogic BV (“the Licensee”). The Licensee reported to the Commission that one of the online slots games it offered to GB consumers was not compliant with a Responsible Product Design Remote Technical Standard (RTS) requiring there to be a minimum of 2.5 seconds from the time a game is started until the next game cycle can be commenced. The Licensee had corrected the fault by the time it had informed the Commission.
The Commission requested further information from the Licensee to ascertain the scope of the failing and the cause.
The investigation found that:
- the Licensee failed to comply with Licence Condition (LC) 2.3.1 – specifically RTS requirement 14D between 31 October 20211 and 30 October 20252
- a further 15 games were not compliant with RTS requirement 14D, however by smaller margins. The Licensee made the decision to disable all games available to the GB market as soon as the scope of the issues became clear
- the errors arose due to the Licensee’s practice of conducting timing checks with a manual stopwatch. The practice of utilising a stopwatch to measure small time intervals is open to significant inaccuracy
- the internal processes, procedures and controls fell short of the standards reasonably expected of licensees, particularly relating to quality assurance testing and internal incident management.
Based on the remedial action taken by the Licensee and in line with our Statement of Principles for Licensing and regulation, the Licensee will make a total payment in lieu of a financial penalty of £122,835.
Stakelogic BV Findings
Licence Condition 2.3.1 states:
“Licensees must comply with the Commission’s technical standards and with requirements set by the Commission relating to the timing and procedures for testing.”
The Commission’s RTS sets out the remote gambling and software technical standards under section 89 and section 97 of the Act.
Responsible Product Design RTS requirement 14D states:
“It must be a minimum of 2.5 seconds from the time a game is started until the next game cycle can be commenced. It must always be necessary to release and then depress the 'start button’ or take equivalent action to commence a game cycle.”
The Licensee confirmed that from 28 May 2025 to 30 May 2025, it made available to GB consumers through sites operated by several licensed operators, a game which did not comply with the requirements of 14D of the RTS.
Tiger Temple 88 operated with 1.97 seconds between when the game was started and the next game cycle was commenced; thereby breaching the 2.5 seconds requirement. The error was found to be the result of ineffective manual testing.
Following enquiries made by the Commission, the Licensee conducted re-testing of its entire portfolio of games offered to the GB market. This testing identified a further 15 games which were non-compliant with the requirements of 14D of the RTS.
The non-compliant games were made available to GB consumers during various periods between 31 October 2021 and 30 October 2025, with a range of between 0.001 seconds to 0.675 seconds below the minimum stated in the RTS. The majority of these games operated with a less significant timing error, when compared to the Tiger Temple 88 game. Many of the games were 42 milliseconds or below the cycle requirements. Corrective action was taken and all games were removed from the GB market while the matter was being addressed.
The Licensee accepted its processes fell short of the requirements and resulted in the failure to comply with LC 2.3.1. The Licensee has committed to making significant changes to its quality assurance testing, incident management processes, and to its wider regulatory compliance framework.
Stakelogic BV Regulatory settlement
This regulatory settlement consists of:
- a payment in lieu of a financial penalty of £122,835 (which will be directed to the consolidated fund)
- agreement to the publication of a statement of facts in relation to this case
- payment towards the Commission’s costs of investigating the case.
In considering an appropriate resolution to this investigation, the Commission has had regard to the following aggravating and mitigating factors:
Aggravating factors
- the Licensee’s decision not to suspend the Tiger Temple game upon first discovering it was non-compliant. The issue was discovered on 28 May 2025 but remained live until 30 May 2025, when a fix was deployed. If immediate action had been taken this would have minimised impact of the issue
- the timeliness of the decision to review all GB products. This action was not taken immediately when the Tiger Temple non compliant game was identified, demonstrating that the incident was managed through a limited and insufficient incident management process. As the Tiger Temple issue was the result of the use of a manual timer, it should have immediately raised concerns that this may be a wider issue if the same methodology had been used across other games
- the full scope of the issue was only determined when the Licensee began a much wider review as a result of Commission enquiries.
Mitigating factors
- the Licensee disabled all of the games available to the GB market upon understanding the scope of the issue
- the Licensee fully co-operated with the Commission’s investigation, worked openly and collaboratively with the Commission throughout, and provided information by agreed deadlines
- the Licensee accepted the failings at an appropriately early stage in the investigation.
Good practice
RTS 14D was introduced on 31 October 2021, specifically to target the risks associated with intensity of gameplay. The requirement was introduced because research showed that fast game cycle speed is associated with increased risks to the consumer.
Gambling operators should take account of the failings identified in this investigation to support wider industry learning. Operators should review their own arrangements and take remedial action where necessary, including consideration of the following:
- RTS compliance - are you fully compliant with the relevant RTS requirements?
- incident management - do you have effective incident management processes in place to ensure issues are identified, escalated and addressed in a timely manner?
- measurement of spins - what methodology is used to measure spins, and how is accuracy assured?
- testing and assurance - are testing arrangements sufficiently robust, and are appropriate checks undertaken on a regular basis?
Footnotes
1 Date RTS 14D requirement was introduced
2 Date all GB games were disabled