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Strategy

Testing strategy for compliance with remote gambling and software technical standards

Requirements for the timing and procedures for the testing of remote gambling products.

2 - Approach

2.1 In deciding which aspects of the RTS will require an element of independent assurance, we considered the following:

  • the visibility of compliance - that is, how easy it is to see whether a system or game is compliant. For example, it is easy to see whether a licensee has mitigated the risk that a consumer will not understand the rules of the game by providing easily accessible information, whereas the underlying fairness of the game is more difficult to observe
  • potential impact of non-compliance.

2.2 Using these criteria, table 1 sets out the Commission’s current testing strategy with requirements divided into two categories. For those requirements identified in the final column, external testing must be assessed by an independent third party. Any categories not identified contain requirements which are capable of being tested and verified by the licensee: subject to audits in section 4.

Table 1: General risk and compliance assurance activities

General risk descriptionDetailed risk examples (not exhaustive)Relevant standardTesting required and or assurance activitiesAssessment by independent third party required
Consumers are not provided with sufficient information about their gambling activity, pertinent information about the site and or licensee's policies, and or the rules of the gambling.
  • Consumers do not understand what they are gambling on
  • Consumers are not aware of their previous gambling activity
  • Consumers are not made aware of pertinent information about the site (eg the use of automated gambling software)
  • Consumers are not made aware of the likelihood of winning
  • Consumers not easily able to keep track of their current balance.
RTS 1A, 1B, 1C, 2A, 2B, 2D, 2E, 3A, 3B, 3C, 3D, 4B 9A, 11B, 13C, 15A, 16A, 16B, 16CLicensee verifies presence of required material accompanying live* gambling products, e.g., on websites, mobile phones, or in printed material
Consumers suffer financial loss because the results of virtual games or other virtual events are not generated fairly.
  • Consumers suffer unfair financial loss because the random number generator (RNG) is not ‘random’
  • Consumers suffer unfair financial loss because scaling and or mapping components do not produce the expected (‘random’) distribution of game outcomes.
RTS 7A (including mechanical RNGs except for exempt lotteries and live dealer physical devices such as roulette wheels and decks of cards)Approved third party test house performs statistical analysis of RNG and outputs (including scaling and mapping if included within RNG), prior to release.Yes
Consumers suffer financial loss because games, progressive jackpots or virtual events contain incorrect and or malicious code components that do not operate in accordance with the published rules of the game.
  • Consumers suffer unfair financial loss because scaling and or mapping components contain incorrect/malicious code that causes the game to operate outside the published rules
  • Consumers suffer unfair financial loss because the actual RTP% is not in line with the expected value/s
  • Consumers are misled about the likelihood of winning because games display unrealistic ‘near misses’, or do not accurately reflect the probabilities of simulated real devices
  • Consumers do not understand game operation due to the game not implementing the rules
  • Progressive jackpot’s do not increment or trigger as per the rules.
RTS 7B, 7C, 7E, 9B(b) and 9B(d)

Approved third party test house examines the game (including any scaling and mapping components) via maths verification, source code analysis and game play to assess whether they operate in accordance with the rules of the virtual game or event, prior to release.

RTS 3A-C and RTS 7B: While test houses aren’t expected to assess how game rules are made available to players (rules easily accessible via hyperlinks etc), it is expected that they review the game display and content of player facing rules to see they accord with the maths and enable players to verify game outcomes.

RTS 9 Progressive Jackpots: Test houses should verify the designs and jackpot trigger functionality to ensure it is capable of delivering the stated RTP,

Yes
Consumers’ gambles are not settled in accordance with the licensee's rules, game rules and or bet rules.
  • Consumer suffers financial loss because games don’t operate in accordance with the rules.
RTS 5AIn addition to pre-release in-house and any required external testing licensees must monitor the performance of games to ensure they operate in accordance with the rules. Approved third party test house assesses performance monitoring measures in place annually. Refer to Section 5 – Live RTP Monitoring.Yes
Consumers are unfairly disadvantaged or misled by system design or functionality.
  • Betting odds fluctuate after consumer request is made
  • Consumers unfairly disadvantaged by games that are affected by network or end-user systems performance
  • Consumers do not know what rules apply because rules are changed during play
  • Progressive jackpot parameters are altered affecting RTP.
RTS 2C, 4A, 7D, 9B(a), 9B(c)Product testing must be conducted prior to release by licensee**.Internal control procedures, for example, game configuration change control, release and performance management
Consumers are able to exploit methods of cheating and collusion to disadvantage other consumers.
  • Consumers experience unfair financial losses because other consumers cheat or collude.
RTS 11AWhere technical solutions are implemented, testing must be conducted prior to release by licensee**.
Consumers are misled about the likelihood of winning due to behaviour of play-for-free games.
  • Play-for-free games do not implement the same rules as the corresponding play-for-money games.
RTS 6AProduct testing must be conducted prior to release by licensee**.
Consumers are placed at a higher risk from irresponsible gambling because responsible gambling facilities do not work correctly or are not provided.
  • Consumers who want to use some form of personal spending limit to control the amount that they gamble are unable to do so because they are not provided
  • Consumers using spending limits spend more than they intended because the limit is not properly enforced.
RTS 12A, 12B, 13A, 13BProduct testing must be conducted prior to release by licensee**.
Consumers suffer financial loss because systems are unable to adequately recover from or deal with the effects of service interruptions.
  • Consumers suffer unfair financial loss because they are unable to remove a bet offer when a betting market changes
  • Consumers suffer unfair financial loss because they are unable to complete a multi-state game due to insufficient data being appropriately stored.
RTS 10BProduct testing must be conducted prior to release by licensee**.
Consumers are treated unfairly in the event of a service interruption.
  • Consumers are unable to make an informed choice about whether to gamble on multi-state games or events, because the licensee’s policies are not published
  • Licensee’s policy is systematically unfair in the event of a service interruption, that is, always operates in the licensees favour.
RTS 10A, 10CLicensee verifies that policies are easily available and accompany live* gambling products.

Licensee verifies performance management of system availability.

Consumers placed at greater degree of risk from irresponsible gambling because products are designed to exploit or encourage problem gambling behaviour.
  • Irresponsible product design encourages consumers to gamble more than they intended or to continue gambling after they have indicated that they wish to stop
  • Consumers spend more than they intended because auto- play restrictions not in place to limit the number or value of transactions that can take place without consumer interaction.
RTS 8A, 8B, 8C, 14A, 14B, 14C, 14D, 14E, 14FWhere appropriate (eg auto-play implementation), product testing must be conducted prior to release by licensee**
Consumers suffer financial loss because the results of live dealer operations are not generated fairly.
  • Live dealer equipment contains bias or dealer procedures flawed resulting in unfair gambling provision.
RTS 17ALicensees administering live dealer operations must seek independent assurance their operation conforms to requirements. Assessment to be conducted by a gambling regulator or test house.Yes
Game integrity compromised because licensees do not implement adequate security.
  • Consumers suffer unfair financial loss because weaknesses in game security are exploited.
SecurityAnnual security audit carried out by qualified and independent third party***Yes
Consumer data or information is disclosed to unauthorised entities because system security is inadequate.
  • Confidential consumer information is disclosed to unauthorised entities leading to criminal or inappropriate use of consumer information.
SecurityAnnual security audit carried out by qualified and independent third party***Yes
Consumer information is lost due to inadequate security, backup or recovery provisions.
  • Consumers suffer unfair financial loss where the content and/or value of consumer transactions (gambles) is irrecoverably lost due to inadequate system security, backup and/or recovery provisions
  • Consumers suffer unfair financial loss where consumer account information is irrecoverably lost, for example, the current value of their deposits with the licensee, due to inadequate system security, backup and/or recovery provisions.
SecurityAnnual security audit carried out by qualified and independent third party***Yes

References

* Remote gambling products that are available to consumers. All licensees are responsible for meeting and verifying these requirements (in Green).

** Section 6 sets out the circumstances in which licensees will be permitted to carry out their own testing of gambling products.

*** Section 7 explains security auditor requirements.

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