Testing strategy for compliance with remote gambling and software technical standards
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.
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 description||Detailed risk examples (not exhaustive)||Relevant standard||Testing required and or assurance activities||Assessment 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.||RTS 1A, 1B, 1C, 2A, 2B, 2D, 2E, 3A, 3B, 3C, 3D, 4B 9A, 11B, 13C, 15A, 16A, 16B, 16C||Licensee 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.||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.||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,
|Consumers’ gambles are not settled in accordance with the licensee's rules, game rules and or bet rules.||RTS 5A||In 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.||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.||RTS 11A||Where 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.||RTS 6A||Product 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.||RTS 12A, 12B, 13A, 13B||Product 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.||RTS 10B||Product testing must be conducted prior to release by licensee**.|
|Consumers are treated unfairly in the event of a service interruption.||RTS 10A, 10C||Licensee 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.||RTS 8A, 8B, 8C, 14A, 14B, 14C, 14D, 14E, 14F||Where 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.||RTS 17A||Licensees 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.||Security||Annual 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.||Security||Annual security audit carried out by qualified and independent third party***||Yes|
|Consumer information is lost due to inadequate security, backup or recovery provisions.||Security||Annual security audit carried out by qualified and independent third party***||Yes|
* 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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Testing strategy for compliance with remote gambling and software technical standards - Procedure for testing
Last updated: 7 April 2022
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