UK Gambling Commission has been made aware that licensees may be benefiting from affiliates advertising models which offer free-to-play versions of the real money games on their websites without the necessary accompanying age verification of users.
That’s why the Commission felt it was necessary to clarify what the latest LCCP changes on age verification entail.
The License Conditions and Codes of Practice (LCCP) represent the set of rules operators need to follow to keep their license. The LCCP is constantly changing due to the dynamic nature of the industry itself. And…
…the latest modifications done by UKGC on May 7, 2019, have to do with the age and identity verification procedures for online operators.
These new rules include:
As of May 7, 2019 operators will need to prevent any unverified customer from gambling until they have gone through the verification process.
BUT…
…apparently there has been some misunderstanding when it comes to how these new rules apply to operators’ affiliates.
LCCP Social responsibility code provision 1.1.2 states:
“Licenses are responsible for the actions of third parties with whom they contract for the provision of any aspect of the licensee's business related to the licensed activities.”
Also, that licensee's must "require the third party to conduct themselves in so far as they carry out activities on behalf of the licensee as if they were bound by the same license conditions and subject to the same codes of practice as the licensee.”
SO…
…what this means is that licensees need to ensure the new LCCP provisions on free-to-play releases are applied to gambling affiliates they employ.
This will maybe require for advertising methods to be modified but these requirements do not apply to other forms of advertising such as screenshots or videos of games that might be available on gambling affiliate websites…
…as these do not allow interaction by the customer. In these cases, there are already existing marketing and advertising rules as well as the Remote Technical Standards (RTS), 6A paragraph d.
ALSO…
…these requirements do not apply to B2B suppliers who are offering demo versions of their games in order to sell them to commercial third parties, rather than consumers.
UK Gambling Commission is advising providers to take immediate steps to ensure that their free-to-play releases cannot be accessed by children and underage people via affiliate’s websites.
Source:
“Free-to-play games being available through gambling affiliates", gamblingcommission.gov.uk, July 1, 2019.