New Italian VLT rules: more competition and more traceability
New Italian VLT rules provide considerable new obligations aimed at avoiding frauds, but also a new certification process that should enhance competition.
With some months of delay, the Italian gambling authority has finally published the new technical rules on videolotteries (VLTs) that are aimed at leading to a major upgrade of platforms and machines. The document is quite complex, but the main changes can be considered the following:
1. Certification of VLT platforms and games by testing labs
I had already discussed about this change in the past. One of the major issues with the Italian VLT market was given by the time necessary to certify platforms and machines that was taking years in some instances. This delay was de facto preventing new game suppliers from entering into the market. But the new VLT rules provide – as already prescribed for online games – that the certification can be run by testing labs accredited with AAMS, the Italian gaming authority.
The tender process to be accredited as testing lab was recently launched and this is also a good news since if the number of accredited testing labs increases also the prices for certifications should decrease, making even easier the life for game suppliers.
AAMS will shortly issue new certification guidelines to be followed by testing labs in order to certify platforms/VLTs against the new VLT decree.
2. Enhanced traceability of players
The general approach taken by the VLT decree is to collect a larger amount of information about gaming sessions in order to limit the risk of fraudulent activities. This obligation is also driven by the upcoming implementation of the 4th AML Directive that goes towards the same route, tracking gaming sessions where unusual behaviours are taken.
Such new information collected might be a good news, but it also means that game suppliers will start collecting a larger amount of personal data, just before the coming into force of the new EU General Data Protection Regulation that poses a considerable new burden on companies that need to ensure privacy compliance.
Interestingly the VLT decree refers also to responsible gambling tools such as the notification to players if they exceed the limit of time and amount spent at the machine. This is something that is already in place in other jurisdictions and might be a valuable improvement.
3. Cross-ticketing still with the same licensee
The VLT rules provide for the possibility to use the same ticket with VLTs of different game suppliers of the same license holders, but do not allow to use it with VLTs of different licensees. The reason of such restriction might be also that it could lead to accounting issues from different license holders.
However, it would be interesting to see whether in the future they will consider to introduce jackpots accumulating funds from different license holders which is not currently prescribed by the regulations.
Due to the very large number of changes to be implemented, AAMS granted a transitional period up to 1 April 2019 to ensure that platforms and VLTs are made compliant with the new VLT decree. It will be interesting to see the impact of these regulations on the market.
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WRITTEN BY GIULIO CORAGGIO
IT, gaming, privacy and commercial lawyer at the leading law firm DLA Piper. You can contact me via email at firstname.lastname@example.org or email@example.com or via phone at +39 334 688 1147.