- Joined
- May 22, 2012
This affects affiliates so I could've put it there but it probably affects more players than affiliates overall, so some answers in case you're wondering.
A pal of mine asked the UKGC whether demos could still be made available by developers direct to interested parties (yes, privately) and the status of demo games on affiliate or other websites NOT provided or operated by license holders, i.e. the casinos or developers:
Thank you for your further correspondence.
I understand that you would like further clarification on how the new regulations coming in to force will impact your affiliate site offering free to play versions of games.
I would firstly like to apologise as, after receiving further clarification, I have found that the information provided in my initial response was incorrect. I’m sorry for any confusion or delay this may have caused.
I can confirm that the new LCCP requirement ultimately only applies to B2C operators offering free-to-play games to customers on their own websites. Our main driver for requiring operators to verify age before allowing customers to access any free-to-play games is that, in the context of those games being available on the operator’s own website, customers are directly exposed to the real-money gambling opportunities that those free-to-play games are advertising.
In contrast, customers are not able to access the real money version of a game on an affiliate website. They key thing is that, if a customer accesses a game on an affiliate website, they must be fully age verified before they can access the product (free play or real money) or deposit money on the operator’s website.
The LCCP only applies to licensed operators and not affiliates, as such the latter are not expected to conduct age verification. However, it is worth noting the following:
Licensees who choose to use marketing affiliates to promote their products must comply with relevant LCCP relating to the licensee’s responsibility for third parties and the promotion of its business by agents.
One matter that licensees will want to assure themselves of is, for any customer who accesses a free-to-play game via an affiliate website, does that customer ‘play’ the game on the affiliate’s website itself or are they redirected to the licensee’s website? If the free-to-play version of the game being advertised on the affiliate site is hosteddirectly by the relevant licensee on their own platform, that licensee would be required to verify the age of any person before they can “access any free-to-play versions of gambling games that the licensee may make available” (in order to comply with the new LCCP code provision).
By “free-to-play games” we mean versions of gambling games with which a player interacts e.g. by pressing a start button to spin the reels – in other words, the customer can ‘play’ the game albeit there is no stake or prize involved. Free-to-play games are described in more detail at RTS 6 of our Remote Gambling and Software Technical Standards (
The new requirements do not include demo products which, while they may involve moving images to show how the game operates, do not involve any element of interaction or ‘playing’ the demo. However, demo products are very likely to be construed as marketing communications and operators will therefore need to ensure that they comply with the UK Advertising Codes and our LCCP in that regard. In particular, demos must not be directed at u18s or feature content of particular appeal to them.
Apologies again for any confusion caused by the initial response, I hope you have found this advice useful.
A pal of mine asked the UKGC whether demos could still be made available by developers direct to interested parties (yes, privately) and the status of demo games on affiliate or other websites NOT provided or operated by license holders, i.e. the casinos or developers:
Thank you for your further correspondence.
I understand that you would like further clarification on how the new regulations coming in to force will impact your affiliate site offering free to play versions of games.
I would firstly like to apologise as, after receiving further clarification, I have found that the information provided in my initial response was incorrect. I’m sorry for any confusion or delay this may have caused.
I can confirm that the new LCCP requirement ultimately only applies to B2C operators offering free-to-play games to customers on their own websites. Our main driver for requiring operators to verify age before allowing customers to access any free-to-play games is that, in the context of those games being available on the operator’s own website, customers are directly exposed to the real-money gambling opportunities that those free-to-play games are advertising.
In contrast, customers are not able to access the real money version of a game on an affiliate website. They key thing is that, if a customer accesses a game on an affiliate website, they must be fully age verified before they can access the product (free play or real money) or deposit money on the operator’s website.
The LCCP only applies to licensed operators and not affiliates, as such the latter are not expected to conduct age verification. However, it is worth noting the following:
Licensees who choose to use marketing affiliates to promote their products must comply with relevant LCCP relating to the licensee’s responsibility for third parties and the promotion of its business by agents.
One matter that licensees will want to assure themselves of is, for any customer who accesses a free-to-play game via an affiliate website, does that customer ‘play’ the game on the affiliate’s website itself or are they redirected to the licensee’s website? If the free-to-play version of the game being advertised on the affiliate site is hosteddirectly by the relevant licensee on their own platform, that licensee would be required to verify the age of any person before they can “access any free-to-play versions of gambling games that the licensee may make available” (in order to comply with the new LCCP code provision).
By “free-to-play games” we mean versions of gambling games with which a player interacts e.g. by pressing a start button to spin the reels – in other words, the customer can ‘play’ the game albeit there is no stake or prize involved. Free-to-play games are described in more detail at RTS 6 of our Remote Gambling and Software Technical Standards (
You do not have permission to view link
Log in or register now.
. The new requirements do not include demo products which, while they may involve moving images to show how the game operates, do not involve any element of interaction or ‘playing’ the demo. However, demo products are very likely to be construed as marketing communications and operators will therefore need to ensure that they comply with the UK Advertising Codes and our LCCP in that regard. In particular, demos must not be directed at u18s or feature content of particular appeal to them.
Apologies again for any confusion caused by the initial response, I hope you have found this advice useful.