Tips The UKGC and Demo slots and games - official reply!

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dunover

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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 (
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.


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.
 

mack341

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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 (
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.
Has this cleared things up :laugh: seems an awful lot of text for an answer to a simple question...
 

Jono777

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Hopefully this fits here also.....

Just had a whopping 5 emails back to back in my inbox asking for ID verification documents from sites I have been with years! (Don't use any of them currently)

Looks like 7th May deadline has encouraged these requests and the new "Do's and Don'ts" are well and truly on their way.....
 

goatwack

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Hopefully this fits here also.....

Just had a whopping 5 emails back to back in my inbox asking for ID verification documents from sites I have been with years! (Don't use any of them currently)

Looks like 7th May deadline has encouraged these requests and the new "Do's and Don'ts" are well and truly on their way.....
Got the same, and I don't even play there! Guess it's a thing now

KABOO.jpg
 

brianmon

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Hopefully this fits here also.....

Just had a whopping 5 emails back to back in my inbox asking for ID verification documents from sites I have been with years! (Don't use any of them currently)

Looks like 7th May deadline has encouraged these requests and the new "Do's and Don'ts" are well and truly on their way.....
Was Kaboo one of them, by any chance?
I got this today...

HI BRIAN, ACCOUNT TEMPORARILY DISABLED!
We’re writing to let you know that we were unable to verify your account in the 72 hours since your first successful deposit, your account has now been temporarily closed due to UK Regulatory requirements.

72 hours??? more like 72 months since my first deposit, and I'm pretty sure I've previously been verified and made withdrawals
 

Jono777

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Yes mate, identical email and identical thoughts!

One of the handful which did surprise me was Betfred. Always thought these 'bookies' type sites did electronic checks.
 

Slottery

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That 72 hours have been there for years. Many operators made it through automated checks through official registers and that was enough, maybe they now have changed their minds/terms and that you actually have to provide physical document instead of these automated checks? No idea, just guessing, UKGC is bit hard to follow at least for me when try to comply with their regulations and not to overdo it and ruin player experience....
 

Jono777

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That 72 hours have been there for years. Many operators made it through automated checks through official registers and that was enough, maybe they now have changed their minds/terms and that you actually have to provide physical document instead of these automated checks? No idea, just guessing, UKGC is bit hard to follow at least for me when try to comply with their regulations and not to overdo it and ruin player experience....
That has to be the understatement of the millennium lol, think they've had even the most knowledgeable with their heads in a spin :p
 

Slottery

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That has to be the understatement of the millennium lol, think they've had even the most knowledgeable with their heads in a spin :p
I try to be polite as possible, still have to try to survive with them and they're not making it 100% clear and easy to understand what they actually want to be done and give clear practices all would have to follow. It is what it is, that's probably one commission who made me start my daily morning yoga, just to stay calm and that i can say them big thanks :)
 

dunover

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Yep - I'm glad I came across this thread as I got the same e-mail too as pasted in above. Had me worried, I thought some twat had opened an account with my details, then thought how the hell could they have deposited in my name? Then I realized it was likely a blanket e-mail, someone's messed up there and a few people who haven't deposited will be panicking now. Numpties.
 

mack341

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Yep - I'm glad I came across this thread as I got the same e-mail too as pasted in above. Had me worried, I thought some twat had opened an account with my details, then thought how the hell could they have deposited in my name? Then I realized it was likely a blanket e-mail, someone's messed up there and a few people who haven't deposited will be panicking now. Numpties.
Dunover, I thought that ukgc reply might bamboozle you, you created the thread :p :thumbsup:
 
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goatwack

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In my case I was mightily pertubed by the threat of Kaboo keeping my account temporarily closed.........indefinitely :eek2:
 

dunover

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Dunover, I thought that ukgc reply might bamboozle you, you created the thread :p :thumbsup:

Yes LOL... I should've said 'I'm glad I saw those Kaboo replies as they answered a question for me'.

Slight derail but useful in this instance.
 

EkJR

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I have to laugh at certain operators asking for this now. It clearly shows they did fuck all during the 72 hours from signup previously which was indeed part of their LCCP. I have backed up and evidenced facts that at least 7 operators in the UK also do not look at first name or date of birth in their automatic verification checks which is quite frankly astonishing. They only check the voters roll to confirm someone is perhaps over 18...no further check.

Personally I think the 7th of May will be a complete shambles. Many will ask for ID despite already having so called auto verification because they did not properly verify the players previously!
 

dunover

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Received today from Rolla:

Dear Partner,

Firstly, thank you for choosing to work with Rolla.

We would just like to take this opportunity to remind you that since the recent LCCP changes came into play for the UK market, you are no longer permitted to offer play for fun games on your websites to any players from the UK, who have not been age verified.

As such we kindly ask you to review your websites that are promoting Rolla, to ensure that any players from the UK, do not have the possibility to play any games in play for fun mode, if not age verified. In the event that this does not happen, we may be forced to close your account.

Should you have any concerns or questions, please do not hesitate to reach out to your Account Manager or contact us.

Best Regards,
Rolla Casino
 

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