What are ‘Return To Player’ statistics?
The UK Gambling Commission (the “Commission”) has a primary objective to ensure that gambling is conducted in a ‘fair and open way’. With respect to remote games, a recent addition to this remit focuses on monitoring Return To Player (RTP) values.
The RTP value is a statistical measurement of how much of the total amount of stakes wagered on a game are returned to the player in the form of payouts. This value is usually expressed as a percentage. For example, a game advertising a 98% RTP value would return 98% of the total amount wagered over a period of time, with the remaining 2% being the margin which is retained by the gaming operator.
It is important to note that the % RTP is an average achieved over a significant number of game plays and not each time the gaming machine is played, and therefore the % RTP value can be volatile over short periods of time. For this reason, RTP is usually measured over thousands of game plays.
What is the ‘live monitoring’ obligation with respect to RTP?
In September 2016, the Commission defined a new technical standard which affects operators offering ‘random number’ driven products such as slots games, as well as products such as bingo, peer-to-peer poker, blackjack and virtual sports.
The technical standard mandates that operators must include procedures for ‘live monitoring’ of RTP products to ensure that games are operating fairly as designed and advertised. This means that operators must develop technical processes to review recorded game payouts in order to ensure that the RTP remains close to the advertised % RTP value. Furthermore, the monitoring must be based on the popularity of a game, so for example, it would not be acceptable to monitor a popular game once per month: the monitoring should be performed on an ongoing ‘regular’ basis. The Commission suggests a daily rolling review of the preceding 30 days.
The live monitoring obligation is in addition to the ‘annual games testing audit’ which operators are required to undertake.
Why is live monitoring important?
The Commission has noted that ‘Consumers are concerned with the fairness of games and often game faults are identified as a result of their complaints’. Specifically, if modifications are made to game software, then it is possible that an error could be introduced which would affect RTP. Such errors could only be detected via live monitoring of the game itself. Furthermore, errors could be introduced in a particular game version only (e.g. Flash, mobile), which highlights the importance of rigorous testing covering all deployment platforms.
What action do operators need to take?
If an operator is offering games which are modified in-house, then they must have appropriate live monitoring in place for RTP. These processes will be checked during an annual audit. If a game is identified as having RTP values which fall outside of the published RTP for the game, then details must be submitted to the Commission.
Operators must keep appropriate records as evidence that testing has taken place, as well as more detailed investigations which have taken place as the result of an alert or customer complaint. Operators must ensure that consumers can be provided with clear, detailed explanations of how their individual performance compares with the game’s expected behaviour.
If an operator licenses games from a third-party B2B provider, then it may be that the B2B is responsible for the live monitoring of the games. This arrangement needs to be clear between both parties and appropriate contracts need to be in place to define which party is responsible for live monitoring.
Live performance monitoring of RTP has been a recent inclusion in the Commission’s formal testing strategy, and operators must be aware of the obligations in order to remain compliant. Operators should look to include live RTP monitoring as part of daily automated operations, and to ensure that this information is readily available should it be required by either the Commission or consumers.
About the author
Matt Hegarty is the director of Bellaport Systems, a UK-based software company which develops software to help businesses with legal compliance. Matt has previously led technical teams developing software for compliance with gambling regulations. For more information, please contact Matt Hegarty directly: firstname.lastname@example.org