comment


Clive Hawkswood, Chief Executive of Remote Gambling Association. chawkswood@rga.e u.com


“The introduction of the new licensing regime in Denmark is due to take place in 2011 following a delay caused by a legal challenge under EU state aid rules (which restrict a state’s ability to favour an economic sector through direct or indirect financial aid) by a group of land-based gambling interests which had concerns about the lower tax rates being proposed for online gambling operators. In the longer term Denmark has every chance of becoming a successful jurisdiction for the online gambling sector. Although the market is not huge, gambling spend is relatively high per head and products such as poker already have a large following. The regime will allow nearly all products to be offered online and the tax, which is based on gross profits, should be workable. In addition the Danish authorities are in discussions with several other jurisdictions with a view to signing agreements that will hopefully reduce, for example, the need for duplication of servers and testing regimes. A large number of operators have expressed an interest in taking out licences because Denmark appears to have avoided many of the pitfalls that other EU jurisdictions, such as France, have fallen into. There is every indication that the Finance Ministry, which is responsible for the regulations, is willing to work with the industry to establish a viable regime that achieves the right balance between consumer protection and the commercial needs of the operators.”


GRoss GamBlinG Revenue


for iGaming operators at this point in time, the Danish Gambling Authority (DGA)’s technical standards are already in place, thereby facilitating a more prepared and organised effort once the market shift finally happens.


In their Technical Requirements on Gambling Operators for Obtaining a Licence to Provide Online Gambling Services in Denmark, version 1.03, the DGA spells out their requirements for future operators’ data store ‘SAFE’, security system ‘Tamper Token’, and problem gambling register ‘LUR’.


SAFE is a specialised file server system to be implemented by each operator to store their player account and game play data, in accordance with strict DGA standards, for a period of 12 months. Operators will be required to provide the DGA with online access to their SAFE data store, allowing DGA’s systems to be in constant communication with the operator’s systems. This will allow the DGA to process data and verify that online gambling is taking place in accordance with their requirements.


Tamper Token is a security system aimed at ensuring that the player account and game play data accumulated by the operator in its SAFE data store remains unchanged after it has been saved. The Tamper Token software actually resides in the DGA’s systems, and is designed to communicate with each operator’s


Up to DKK5m (approx €670,000) DKK5-10m DKK10-25m DKK25-50m DKK50-100m


DKK100m or more


SAFE data store using special keys that calculate Message Authentication Code (MAC) identification for validating data.


LUR is a register of all players in Denmark who have voluntarily requested exclusion, either temporarily or permanently, from playing online games in Denmark. The register is maintained by the DGA, and operators will be required to provide facilities on their iGaming website to allow players to register in the LUR. Prior to opening any new player account, the operator will be required to verify that the applicant is not listed in the LUR.


Finally, the DGA warns that further requirements on gambling operators will be published, including a gambling systems approval procedure.


annual licence fee peR licence


DKK50,000 (€6,700) DKK250,000 (€33,500) DKK450,000 (€60,400) DKK650,000 (€87,000) DKK850,000 (€114,000) DKK1.5m (€200,000)


In their Executive Order on Betting and Online Casinos, released 26 July 2010, the DGA spells out detailed and comprehensive requirements for player account registration and maintenance, payment systems, responsible gaming, player complaints, and internal and external auditing.


While these requirements provide a good basis for the technical regulation of iGaming in Denmark, they fall short in addressing the design aspects of the actual games themselves, as well as the Random Number Generator (RNG)s to which they will be connected. These are key elements of technical regulation that have not yet been published by the Danish Gambling Authority.


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denmaRk


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