PLEASE NOTE: THIS NEWSLETTER IS NO LONGER VALID. THE NEWSLETTER IS REPLACED BY THE DGA'S GUIDANCE ON LAND-BASED BETTING.
Change of practice regarding self-service terminals
10 June 2018
This newsletter replaces Newsletter no. 33 about betting with regard to the options of self-service terminals in shops.
The Danish Gambling Authority changes the options to provide betting via self-service terminals.
According to the new practice, betting may be provided via self-service terminals in shops where supply of betting is allowed in accordance with the rules in force if a number of conditions are met.
The background to the change
The background to the Danish Gambling Authority’s change of practice is a natural cause of the technological development in society as self-service solutions are increasingly in demand among consumers and business owners. In this connection, the Danish Gambling Authority has made a thorough assessment of the possibilities of providing betting via self-service terminals and has found it possible under certain circumstances. The supply of betting must take place in a way that is professionally sensible including not selling betting products to persons under 18.
Conditions for providing betting via self-service terminals
It is a basic condition for running a gambling business that it takes place in a way that is professionally sensible cf. the Danish Act on Gambling, section 29. In this connection, it is important that licence holders who provide betting via self-service terminals make a thorough risk assessment of how supply of betting via self-service terminals affect the considerations and obligations that follow from the Danish Act on Gambling, section 1. Businesses that provide betting via self-service terminals must therefore examine their relevant in-house procedures e.g. regarding combat of match-fixing, money laundering, and financing of terrorism, and protection of minors as well as respond to the risks that follow from their supply of betting via self-service terminals. The Danish Gambling Authority finds that supply of betting through self-service terminals puts increased demands on the way that the licence holder arranges its supply of betting in each place of sales.
The arrangement of shops in relation to self-service terminals
The Danish Gambling Authority assesses that supply of betting via self-service terminals can only take place in a professionally sensible way if the self-service terminals can be supervised by the shop staff at all times. The Danish Gambling Authority assesses that the shop staff often stay behind the cash register when customers are in the shop. Consequently, the self-service terminal must be placed in connection to the cash register and must at all times be duly supervised by the staff behind the cash register.
In practice, this, among other things, means that the staff behind the cash register must be able to assess the age of the customer who uses the self-service terminal. Moreover, the staff must be able to address the customers to ensure that the rules are complied with.
The Danish Gambling Authority assesses that the estimation of age can only be made if the terminal is placed in the same room as the shop’s primary cash register and if the staff have a clear view of self-service terminal from the cash register. In this connection, the Danish Gambling Authority assesses that the supervision must happen physically, which means that the requirement cannot be met by supervising the self-service terminal via video surveillance.
The Danish Gambling Authority also assesses that the staff behind the counter in super markets with several counters are not able to duly supervise a self-service terminal. Among other things, this must be compared to the number of customers that are normally served in these types of shops, and that the work behind the counter makes the staff unable to address themselves to customers who use the self-service terminal, if the supervision requires it.
The Danish Gambling Authority assesses that self-service terminals may be installed in super markets with several counters if the super market has an independent staffed kiosk. It is a condition that the self-service terminal is installed in the same room as the cash register of the kiosk and that the staff behind the cash register have a clear view of the self-service terminal.
What is a self-service terminal?
The Danish Gambling Authority defines any betting terminal as self-serviced if it is possible to bet without having contact with the staff of the terminal.
The Danish Gambling Authority assesses that a bet is placed when it has been paid and the betting operator has accepted the bet in question.
The means of payment is not of consequence to the assessment of whether the terminal is self-serviced. In this way, terminals that accept pre-paid vouchers instead of cash or credit cards are also considered self-service terminals although the voucher is bought from the staff. The same applies if winning tickets can be used as payment at the terminal.
A terminal at which a bet cannot be paid and therefore cannot be finally placed will not be considered a self-service terminal. This would be the case with a terminal on which the player can fill in a betting ticket electronically, print it, and pay for it at the cash register.
Which bets are included?
This change of practice only concerns the possibility to provide betting on real events that are still undetermined via self-serviced betting terminals.
The change of practice does not cause changes in connection to supply of betting on electronically simulated sport events that must still only be provided in the specially arranged betting shops. We refer you to the Danish Gambling Authority’s newsletter no. 33 about betting for a closer description of betting shops.
Existing licence holders
Existing licence holders with licence to provide betting including land-based betting will receive new licences that specifies the Danish Gambling Authority’s new practice regarding self-service terminals.