Guidance on new types of games

Here you can find more information on how, as a licence holder, you can assess whether a game type may be offered legally

The Danish Gambling Authority regularly receives enquiries from licence holders and game providers who wish to introduce a new game type to the Danish market.

It is important to emphasise that the Danish Gambling Authority cannot pre‑approve games. We can only provide guidance on our interpretation of the rules and on the characteristics of a given game type. It is always the responsibility of the licence holder to assess whether a game may be offered within the scope of the relevant licence(s).

The Danish Gambling Authority continuously supervises the gambling market in Denmark. If we identify games that are considered to fall outside the scope of a licence, the licence holder and the provider will receive a consultation.

Technical assessments in the Game Portal

When a game is uploaded to the Danish Gambling Authority’s game portal, only a technical assessment is carried out to determine whether the game complies with the applicable requirements. As a general rule, no legal assessment is made of whether the game may be offered lawfully in Denmark.

The purpose of the game portal is to ensure that all games comply with the technical requirements set out in SCP.07 Requirements for Games in the certification programme for betting and online casino.

Even if a game can be tested and inspected within a specific game category, this does not necessarily mean that the game may be offered on the Danish market. Licence holders should therefore always ensure that a separate legal assessment of the game type is carried out.

Licence holders should also contact the Danish Gambling Authority if they are uncertain about how data for a given game must be reported.

Combination games

Licence holders with an online casino licence may offer combination games — games in which the chance of winning depends on a combination of skill and chance.

It is the responsibility of the licence holder and the provider to assess whether a game falls within this category. The Danish Gambling Authority’s view is that the skill element must not be illusory.

An example of a game type where we have seen versions that may be categorised as combination games is Slingo. In these versions, the skill element is considered sufficient because the player must place “wilds” strategically on the game board. It is essential that this choice is a mandatory part of the game in order to constitute a genuine skill element.