Ensuring Game Integrity and Player Awareness

The overall intent of this theme is to ensure that gaming in Ontario is conducted with honesty and integrity and that players have sufficient information to make informed decisions prior to gaming. 

The identified regulatory risks under this theme are:

  • Inability to regulate all components. 
  • Related parties winning at a higher relative percentage than the public. 
  • Players have insufficient information to make an informed choice. 
  • Game and system lack integrity. 
  • Game procedures not followed. 
  • Game and systems fail. 
  • Potential compromising of betting markets through activities such as insider betting or game manipulation.

Game Integrity

4.01 All gaming activities and financial transactions shall be conducted fairly and honestly, and must be independently verifiable. (Also applicable to Gaming-Related Suppliers)

Requirements – At a minimum:

  1. Continuous independent monitoring and recording of lottery schemes and cash (and cash equivalent) handling must be in place to support the verification of:
    1. Adherence to required game rules by players and employees or, in sport and event betting, the processing and redemption, if any, of the bet fairly, honestly and in accordance with the terms of the bet placed by the player, including applicable betting rules;
    2. Confirmation of outcomes of lottery schemes;
    3. Prize payment to the proper person;
    4. Accuracy of financial transactions.
  2. Continuous logs shall be maintained for critical gaming systems including to track financial accounting and game state history.

4.02 There shall be appropriate, accurate and complete records of transaction and game state and play information kept and made available for the purposes of (Also applicable to Gaming-Related Suppliers):

  1. Ensuring timely investigations can be performed by the Registrar.
  2. Capturing information needed to continue a partially complete game within a reasonably defined time.
  3. Resolving disputes in a fair and timely manner.
  4. Ensuring player complaints can be resolved.
  5. Tracking all relevant player information (including funds information).
  6. Tracking all relevant individual gaming sessions and game play information.
  7. Tracking all relevant information related to events (including significant events).
  8. Tracking of game enabling, disabling and configuration changes.

Guidance: There should be an adequate amount of storage, capacity and retention of logged information. The appropriate capacity, design and monitoring of the logging facilities should be in place to ensure that logging is not interrupted for a technical reason that could have been prevented.

4.03 There shall be a mechanism in place to ensure that if logging is interrupted, compensating manual controls are used, where reasonable. (Also applicable to Gaming-Related Suppliers)

4.04 The gaming system shall be capable of providing custom and on-demand reports to the Registrar.  (Also applicable to Gaming-Related Suppliers)

Guidance: the intent is to ensure that the Registrar can receive information in an appropriate format when necessary. Examples are: a list of all games hosted by the website, or a list of all active player accounts.

4.05 Game specifications must be documented that clearly indicate (Also applicable to Gaming-Related Suppliers):

  1. The objectives of the game;
  2. The wagers that may be made;
  3. How the game is operated and played;
  4. Odds of winning for each prize available to players;
  5. The advantage of the operator in relation to each wager.

4.06 Prior to placing a bet or wager, the player shall be provided with sufficient information to make informed decisions about betting or wagering based on chances of winning, the way the game is played, and how prizes and payouts are made. (Also applicable to Gaming-Related Suppliers)

Requirements – At a minimum:

  1. Comprehensive and accurate information that explains the applicable terms governing play must be easily available to the player prior to the placing of a bet or wager through such supports as “game rules”, “help” or “how to play” pages placed prominently to allow players to easily locate them.  All reasonable steps must be taken to ensure the content is understandable.
  2. The explanatory content shall:
    1. indicate the methods of how players may participate in the game and provide instructions and any terms for each of these methods,
    2. provide clear instructions on how to interact with the game,
    3. provide clear descriptions of what constitutes a winning outcome,
    4. indicate any restrictions on play or betting (e.g., play duration limits, maximum wins),
    5. contain comprehensive, accurate and understandable information on the odds of winning, payout odds, or returns to players,
    6. indicate prize value units (e.g., currency or credits),
    7. provide any other information on elements that will affect play (e.g., the number of decks or frequency of shuffles in virtual card games, the method of in-game betting) or results (e.g., how progressive jackpots work, number and kind of tokens to be collected to enter a bonus round,  the rules and behaviour in a bonus round, how the results of pool betting in sport and event betting work, the procedures for confirming the results),
    8. contain the same information and be consistent across all languages it is provided in.
  3. If certain outcomes, prizes or features are only available under limited circumstances, the explanatory content must clearly indicate what these circumstances are.
  4. Where speed of interaction has an effect on the player’s chances of winning, players must be informed that the speed of connection or processor may have an effect on the game.
  5. Where player skill and/or strategy has an impact on the player’s chances of winning, players must be informed that their skill and/or strategy will have an impact on their chances of winning.
  6. For all peer-to-peer games, players must be informed of possible communication loss and the impact to the player in such an event.  
  7. The denomination of each credit shall be clearly displayed.
  8. The units of displayed prizes and payouts (e.g. denominational units, currency) must be clear.
  9. Cash out options and how to redeem winning bets in sport and event betting.

  10. Players shall be provided with information that indicates circumstances in which a game can be declared void.

4.07 Information provided to players prior to and during game play shall not mislead players or misrepresent games. (Also applicable to Gaming-Related Suppliers)

Requirements – At a minimum, information shall not:

  1. Describe any outcomes, prizes, or features that are not achievable. 
  2. Encourage play as a means of recovering past gambling or other financial losses.
  3. Be designed so as to make false promises or present winning as the probable outcome.
  4. Imply that chances of winning increase:
             a. The longer one plays;
             b. The more one spends; or
             c. Suggest that skill can influence the outcome (for games where skill is not a factor);
  5. Use language that suggests the probability of a particular outcome is more likely to occur than its actual probability.  Examples include the use of the terms, “due”, “overdue”, “ready”, and “ready to hit”. 
  6.  Mischaracterize the nature of the game by giving it a commonly accepted name, such as “European Roulette”, if the game does not operate as a player would reasonably expect.

4.08 All igaming games, random number generators and components of igaming systems that accept, process, determine outcome of, display, and log details about player bets, including any subsequent modifications, must either be approved by the Registrar or certified by an independent testing laboratory registered by the Registrar, as per the AGCO’s ITL Certification Policy, prior to being provided for any gaming site. [Amended: April, 2023]

Guidance: For greater certainty, this Standard applies to gaming equipment used in Live Dealer games that contains electronic components. 

4.09 Gaming systems and gaming supplies shall be provided, installed, configured, maintained, repaired, stored, and operated in a way that ensures the integrity, safety and security of the gaming supplies and systems. (Also applicable to Gaming-Related Suppliers) [Amended: October, 2022]

Requirements – At a minimum:

  1. Only games and remote gaming servers approved by the Registrar or certified by an independent testing laboratory registered by the Registrar shall be used on the gaming site.
  2. The Registrar shall be immediately notified where there is any problem with the integrity or security of the gaming system or gaming supplies.
  3. Monitoring and testing shall be performed throughout the life of the gaming system and gaming supplies to ensure they are operating as approved.
  4. In the event of any suspected integrity or security problem with a gaming system or gaming supply, logs of the current state of the gaming system and gaming supply, and any supportive evidence shall be preserved.
  5. Operators shall monitor the payback of their live games to detect any behaviour that may indicate faulty performance.
  6. Gaming suppliers shall take immediate action, conduct timely investigations, and make any necessary corrections when there is a problem with the integrity or security of gaming systems.

4.10 Where there are suspected game or system faults that may impact game integrity or fairness including the integrity or fairness of sport and event betting (e.g., influencing a player’s chances of winning or the return to players), Operators shall make the game unavailable to players until the issue has been resolved. In the case of sport and event betting, making a game unavailable may include the suspension of betting, the withholding of funds, and the refund of any bet until a gaming system fault has been resolved. Operator decisions must be fair, reasonable, and made in good faith.

4.11 Production, testing and development systems shall be logically separated. (Also applicable to Gaming-Related Suppliers)

4.12 Game outcomes and sport and event betting transactions shall be recoverable, where technically possible, so that player bets can be settled appropriately. (Also applicable to Gaming-Related Suppliers)

4.13 In any case where there is a game or system fault, including where game outcomes or sport and event betting transactions are not recoverable, the Operator shall have clearly defined policies and processes in respect of treating the player fairly when resolving the player’s transactions. These policies and processes shall be made available to players. (Also applicable to Gaming-Related Suppliers)

4.14 Mechanisms shall be in place to allow a game to be recreated up to and including the last communicated state to the player. (Also applicable to Gaming-Related Suppliers)

Requirements – At a minimum:

  1. Selected electronic game elements and game outcomes shall be logged before they are displayed to the player.
  2. Information shall be captured that is needed to continue a partially complete game within a reasonable period of time.

4.15 A player’s bet and the outcome of the game shall be clearly displayed, easy to understand, and available for a sufficient length of time for the player to review. (Also applicable to Gaming-Related Suppliers)

4.16 Games shall pay out accurately, completely and within a reasonable time of winning, subject to checks and verifications. (Also applicable to Gaming-Related Suppliers)

Collusion and Cheating

4.17 Operators shall have mechanisms in place to appropriately deter, prevent and detect collusion and cheating.

4.18 All relevant activities related to the detection of collusion and cheating shall be logged.

4.19 Players shall be provided with clear information on the process to report activities related to collusion and cheating, including the suspected use of bots. The process must be simple to use and readily accessible to a player seeking to make a report.

Requirements – At a minimum:

  1. Complaints by players about unfair treatment, cheating and collusion must be investigated.
  2. Information about the Operator’s policies and procedures to deter, prevent and detect unfair behaviour, cheating and collusion, including the suspension or disabling or accounts and any recovery of funds, must be made available to the public on request. 
  3. Where an investigation, whether initiated by the Operator or as a result of a player complaint, results in the suspension or disabling of a player account, records of the investigation identifying the activities, the reason for the investigation (including whether it was initiated as the result of a player complaint) and any relevant evidence should be retained in accordance with Standard 1.09. 
  4. The Registrar shall be informed, in accordance with the notification matrix, of any incident that an Operator reasonably believes constitutes an incident of intentional cheating while playing a lottery scheme.

Speed and Interruption

4.20 Where speed of interaction has an effect on the player’s chances of winning, the Operator shall take reasonable steps to ensure the player is not unfairly disadvantaged due to gaming system related performance issues.

4.21 Service interruptions shall be responded to and dealt with in a way that does not disadvantage players. (Also applicable to Gaming-Related Suppliers)

Requirements – At a minimum, the gaming system shall:

  1. Inform players that the speed of connection or processor may have, or appear to have, an effect on the game;
  2. Recover from failures that cause interruptions to the game in a timely fashion;
  3. Where appropriate, void bets;
  4. Retain sufficient information to be able to restore events to their pre-failure state, if possible;
  5. Pay players the amount won up to that point, or return bets to players where a game cannot be continued after a service interruption, whichever is the better outcome for the player.

Peer-to-Peer Games

4.22 In peer-to-peer games, Operators must implement measures intended to deter, prevent and detect the use by players of software programs to automatically participate in game play (referred to as a bot) or to provide the player with an unfair advantage over other players.

Requirements – At a minimum:

  1. Operators must clearly provide notice to players of peer-to-peer games that the use of such software is not permitted and, if a player is found to have used such software, it will be considered to be cheating and the player may be sanctioned by the Operator accordingly.

4.23 Games must be conducted in a manner that ensures players are treated fairly and not unfairly disadvantaged by other players. (Also applicable to Gaming-Related Suppliers)

Requirements – At a minimum:

  1. Measures intended to deter, prevent, and detect unfair behaviour, collusion and cheating, including the suspected use of bots, must be implemented.
  2. Information regarding specific game elements (such as a player’s hand or cards) shall not be accessible to give advantage to any player during games, unless by the player themselves.
  3. A mechanism shall be in place to ensure that a player cannot play against themselves or occupy more than one seat at an individual table.
  4. Gaming systems must retain a record of relevant activities to facilitate investigation and be capable of suspending or disabling player accounts and player sessions.
  5. Operators must monitor the effectiveness of their policies and procedures.
  6. As a minimum deterrent, players must be informed that accounts may be closed if the player has cheated, colluded or acted unfairly towards another player.

Determination of Game Outcomes

4.24 Games must operate according to their game specifications and the outcomes must be determined in accordance with the terms governing play and prevailing payouts as they are described to the player. Sport and event betting must be conducted fairly, honestly and in accordance with the terms of the bet placed by the player. (Also applicable to Gaming-Related Suppliers)

Requirements – At a minimum:

  1. All possible game outcomes (winning and losing outcomes) shall be available in each play, unless clearly explained to the player.
  2. The probability of game outcomes in virtual games shall be the same as in the associated live game (e.g., card games), unless the differences are set out in the terms governing play and communicated to players.
  3. The probability of achieving a specific game outcome shall be constant and independent of game history, player or any other factor, unless clearly explained in the terms governing play. Where the game outcome is intended to be random (e.g., dice games or slot games), the outcome must not be dependent or based upon any history or other factors.
  4. Sport and event bets shall be accepted, processed, and settled in accordance with the terms of the bet placed by the player, including any applicable betting rules.

4.25 Bets shall be committed before the determination of game outcomes.  Any wager received after the determination of game outcomes associated with the wager shall be voided and returned to the player. (Also applicable to Gaming-Related Suppliers)

4.25.1 In sport and event betting, bets must be settled fairly and in accordance with the terms of the bet placed by the player and any applicable betting rules that were available to the player when the bet was placed.  Where raised, the reasons for the settlement must be clearly and promptly provided to the player. (Also applicable to Gaming-Related Suppliers)

4.25.2 The results of bets on sporting or other events must be provided to players making bets on the events. Any change of results must be made available.  Account balances will be updated as the results of wagers are confirmed. (Also applicable to Gaming-Related Suppliers)

4.25.3 Sport and event betting operators shall have controls in place to ensure the accuracy and timeliness of sport and event results data. (Also applicable to Gaming-Related Suppliers)

Randomness of Game Outcomes

4.26 A mechanism shall be in place to randomly select game elements used to determine game outcomes. This Standard does not apply to sport and event betting products.(Also applicable to Gaming-Related Suppliers)

Requirements – At a minimum:

  1. Initial values and conditions shall be selected and used to seed the random selection process in a way that ensures the randomness of the resulting game outcomes and avoids any correlation of selected game elements with elements selected by any other instances of the mechanism.
  2. The selected game elements and their associated game outcomes shall not be influenced, affected or controlled by the amount wagered, or by the style or method of play unless the conditions are changed and are disclosed clearly to the player.
  3. The mechanism used to select game elements and their associated game outcomes shall be impervious to outside influences (such as electro-magnetic interference, devices within or external to the gaming system; the characteristics of the communication channel between the system and the end player device, the player or the Operator) and its components shall not be subject to deterioration that impacts, before any scheduled replacement lifecycle, the randomness of selection.
  4. The selected game elements and their associated game outcomes shall not be altered, discarded or otherwise manipulated through a secondary decision by the game program and shall not be impacted by load on the gaming system.
  5. Any failure by the mechanism to randomly select game elements, including an interruption in the selection process, must be identified and responded to quickly and appropriately to minimize the effect on players. 

4.27 Mechanisms used to select game elements and their associated game outcome must be capable of being monitored and inspected to ensure the integrity of the mechanisms and its component devices and the randomness of the generated outcomes. This Standard does not apply to sport and event betting products. (Also applicable to Gaming-Related Suppliers)

Game Management

4.28 Terms governing play must not be changed during a game session unless the player is made aware of the change before the player places any wagers in the game. (Also applicable to Gaming-Related Suppliers)

Requirements – At a minimum:

  1. Where applicable, game interface changes made by the player shall be appropriately limited by the gaming system to ensure that information and representation of the game remains fair and accurate and in accordance with the terms governing play.
  2. Information on the current state of multi-state games must be clearly displayed,
  3. Displays of jackpot amounts that change over time should be updated as frequently as practicable and particularly after the amount has been reset after a win.
  4. Odds in sport and event betting sometimes change prior to or during an event. Changes in odds must be updated and publicly available to all players. This is not intended to entitle a player who has previously placed a bet to receive new odds on that bet.

4.29 Game sessions must be appropriately secured and checked for authenticity. (Also applicable to Gaming-Related Suppliers)

4.30 There shall be a player activity time-out that automatically logs the player out or ends the player’s session after a specified period of inactivity. (Also applicable to Gaming-Related Suppliers)

Downloadable Game Content

4.31 All critical functions, including the generation of the outcome of any game, shall be generated by the gaming system, independent of the end player device.

Guidance: The intent is for the Operator to maintain control (i.e., security, integrity) of all critical game functions. 

Sport and Event Betting Integrity

4.32 Sport and event betting operators shall have risk management measures in place to mitigate the betting integrity risk associated with sport and event betting, including insider betting and event manipulation. (Also applicable to Gaming-Related Suppliers)

Requirements – At a minimum:

  1. Operators shall establish controls to identify unusual or suspicious betting activity and report such activity to an independent integrity monitor.
     
    Unusual betting activity is a betting pattern that deviates, including statistically, from the activity otherwise exhibited by patrons and reasonably expected by an operator or independent integrity monitor, which may indicate potential suspicious activity in the betting or the underlying sport or other event. Unusual betting activity may include the size of a patron's wager or increased wagering volume on a particular event or wager type.
     
    Suspicious betting activity is unusual betting activity that cannot be explained and is indicative of match fixing, the manipulation of an event, misuse of inside information, or other illicit activity.
  2. Independent integrity monitors shall not have any perceived or real conflicts of interests in performing the independent integrity monitor role, including such as acting as an operator or as an oddsmaker. 
  3. Independent integrity monitors shall promptly disseminate reports of unusual betting activity to all member sport betting operators.
  4. All sport and event betting operators shall review such reports and notify their independent integrity monitor of whether they have experienced similar activity.
  5. If an independent integrity monitor finds that previously reported unusual betting activity rises to the level of suspicious activity, they shall immediately notify any entity with which they have an information sharing relationship, including independent integrity monitors, sport betting operators, the appropriate governing authority for the sport or event, and any other organizations or individuals identified by the Registrar.
  6. All independent integrity monitors receiving such a report shall share such report with their member sport betting operators.
  7. Independent integrity monitors shall facilitate collaboration and information sharing to enable the investigation of and response to prohibited activity associated with the suspicious betting activity as directed by the Registrar.
  8. Independent integrity monitors shall provide, in accordance with the notification matrix, the Registrar with:
    1. All reports of unusual betting activity;
    2. If the activity was determined to be suspicious; and
    3. The actions taken by the independent integrity monitor.

Guidance: The Registrar will publish a list of registered independent integrity monitors.

4.33 An operator receiving a report of suspicious activity under Standard 4.32 may suspend or cancel sport and event betting on events related to the report or withhold associated customer funds. To this end, an Operator must ensure that it has reserved itself the authority to suspend betting, void bets, and withhold associated customer funds. The Operator’s decision to suspend or cancel sport and event betting, or withhold associated customer funds, on events related to the report must be fair, reasonable, and made in good faith.

4.34 Operators offering sport and event betting products shall ensure that all bets offered meet the following criteria [Amended: February, 2022]:

  1. The outcome of the event being bet on can be documented and verified;
  2. The outcome of the event being bet on can be generated by a reliable and independent process;
  3. The outcome of the event being bet on is not affected by any bet placed;
  4. The majority of participants in the event or league are 18 years of age or older; event shall be broadly defined as assessing total participants in the event/league, rather than in a particular heat, game, match or final contest in the overall sporting event;
  5. For sporting events being bet on, the event must be effectively supervised by a sport governing body which must, at minimum, prescribe final rules and enforces codes of conduct that include prohibitions on betting by insiders (not applicable to novelty bets);
  6. There are integrity safeguards in place which are sufficient to mitigate the risk of match-fixing, cheat-at-play, and other illicit activity that might influence the outcome of bet upon events;
  7. The bet is not on a past event for which the outcome is publicly known;
  8. The bet is not reasonably objectionable;
  9. The event being bet on does not involve animal fighting or cruelty;
  10. Bets on assets and financial markets (e.g., stocks, bonds, currencies, real property) are prohibited;
  11. Bets which expose players to losses greater than the amount wagered are prohibited;
  12. Bets which mimic the structure of financial instruments, products, or markets are prohibited;
  13. Bets on synthetic lottery products and bets on lottery outcomes are prohibited;
  14. The event being bet on is conducted in conformity with all applicable laws;
  15. Bets on minor league sports in Canada, including the Canadian Hockey League (CHL), are prohibited.

Guidance:

  • For the purpose of Req. 8, reasonably objectional bets include bets on events which are unethical, allow entertainment to be derived from human suffering or death or involve non-consensual violence or injury.
  • Req. 12 applies to contracts for difference including spread betting.

Live Dealer Game Integrity

Last Updated

4.35  Access to live dealer gaming supplies shall be restricted to individuals with a business need. (Also applicable to Gaming-Related Suppliers). [Added: October, 2022]  

Requirements – At a minimum:  

  1. Access privileges are granted, modified, and revoked based on employment status and job requirements and all activities associated with these actions logged.  
  2. Access privileges are independently reviewed and confirmed on a periodic basis.  

4.36  Operators must have controls in place to ensure live dealer game presenters do not compromise the integrity of a game. [Added: October, 2022]