Understanding the new norm of the regulatory changes in Denmark’s iGaming sector

The Danish Gambling Authority (DGA) has recently introduced a series of revised requirements for licensees in the iGaming sector, marking a significant shift in the regulatory landscape of the jurisdiction. These changes, initially announced on 24 May, will be implemented in 2025, indicating a concerted effort to refine and enhance regulatory practices within Denmark’s thriving iGaming industry.

While the exact enforcement date is yet to be determined, the DGA is recommending a transition period to accommodate these changes. The specifics of this period will be disclosed alongside the final version of the updated requirements, following a consultation period designed to gather feedback and insights from stakeholders.

Implications for operators

While operators will, without doubt, face challenges in adapting to these new requirements, the changes are generally seen as a positive step towards enhancing transparency and accuracy in the sector. The DGA’s open call for feedback also indicates a collaborative approach, allowing operators to participate in the final implementation of these rules.

✅ New Guidelines	What operators will need to do
✅ Detailed Reporting	Provide detailed reporting on odds for betting activities, to include specific requirements for partially closed bets and spread betting.
✅ Player Identification	Player IDs compulsory – exemption for player identification information in land-based betting reports has been removed
✅ Fixed Odds Bets	All fixed odds bets must now be reported as independent transactions, ensuring detailed reporting similar to other types of betting.
✅ Feedback Opportunity	Collaborative approach between regulator and operators is encouraged in the approach to the final implementation of these rules.
✅ Enhanced Transparency	New regulators will increase transparency and accuracy in the iGaming sector, marking a positive step towards a more robust regulatory environment.

Operators will be expected to provide detailed reporting on odds for betting activities, including additional specific requirements for partially closed bets and spread betting. The new rules also clarify the handling of betting exchanges, where both sides of all bets are expected to be reported. In previous versions of the DGA requirements, player identification information was not required for land-based betting reports. However, this exemption has now been removed following the introduction of compulsory player IDs. Additionally, new requirements are included for providing test data for jackpots. Procedures for amending reported data are very clear, specifically distinguishing between changes to the game result and the correction of reporting errors.

Reaction from operators

The response from operators to the new requirements introduced by the DGA has been varied. The regulator’s open call for dialogue suggests that operators are actively contributing to this change and will have the opportunity to express their concerns and suggestions. However, the introduction of these new rules poses a significant challenge for operators. The need for more detailed data and the requirement to report each bet as a separate transaction will likely necessitate considerable adjustments to their current operations. The removal of the previous exemption for land-based betting, which permitted operators to exclude player identification information, also represents a notable change. Despite these challenges, the new requirements are perceived as a necessary progression towards increased transparency and more accurate reporting. They aim to enhance the current regulatory methods within Denmark’s gambling industry. The DGA’s efforts to improve regulatory oversight and ensure the accuracy of reporting have been acknowledged as setting a commendable standard for other global gambling officials. However, the complex regulatory environment undoubtedly makes Denmark a difficult jurisdiction for operators to thrive in. The DGA’s emphasis on oversight and regulation, while beneficial for the industry’s integrity, may present operational and compliance challenges for operators..

Enhanced transparency and accountability

The updated requirements in reporting will significantly reduce operational and reputational risks. For example, several adjustments to the language used to define certain bet types, are aimed at providing greater clarity and precision. One of the key directives in the new requirements is the mandate for all fixed odds bets to be reported as independent transactions. This move is designed to ensure that these activities are reported with the same level of detail as other types of betting. All transactions related to fixed odds betting, including the placing of bets, wins, losses, and cancellations, must now be recorded using one of two standard record types: one for transactions and another for winnings. In the wake of these new rules, licensees will also be required to report each bet in a combination bet – such as a double, treble, or accumulator – as a separate transaction. This requirement extends to traditional fixed odds betting, bets on virtual sports, and exchange betting. In addition to the detailed transaction reports, licence holders will be required to compile summarised data on their operations to be submitted daily. This move is expected to enhance transparency and accountability within the sector. The updated documentation also includes clarifications on various types of poker games and how they should be reported, providing operators with a clearer understanding of their reporting obligations. As these changes loom on the horizon, operators and other interested stakeholders are encouraged to submit their feedback on these proposals via the DGA’s contact form not later than 10 June 2024. Once the consultation period has closed, the DGA is expected to set out timelines for a possible transition arrangement and the final date when these changes will come come into effect, expected at some point in 2025. This marks a new chapter in the evolution of the iGaming sector in Denmark, with the updated requirements set to deliver a more robust and transparent regulatory environment.