4. Ensuring Game Integrity and Player Awareness

Last Updated: 
2023-11-01

4.1    All gaming activities and financial transactions shall be conducted fairly and honestly, and must be independently verifiable. 

Lottery-Specific Guidance: Given the operational nature of the lottery sector, not all aspects of lottery activities and transactions will be independently verifiable, but it is expected that they will be where possible.

4.2    Rules of play, including any subsequent modifications, shall be submitted to the Registrar for approval.

Requirements – At a minimum, the rules of play shall contain:

  1. Odds of winning, payout odds or returns to players.
  2. A description of how the game is played.
  3. Circumstances in which a game can be declared void.

Lottery-Specific Guidance: For lottery, rules of play encompass game conditions and as such shall be submitted for Registrar approval, but fact sheets are not required to be submitted.

Due to the nature of sports betting in Ontario, the “Odds of winning, payout odds or returns to players” for sports games are typically indicated on the ticket, not within the rules of play. As well, returns for players can vary depending upon the amount of a given wager. Sports games, therefore, are excluded from Requirement 1.

4.3    Lottery schemes must be conducted in accordance with the approved rules of play. Sport and event betting must be conducted fairly, honestly and in accordance with the terms of the bet placed by the player.

Requirements – At a minimum:

  1. All bets shall be accepted, processed and settled in accordance with the approved rules of play.
  2. Adequate supervision of the lottery scheme is in place to ensure adherence to required procedures.
  3. Devices that compromise or affect the integrity of lottery schemes shall not be permitted.

  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.

4.3.1    The Operator offering sport and event betting products shall ensure that all bets offered meet the following criteria:

  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);
  1. 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;
  2. The bet is not on a past event for which the outcome is publicly known;
  3. The bet is not reasonably objectionable;
  4. The event being bet on does not involve animal fighting or cruelty;
  5. Bets on assets and financial markets (e.g., stocks, bonds, currencies, real property) are prohibited;
  6. Bets which expose players to losses greater than the amount wagered are prohibited;
  7. Bets which mimic the structure of financial instruments, products, or markets are prohibited;
  8. Bets on synthetic lottery products and bets on lottery outcomes are prohibited;
  9. The event being bet on is conducted in conformity with all applicable laws;
  10. Bets on minor league sports in Canada, including the Canadian Hockey League (CHL), are prohibited.
  11. In-game and peer-to-peer bets are prohibited.
  12. Individual bets over $100 are prohibited, except for the Pools products, for which bets over $500 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.

4.3.2    The Operator may only offer Draw-Based games and Instant games through a Self-Serve Lottery Terminal.

Guidance: Permissible games do not include:

  1. sport and event betting
  2. card games,
  3. table games
  4. slots, or
  5. any game that offers real-time play, except instant games.

4.4    Removed, April 2017.

4.5    All gaming systems and gaming supplies, including any subsequent modifications, shall be submitted to the Registrar for assessment and approval, at the expense of the supplier, prior to being provided to any gaming site.

Requirement:

  1. At a minimum, in accordance with the established notification matrix, approval by the AGCO is required prior to putting a gaming system or gaming supply in play.

Lottery-Specific Guidance: For the purposes of this Standard instant game tickets are not required to be submitted for assessment.

4.6    Gaming systems and gaming supplies shall be provided, installed, configured, maintained, repaired, and operated in a way that ensures the integrity, safety and security of the approved gaming supplies and systems, and in accordance with the Registrar’s approval. 

Requirements – At a minimum:

  1. Only gaming systems and gaming supplies approved by the Registrar shall be used at a gaming site.
  2. Any problem with the integrity or security of the gaming system or gaming supplies shall be reported in accordance with the established notification matrix.
  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, the current state of the gaming system and gaming supply, and any supportive evidence shall be preserved until investigators (OPP or AGCO) have provided direction.

4.6.1    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.

4.7    Production, testing and development systems shall be logically separated.

4.8    Moved to Electronic Lottery Systems Minimum Technical Standards.

4.9    Where game outcomes or sport and event betting transactions are not recoverable, Operator shall have clearly defined policies in respect of treating the player fairly when resolving the player’s transactions. These policies and processes shall be made available to players upon request.

4.10   Not applicable to lottery sector.

4.11   A player’s bet and the outcome of the game shall be clearly communicated and easy to understand.

4.11.1    In sport and event betting, details on placed bets shall be made readily available and clear to the player.

Requirements – At a minimum, the betting system or lottery ticket shall give the player the following information:

  1. The gaming site or brand with which the bet was made.
  2. The event and outcome upon which the bet was placed.
  3. The date and time of the bet and information about the outstanding bet.
  4. The payout odds and total monies bet.

4.11.2    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.

4.11.3    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.

4.11.4    The operator shall have controls in place to ensure the accuracy and timeliness of sport and event results data.

4.12   Complaints and any inquiries related to game integrity must be recorded and addressed in a timely and appropriate manner.

4.13   Games shall pay out accurately, completely and within a reasonable time of winning, subject to checks and verifications.

Requirement - At a minimum:

  1. The Operator shall have mechanisms in place to ensure that prizes are paid to the rightful person and only to eligible individuals.

Lottery-Specific Requirements – At a minimum, the Operator shall:

  1. Ensure that additional verifications take place to determine the rightful owner and/or eligibility for:
    1. all major prize claims (over a threshold as approved by the Registrar)
    2. irregular or suspicious claims
    3. claims by insiders or other designated persons.
  2. Have mechanisms in place at Seller locations to ensure that prizes are paid out to the proper person, including:
    1. a maximum level of prize redemption permitted at Seller locations
    2. a clear indication of the prize validation outcome provided
    3. winning number information made available to members of the public.
  3. Have in place an escalation process for prize claim issue resolution.
  4. Not allow players to redeem or claim any prizes or portion of a prize through the self-serve lottery terminal, except a prize or the portion of the prize that is in the form of one or more lottery tickets valued at $300 or less.
  5. Not allow players to purchase more than $300 of lottery products per transaction on an self-serve lottery terminal.

4.14   Operators and gaming-related suppliers shall have mechanisms in place to appropriately deter, prevent and detect collusion and cheating.

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

4.16   Individuals must be able to easily and readily report activities related to collusion and cheating.

4.17   There shall be mechanisms in place to ensure the integrity, security and fairness of lottery draws.

Requirements – At a minimum:

  1. Draw machines shall be tested to ensure randomness.
  2. All draws must be verified by an independent oversight function acceptable to the Registrar.
  3. Physical draws shall be video recorded and recordings must be kept for a period of time as specified by the Registrar.
  4. A record of all electronic draws must be kept for a period of time as specified by the Registrar.
  5. Winner selection processing and winning share values shall be independently validated.

4.18   In the event that the Operator suspends, recalls, withdraws, or cancels all or part of a lottery scheme, the Operator shall have clearly defined policies in respect of treating the player fairly when resolving the player’s transactions.

4.19   There shall be documented procedures for setting and updating the odds for sports games, taking into account market forces.

4.19.1    The operator 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. The Operator 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.

4.19.2    An operator receiving a report of suspicious activity under Standard 4.19.1 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.

4.20   The results for sport games shall be verified using credible sources and according to industry good practices.

4.21   The Operator shall have clearly defined policies and procedures in place to address unclaimed prizes.

4.22   Winning instant game tickets shall be randomly generated during printing. 

4.23   The Operator shall maintain an accurate, complete, and auditable list of all individuals involved in the handling of lottery tickets at Seller locations.

Requirements – At a minimum:

  1. Sellers must ensure that the Operator has an up-to-date list of all individuals involved in the handling of lottery tickets at the Seller’s location.

4.24   Sellers and Seller’s employees may only conduct a player’s lottery transactions when that player is present at the Seller’s location.