(a) The definition of the “CIS” refers to a very specific IT structure, without taking into consideration international operators’ existing IT systems, which may adopt a different structure. We propose that the regulation shall follow a more generic approach, setting out only the minimum elements of the IT system as well as the obligation to offer access to specific functions.
(b) As regards the definition of “Gaming Guide” it is stated that the Guide shall specifically contain an “odds/ winnings table”. This is not feasible in certain categories of games (e.g. peer-to-peer games). We propose that the phrase “where applicable” is added in the end of the sentence. The same amendment shall be effected in articles 8.1.c and 13.1 which contain similar provisions.
(c) The definition of “Player’s electronic account annual result” does not encompass “in-play money”. We propose that this is clearly defined.
(d) The definition of “Playing Session” refers to the time a player participates in a game. This could be problematic and confusing. We propose that this is more clearly defined.
(a) The definition of the “CIS” refers to a very specific IT structure, without taking into consideration international operators’ existing IT systems, which may adopt a different structure. We propose that the regulation shall follow a more generic approach, setting out only the minimum elements of the IT system as well as the obligation to offer access to specific functions. (b) As regards the definition of “Gaming Guide” it is stated that the Guide shall specifically contain an “odds/ winnings table”. This is not feasible in certain categories of games (e.g. peer-to-peer games). We propose that the phrase “where applicable” is added in the end of the sentence. The same amendment shall be effected in articles 8.1.c and 13.1 which contain similar provisions. (c) The definition of “Player’s electronic account annual result” does not encompass “in-play money”. We propose that this is clearly defined. (d) The definition of “Playing Session” refers to the time a player participates in a game. This could be problematic and confusing. We propose that this is more clearly defined.