REGULATORY REPORTING INTERFACE – THE IGSA’S NEW HORIZON
The next in our series of articles about the International Gaming Standards Association’s (IGSA) activities focuses on an important new standard that is of particular use to Regulatory Authorities; the Regulatory Reporting Interface or RRI. This new standard is about to be released and offers important efficiencies and synergies in reporting within the regulatory landscape.
Several years ago, IGSA identified the need for an online gaming data reporting standard. The lack of standardization across gaming jurisdictions meant that online gaming platform (IGP) and remote gaming system (RGS) suppliers had to redevelop their data reporting engines for every new jurisdiction where they got licensed to operate. This rework just added cost and delayed progress.
The lack of standardization went beyond the data reporting format or frequency. The components of that data reporting, the data elements themselves, where also not standardized. In Europe, as an example, this lack of standardization meant that country-specific Regulatory Authorities and the European Commission more broadly, could not easily and accurately compare data across jurisdictions.
Data reporting formats, frequencies and data elements vary jurisdiction to jurisdiction even though the IGP and RGS suppliers are the same and the games they provide in those jurisdictions are largely the same ones. To exacerbate matters in some cases, Regulatory Authorities are being asked to provide oversight for land-based, online and even lottery gaming activity. Systems that those gaming verticals use are different, with different reporting capabilities and different data elements. With no data reporting standards in place, this is challenging at best.
For these reasons, IGSA early in the development of RRI expanded its scope to include all three gaming verticals. The RRI creates a single Extended Mark-up Language (XML) or JavaScript Object Notation (JSON) mechanism that land-based and online systems can use to send data files that regulators need, in a standard format. The RRI standard must be programmed into both the Regulatory Authority’s systems as well as the supplier’s systems. For land-based operations this may be the Casino Management System, Central Determination System or Lottery Central System (collectively land-based systems). For online operations this may be the Remote Game System, Internet Gaming Platform, or Remote Jackpot System (collectively online systems).
RRI exposes a superset of the data that is produced as a result of wagers and wins occurring on casino games, sports betting, poker, and lottery. Each Regulatory Authority decides the data they want by selecting specific data elements that are saved in a schema on their system. The schema also identifies the order in which the data elements should be presented. The Regulatory Authorities also choose the reporting frequencies they require, either in real-time, near-real-time or periodic reporting. It must be said that IGSA highly recommends using either near-real-time or periodic reporting.
With RRI, system developers will no longer have to modify their programs to match the data reporting requirements of a particular jurisdiction. Instead the land-based or online systems will read the schema for each data report from the Regulatory Authority’s system through RRI. This schema will instruct systems the data elements that are needed for a particular report, what order they must be in and the frequency of that report. Then the systems simply fetch the data from their internal databases, put them in the required order and send them to the Regulatory Authority’s system using a standard file naming convention. RRI does not dictate how the regulators store that data. They can put in a data vault, in a relational database, or in a flat-file database, whatever data storage system they wish to use.
Those readers more technically inclined, can see that RRI could actually be programmed into a separate module that sits above the existing land-based or online system and interfaces into those systems to pull the required data. This further simplifies the implementation as many jurisdictions require those systems to be submitted to and approved by third party laboratories, which is both time consuming and expensive.
Additionally, RRI is extensible, meaning that any new data elements that are needed as a result of new game innovation can be added. RRI also allows gaming jurisdictions to add their own selection-values in certain data elements, similar to the choices you get when you click on a drop-down list. RRI has a standard set of selection-values for certain data elements, but a gaming jurisdiction can add more. This does not require system developers to reprogram their reporting engine. As long as they are capturing those values in their system – and they would have to be in order to be compliant with that jurisdiction’s requirements – then RRI allows them to simply grab the data element and its value.
At its core RRI is about reporting data and that data is comprised of data elements. Therefore, having a data dictionary of the data elements available is critically important. That data dictionary needs to list not just the elements, but also define them. Each data element definition includes a specified type (string, timedate, uniqueId, decimal), a specified maximum length, whether required or optional, and whether it could have more then one value (recursive). The data elements are the building blocks that will then create the data reports.
IGSA was not the only organization to identify this data reporting standardization need. In late 2010, the European Commission asked its then Expert Group on Gambling to study whether having a pan-European standard on “… reporting for the purpose of supervision of online gambling….” would be beneficial. The Expert Group’s research conducted between 2013 and 2016, indicated that it would indeed be beneficial. In April of 2018, the European Commission issued a mandate[1] to create such a standard, which the European Committee for Standardization (CEN) took on. CEN created Technical Committee 456 to create this standard. IGSA was pleased to see that other organizations saw the same need and GSA Europe became a Liaison Organization to CEN TC/456 specifically to help create the standard.
By 2018, when CEN created TC/456, IGSA had been working on RRI for a couple of years and had gone through ten drafts of the standard. Given the progress that IGSA had made with RRI, it was in a position to help CEN TC/456 achieve its objective faster. For this reason, GSA Europe, as the Liaison Organization to CEN TC/456, donated RRI to CEN using it as a spring board to jump start the TC/456 work. GSA Europe’s Managing Director was asked to become a Co-Project Leader to help guide the technical aspects of developing the standard, which he accepted, and the project is well on its way to align to agreed timelines with the European Commission.
In the meantime, IGSA has finished developing RRI version 1.0. The members of the IGSA Online Gaming Committee that have been working on this standard, unanimously voted to release the standard which is now going to the IGSA membership for review and comment. This will be followed by a formal Board of Directors vote for release.
There are some minor differences between the reporting standard being developed by CEN TC/456 and RRI. As one can appreciate, the TC/456 work is focusing only on European needs and as directed by the European Commission’s mandate, only on online gaming. IGSA developed RRI to address the needs of the global gaming industry and to cover land-based in addition to online gaming. In this regard, the TC/456 standard can be considered a sub-set of RRI, but fundamentally aligned in design and objective.
AUTHOR
Mark Pace is the Managing Director of the International Gaming Standards Association – Europe.
[1] European Commission – Commission Implementing Decision M/558 of 4/4/2018