Consultation Feedback Summary

The Malta Gaming Authority (MGA) is publishing a summary of the responses received for the public consultation on Digital Games of Skill with Prize, as submitted by respondents.

Click on the questions to view feedback received.

Most of the respondents across all the categories provided a list of areas that, in their opinion, should form part of the certification. Only 3 respondents from 3 different categories, namely, operators, key officials and other disagreed with the idea of introducing an examination to be certified as a Key Official.

In their absolute majority the respondents agreed that a KO must have the relevant experience and holds a position within the company. It could be noted that less than 45% of the respondents specified the number of years required to qualify as a KO. Again, these covered the various strata of categories.

In reply to question 3, 15 out of 18 respondents agreed with the proposal of introducing 16 CPD hours annually. Only one of the respondents provided a negative reply while the other two respondents (from the KO categorisation) did not provide a reply to this question.

The majority of the respondents (89%) agreed with question 4, that is, the activities proposed by the MGA to be recognised towards the CPD requirements.

All the respondents who answered question 5 (over 94%) provided the subject areas that should be considered towards the KOs CPD.  These include subjects like information systems auditing and security; legal, financial and compliance matters; anti-money laundering; technical area and legal responsibilities of KOs; general management; data protection as well as general industry knowledge and trends.

Fourteen out of 18 respondents are in favour of introducing periodic meetings and annual submissions. The other four replies, all coming from the KO category, did not categorically disagree with the proposed changes but did not express a positive opinion either.

All the respondents provided an opinion of what they think would create a conflict of interest.  These included situations when the KO is a director of the company or the KO is a beneficial owner of the licensee company; when KO is responsible for more than one company that are not part of the same group; positions that are highly KPI driven or positions like COO, CFO and CEO as well as where the KO forms part of companies that are engaged by the MGA to perform audits.

The majority of the respondents (over 94%) provided an opinion on the subject matter. Some of the challenges mentioned included the difficulty to have in-depth understanding of all the companies the KO is responsible for; dealing with third party providers;  the role of KO since it is appointed solely to meet legal requirements rather than as an executive of the company; the fact that one can act as a KO for more than one company which may also be independent from each other, thus not within the same group and the requirements and timelines may be different as well as the fact that a KO has to work in different jurisdictions  and cultures.

Over 94% provided a reply to this question. Eight respondents expressed their opinion of introducing a cap. These covered five operators and one from each of the other categories. Four respondents (three from the KO category and one form the Other category) do not agree with such a measure. The rest of the respondents are not in favour neither against.

Over 94% of the respondents provided a reply. 13 respondents agree with this timeframe, three replies coming from the Operator, Key Official and Other category respectively expressed the opinion of having a shorter transition period while the rest required a longer period.