Mobile applications are playing an increasingly significant role in our everyday lives, and gambling is no exception. However, gambling games where the outcome depends entirely or mostly on luck are subject to specific regulations and restrictions.
The App Store and Google Play Store are the two main platforms where users can download various gambling applications. However, as with all categories of apps, there are certain rules that developers and users of gambling apps must comply with. In this article, we will look at the App Store and Google Play Store rules and policies regarding gambling apps, and point out the key principles that developers and users should be aware of.
The main act regulating gambling apps available on the App Store is the App Store Review Guidelines. According to this document, the following requirements can be highlighted:
In 2019, Apple has introduced a “17+” age limit for gambling apps available through the App Store in all countries and regions. In addition, Apple has announced that casino, entertainment and simulated gambling apps will be available in South Korea to users who are at least 19 years old.
Sweepstakes and contests must be sponsored by the app developer. The app must include official rules for contests and sweepstakes and make it clear that Apple is not sponsoring or in any way involved in these activities.
Apps offering real money games (e.g. sports betting, poker, casino games, horse racing) or lotteries must be properly licensed and authorised in the jurisdictions where the app is used and must be linked to those locations. Illegal gambling tools, including card counters, are prohibited on the App Store. Lottery apps must specify consideration, chance and the prize itself. For example, entry consideration $2, prize between $1 and $500, winning percentage (chance): 0.2% (or 1:500).
In 2019, Apple announced that as of September, it would only allow gambling apps native to iOS to be hosted in its App Store. This change was due to the fact that many gambling apps were ‘container’ apps, as they essentially repackaged their websites into apps, which was easier for developers to maintain. However, for the safety of users, Apple banned this method and allowed only ‘native’ apps.
Applications that provide services in highly regulated areas (such as gambling) or that require confidential user information must be provided by a legal entity and not by an individual developer.
Failure to meet these requirements will prevent the app from appearing on the App Store.
The Google Play Store in turn allows the following types of gambling apps: online casinos, sports betting, horse racing (if regulated and licensed separately from sports betting), lotteries, daily fantasy sports and eligible apps must also meet the following requirements:
To apply for distribution on the Play Store of a new gambling app, a new country (region) of distribution or a new category of gambling supported by the Play Store for an existing app, an online form must be completed for each market where the app will be distributed. The form should include details of the licensee, the licence itself, attach copies of proof documents, and agree to certain conditions, such as users confirming that they are of legal age to use the gambling app, implementing and maintaining the necessary age verification systems, posting information on responsible gaming, and providing information on treatment options for gambling addiction.
The app must also prevent access and use from countries, states/territories, or the geographic areas not covered by the developer-provided gambling license. The developer must not offer a type of gambling product that exceeds the scope of its gambling license.
As stated above, one of the requirements of the application form for the distribution of gambling apps is that the developer must confirm the implementation and maintenance of the necessary age verification systems. In practice, however, applications most often only require the user to state their age when registering and tick the box above the requirement for the user to prove that they are 18 years old.
The concept of ‘responsible gambling’ implies that applications should contain information about the possible risks and consequences of gambling addiction, prevention of attraction and exaggeration of prizes, i.e. should not create false expectations of the chances of winning or exaggerate the size of prizes. This principle also includes self-exclusion programmes that allow players to exclude themselves temporarily or permanently from gambling, the option of setting time or financial limits.
Based on compliance with these requirements and legal requirements, 3 groups of gambling applications can be identified:
Such applications are often created under the guise of gambling applications, but are in fact created to defraud users and illegally obtain their money. They may present themselves as legitimate gambling sites, but actually create situations where players have no real chance of winning, using algorithm manipulation, fake results or non-payment of winnings.
Applications in this group fall somewhere in between fully legal and illegal. They may not meet certain security and legality requirements, which may include insufficient measures to protect user data, non-transparent terms and conditions, unconfirmed payouts of winnings or lack of a license to operate a gambling business. While such applications may function and are not directly intended to defraud, they violate gambling laws and the requirements of gaming platforms.
Such applications comply with legal requirements and have all the necessary permits and licences to organise gambling. They comply with all the requirements set by the competent authorities and offer a safe environment for players. They usually have clear terms and conditions, transparent game algorithms and reliable payout systems, ensure user data security and comply with requirements to prevent access to gambling by underage persons.
Apple’s rules for advertising on the App Store list gambling-related apps as ‘restricted’, meaning that there are specific rules about where their ads can be placed. However, in October 2022, Apple suspended advertising of gambling apps on the App Store after numerous complaints from users and developers. Unlike Apple, Google is giving users the option to limit the number of potentially “inappropriate” ads they see, including those related to gambling. Google allows apps with gambling ads if they meet the following requirements:
Thus, Apple and Google have implemented fairly strict rules for gambling apps to ensure that such apps available on their platforms are safe and compliant with the law. Compliance with these requirements allows developers to create and host safe gambling apps, and users can trust the apps they download. It is vital that both developers and users become familiar with these legal requirements and work together to promote responsible gambling practices in mobile apps.
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