The Malta Gaming Authority (MGA), alongside the Malta Digital Innovation Authority (MDIA), has introduced an AI Gaming Charter designed to guide the integration of artificial intelligence technologies within Malta's gambling sector.
Launched this week, the Charter provides a voluntary framework that aims to enhance existing legal structures, including the European Union’s Artificial Intelligence Act (EU AI Act) and the General Data Protection Regulation (GDPR).
A primary focus of the document is the necessity of human oversight due to the rapid advancement of AI technology.
The Charter’s aim is to translate legal and ethical guidelines into applicable practices for the industry. This includes the use of AI in various applications, such as customer service chatbots, fraud detection mechanisms, anti-money laundering (AML) efforts, and responsible gambling programs.
While the Charter does not impose new legal requirements, it offers extensive best practice recommendations centered on key themes such as transparency, human oversight, data governance, fairness, non-discrimination, system reliability, and environmental responsibility.
It encourages licensed operators to compile inventories of AI systems, clearly identify their roles as suppliers or users within the framework of the EU AI Act, and adopt a risk-based methodology.
The document also references tools provided by the MDIA, such as the compliance checker for the EU AI Act, and outlines reporting obligations to regulatory bodies concerning significant AI-related incidents.
Key recommendations include:
**Transparency and Disclosure**: The Charter emphasizes that players should be able to recognize their interactions with AI-driven systems. Developers must disclose AI-generated content, including deepfakes, per Article 50 of the EU AI Act. It differentiates between what information should be shared with regulators and the public, aiming to protect sensitive algorithms and data from needless exposure.
**Human Oversight**: The Charter states that AI should supplement human judgment rather than replace it, particularly in sensitive areas such as monitoring gambling harm and account restrictions. For higher-risk AI applications, operators must keep thorough logs detailing escalation processes and perform regular validation tests.
**Data Governance and Privacy**: Reinforcing principles of the GDPR, the Charter calls for practices like data minimization, purpose limitation, accuracy, and proper data retention management. It urges operators to document the origins and quality of AI training data and to proactively mitigate any bias.
**Environmental Sustainability**: The Charter acknowledges the substantial energy consumption associated with AI training and operations. Recommendations include performing due diligence on suppliers' energy practices, enhancing efficiency in deployment, and factoring in carbon footprints during the development process.
Data gathered for the Charter showcases varied AI adoption across the sector, with many firms only at the proof-of-concept stage or concentrating on back-office functions rather than direct player engagement. According to the study within the Charter, “data indicates that several organizations are deploying AI at Minimum Viable Product stages, especially in responsible gambling behavioral modeling, fraud detection, AML, recommendation engines, player onboarding, KYC, payments, human resources, and player acquisition.” This suggests that while some gaming licensees are moving past initial trials, they are still testing practical applications before broader implementation.
A separate analysis by The Playa, in collaboration with Gaming Operations Academy and WarriorLab, indicates that VIP account managers heavily rely on outdated systems. The study revealed that while managers appreciate AI for streamlining tasks, many are reluctant to rely entirely on automated systems for final decisions. Approximately 38% expressed concern that AI integration could diminish the personal touch in managing VIP accounts.
The Charter aims to bridge this gap by providing accessible guidelines that promote responsible and proportionate AI usage. Charles Mizzi, CEO of the MGA, characterized the Charter as a balancing act, emphasizing, “Our role as a regulator is not to stand in the way of innovation, but to help create the certainty and confidence needed for innovation to flourish responsibly.” MDIA CEO Kenneth Brincat also underscored the significance of building trust and accountability, saying the Charter “translates these principles into practical, sector-specific guidance."
