How casinos report to regulators
Why regulatory reporting is needed
Reporting is not a "paper routine," but a transparency tool: it confirms the honesty of games, the protection of customer funds, the fight against laundering and responsible play. For mature operators, reporting is built into the product: metrics and logs are collected automatically, verified, signed and safely sent to the regulator.
Requirements map: what regulators usually ask for
1) Finance and taxes
GGR/Net Gaming Revenue: bets, wins, cancellations, bonus cost, jackpot deposits; cross-sections by jurisdiction/product/currency.
Game taxes and fees: calculation at GGR/turnover rates; withholding tax reports on winnings (where applicable).
Customer funds and segregation: customer balance register vs. customer bank accounts; daily liquidity reconciliations and confirmations.
Fraud/chargebacks/returns: volumes, shares, reasons, SLA processing.
2) AML/KYC/KYT
SAR/STR (suspicious transaction reports), CTR/threshold reports for large transactions.
KYC-statuses: share of verified clients, EDD, POP/sanction matches, rejected applications.
KYT: abnormal deposit/withdrawal patterns, crypto screening (if used), sources of funds, and off-ramp policies.
3) Responsible Gaming (RG)
Harm/Intervention KPIs: proportion of players with limits, activated timeouts, self-exclusions, behavior trigger response SLAs.
Communications: number of warnings, transfers to assistance services.
Outcomes of cases: intervention results, repeated episodes.
4) Honesty of games and technical control
RNG/RTP: actual RTP by game/provider/period vs. theoretical; corridors and deviations.
Round logs: unchanging bet/win/outcome records, build hashes.
Jackpots: accumulation/payouts/funds, audit pools.
Change-management: release registry, version control, artifact signatures.
5) Marketing and Affiliates
Bonus T & Cs: Changes, wager coast, average actual wager.
Promotional materials: pre-approval and real creatives, target logic 18 +/21 +.
Affiliates: list of partners, UTM/trackers, complaints and sanctions against partners.
6) Information security and privacy
Information security incidents/leaks: detection time, classification, notifications of subjects/regulators, correspondent actions.
Accesses and admin actions: RBAC/MFA revisions, critical operation logs.
Pentests/scans: plan-fact, vulnerabilities found and closures.
7) Support and controversy
Support SLA: first response/resolution time.
ADR/Ombudsman: number of cases and outcomes.
Complaints about payments/bonuses: categories, share of justified.
Dates: typical calendar
Daily (D): rate/pay telemetry, customer funds, incident logs, self-exclusion block list.
Weekly (W): RTP reconciliation, report on RG triggers, KYT triggers.
Monthly (M): GGR/taxes, reconciliation of bank balances, support KPIs, marketing and affiliates.
Quarterly (Q): audit change-management, pentest/scans, report on information security/privacy incidents.
Annually (Y): independent audit of finance/information security (ISO/SOC, if any), recertification of RNG/games, personnel training (RG/AML/information security).
Transmission formats: exactly how they send
API/streams to central hubs (JSON/NDJSON, protected TLS + mTLS/signatures).
SFTP/CSV with integrity control (SHA-256) and schemas: field dictionaries, units of measurement, timezones.
XBRL/regulator portals for finance.
Docks (PDF/signed reports) for incidents, penetration tests, change-review.
Reporting data architecture (high-level)
1. Collection: events of game rounds, payments, authorizations, marketing → in the "raw" data lake (WORM-compatible storage).
2. Cleaning and normalization: unified reference books (game, provider, jurisdiction, currency), deduplication, time zone reduction.
3. Buch-rules: calculation of GGR/net, bonus-costa, shares of providers, tax bases.
4. Data quality (DQ): completeness, validity, uniqueness, timeliness; alerts and automatic backfill.
5. Signature and issue: control of two pairs of eyes (4-eyes), electronic signature, issue log.
6. Delivery: queues/batches, retrays with idempotency, confirmation of admission.
Mini field dictionary (fragment):- 'round _ id '(UUID, unique, idempotent)
- `game_code` / `game_version_hash`
- 'bet _ amount '/' win _ amount '(decimal + currency)
- `bonus_cost_amount` / `bonus_type`
- `player_status` (KYC: pending/verified/EDD)
- `jurisdiction_code` / `license_id`
- `rtp_theoretical` / `rtp_actual_period`
- `self_excluded` (bool, timestamp)
Reconciliation
Operational reconciliation: amount of bets/winnings on game logs = amounts from billing/platform.
Bank reconciliation: customer platform balances = segregated account balances.
Provider reconciliation: reports of content providers vs. platform (by game/day/operator).
RTP monitoring: actual RTP within the corridor; deviations → investigation ticket.
DQ rules: zero/negative amounts, duplicate 'round _ id', missing hour windows → block list before correction.
Typical cases of immediate notification of the regulator
Serious information security incidents (PII/payment data leak).
RTP/jackpot anomalies affecting the calculation of winnings.
Massive payment delays (SLA violation).
Significant AML actuations and interlocks.
Math/engine changes without prior recertification.
Common mistakes and how to avoid them
"Paper compliance." There are policies, there are no metrics in the product → embed RG/AML in UX and logs.
Inconsistent definition records. Different GGR for the financial team and BI → a single glossary and calculation layer.
No WORM storage. Logs can be rewritten → unchangeable storage/retention policies can be enabled.
Releases without change-gate. Game updates without hash fixation/certification → release matrix and freeze periods.
DQ debt. Manual Excel summaries → automation, schema tests, data quality alerts.
Time gap. Inconsistent timezones → store UTC, display locally.
Remediation plan (if discrepancies are found)
1. Root cause (tech/processes/people/data) → post-mortem.
2. Corrective Actions: who/what/when; MAJOR → MINOR priority.
3. Patches and backfills: recalculation of metrics, resubmission; change log.
4. Prevention: circuit tests, canary unloading, release checklists.
5. Communications: notification of the regulator/partners, evidence of corrections.
Roles and Responsibilities (RACI)
Compliance (A/R): interpretation of requirements, calendar, contact with the regulator.
Finance (R): GGR/taxes, reconciliations, customer funds.
Data/BI (R): data models, DQ, storefronts, uploads.
Engineering (R): logs, API, delivery security.
InfoSec/Privacy (R): IR/BCP, pentests, notifications.
Operations/Support (C/I): SLA, complaints, ADR.
Legal (C): interpretations of laws, T&C changes
Executive (A/I): approval of risks and resources.
Check sheets
Before monthly reporting
- Reconciled GGR/customer funds/bank balances.
- RTP report without exits beyond the corridors; investigations are closed.
- DQ-board "green" (completeness/validity/timing).
- Files signed (hashes/electronic signature), issue log updated.
- Game/version changes have passed change-gate and, if necessary, recertification.
- AML/KYC/KYT and RG reports are prepared and agreed.
To launch a new market
- Requirements mapping (what we pass: D/W/M/Q/Y, formats).
- Data dictionary agreed with regulator/providers.
- Delivery channel (API/SFTP/portal) tested with test cases.
- SLA/retray/idempotency tested; "canary" passed.
- Incident plan (who/how notifies) worked out.
Brief FAQ
Do I need to store "raw" logs if there are units?
Yes I did. Regulators often require spot checks and retro audits - this is impossible without raw materials.
Is real-time monitoring mandatory?
In a number of markets, yes. Prepare betting/payout streaming and heartbeat events.
Who is responsible for the correctness of the RTP showcase - provider or operator?
Both: the provider gives certified mathematics, the operator controls the display and post-monitoring.
Strong reporting is a system: uniform definitions and models, unchangeable logs, automatic reconciliations, strict release discipline and transparent delivery channels. This architecture reduces regulatory risks, speeds up approvals, increases the confidence of banks and providers - and directly affects the economy: less downtime, less fines, more trust of players.