Introduction

Following the end of Macau's gaming industry monopoly, dealer-operated electronic table games (DETGs) have assumed an important and decisive role in the Macau gaming market. Until recently, no technical standards covered the hardware and software of these particular gaming products.

Considering the development and increasing importance of this type of gaming product, the Macau Gaming Inspection and Coordination Bureau decided that it was necessary to advance a new set of "credible technical standards for DETG".

On December 6 2017, following the issuance of the technical standards, the bureau published Instruction 1/2017 on DETG Technical Standards Version 1.0 (the guidelines). The main purpose of the guidelines is to unify the technical requirements for bureau approval of DETGs. The relevant test reports and certificates must be in accordance with the guidelines' aim of improving "fairness, transparency, so as to enhance the positive image of the gaming industry in Macau".

Guidelines

Commencement, effectiveness and enforcement

The commencement date of the guidelines is January 1 2018, but the effectiveness date has been postponed to June 30 2018 in order to allow manufacturers to implement the new standards imposed under the guidelines (the grace period).

After July 1 2018, all DETGs with an approval process which has been submitted to the bureau will be tested and certified by an authorised laboratory.(1) DETGs that do not comply with the technical standards by 12:00pm on December 31 2019 must be disconnected and permanently withdrawn from operation.

Grace period operation

During the grace period, the bureau will accept applications for approval of DETGs that are compliant with the guidelines or GLI25 dealer-controlled electronic table games.

All DETGs approved at the commencement date but upgraded with any hardware or software which materially changes(2) the operation, fairness, security, reliability or auditability of the product will be treated as a new application (ie, requiring new approval). In such a case, the upgraded product must fully comply with the guidelines.

Grandfather period operation

The guidelines set out a grandfather period from July 1 2018 and December 31 2019 (inclusive). During this period all gaming concessionaires (or sub-concessionaires) must submit so-called 'updating reports' detailing their developments to withdraw from operation or convert DETGs to fully comply with the guidelines. The updating reports should be filed with the bureau no more than 30 days after the end of each six-month period, commencing on June 30 2018.

The updating reports should advise on the total number of DETGs which:

  • have been withdrawn permanently from operation or have been converted to become fully compliant during the relevant period;
  • have been withdrawn from operation during the grandfather period; and
  • are non-compliant at the reporting date.

Each updating report must also contain an itemised schedule with serial numbers of all withdrawn or converted DETGs.

Gaming concessionaires (or sub-concessionaires) must use their best efforts to achieve at least a 40% conversion rate by 12:00pm on December 31 2018.

The grandfather period will not be extended.

Comment

The technical standards recently disclosed by Macau's gaming regulator assume a double importance for local gaming industry. First, the technical standards have bridged a gap in the existing legal framework, helping to mitigate uncertainty about the operation and legal processing of this sort of hardware and software within the gaming industry which is relevant to stakeholders, gaming operators, manufactures and clients. Second, the technical standards have contributed to the standardisation of these two different generations of electronic gaming machines and their respective software's technical standards, confirming the regulator commitment to implement the best international industry practices in Macau.

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For further information on this topic please contact Pedro Cortés or Óscar Alberto Madureira at Rato, Ling, Lei & Cortés Advogados by telephone (+853 2856 2322) or email (cortes@lektou.com or madureira@lektou.com). The Rato, Ling, Lei & Cortés Advogados website can be accessed at www.lektou.com.

Endnotes

(1) According to Instruction 1/2017, Annex I, the authorised laboratories include:

  • BMM International Pty Ltd;
  • Gaming Laboratories International;
  • Technical Systems Testing;
  • Enex TestLab;
  • Slovenia Institutes of Quality and Metrology;
  • QALab Pty Ltd; and
  • Eclipse Compliance Testing.

(2) Material changes (if any) will be considered on a binding basis by the bureau following any submissions made by authorised electronic gaming machines manufacturers.