What is Online bingo?
There is no legal definition of the game of bingo, or a standard set of rules under which the game is played. However, the game and its rules have evolved to the point where, despite the absence of any formal industry standard, the way in which bingo is played is broadly similar throughout Great Britain. Bingo is equal chance gaming.
It is worth noting that although there is no statutory definition, the Gambling Commission has published our view of what bingo is and how it differs from other forms of gambling. This can be found in the advice note ‘What constitutes bingo’. This advice was developed with the support of key stakeholders from the Bingo industry.
What constitutes online bingo?
Bingo is a traditional form of gambling that has seen considerable innovation in recent years. It is also the only form of gambling recognised in the Gambling Act 2005 (the Act) that does not have a specific statutory definition, the Act providing simply that ‘bingo’ means ‘any version of that game, irrespective of by what name it is described’. The Gambling Commission (the Commission) has no desire to change the position set out by Parliament.
However, in the light of rapid and expanding product development and innovation in the sector, we consider it important to provide some clarity as to where we consider the boundaries between bingo and other forms of gambling lie. The Commission therefore offers the advice in this note to help bingo operators avoid creating and offering products that we consider to be casino games, lotteries or fixed odds betting.
The Commission has, both before and since the coming into force of the Act, received many enquiries from both the ‘traditional’ bingo industry and from new entrants, or potential new entrants to the market, about new game formats proposed to be offered as bingo in bingo licensed premises. It has also had correspondence with The Bingo Association about what constitutes bingo. Whilst only the courts can provide a definitive interpretation of the law, the Commission considers it helpful to publish this advice note setting out its views as to the essential requirements for a gambling product to be recognised as bingo.
In the context of this advice, it should also be noted that, as well as providing bingo, holders of bingo premises licences may, by virtue of section 291 of the Act, also offer facilities for prize gaming1 provided such gaming complies with the conditions attached to all bingo operating licences by the Gambling Act 2005 (Operating Licence Conditions) Regulations 2007 (SI 2007 No. 2257) which impose limits on both participation fees and prizes.
Bingo itself, whilst traditionally played for a prize pool comprising players’ stakes less participation fees, may also be played for a set prize or prizes determined neither by reference to the number of persons playing nor the amount paid for or raised by the gaming, and therefore in a format which meets the definition of prize gaming. Such a bingo format, especially when played for modest prizes, is often referred to as ‘prize bingo’. But bingo of this type also meets the essential requirements set out below and consequently, unlike other types of gaming, may be offered in bingo licensed premises without the need for reliance on the specific permission contained in section 291 and thus without having to comply with the participation fee and prize limits laid down in the 2007 Regulations. 1 Gambling Act 2005 section 288 – Meaning of ‘prize gaming’ Gaming is prize gaming for the purposes of this Act if neither the nature nor the size of a prize played for is determined by reference to– (a) The number of persons playing, or (b) The amount paid for or raised by the gaming. Victoria Square House Victoria Square Birmingham B2 4BP T 0121 230 6666 F 0121 230 6720 www.gamblingcommission.gov.uk Gambling Commission Advice note – what constitutes bingo?
Fundamental principles of bingo
In its historic development, bingo is essentially a lottery played as a game. Although dated, a good starting point in understanding the characteristics of bingo is its description in the 1978 Royal Commission Report: ‘Bingo is a lottery played as a game. Each player receives for his stake a set of numbers which he has not chosen. These are marked off against numbers selected at random and announced by a caller, and the winner is the person who can first substantiate a claim to have marked off all those, or a particular section of those, in the set he has been given.’ 3.2 The Act distinguishes bingo from casino gaming. It provides in section 65 for separate casino and bingo operating licences and, in section 68(3), excludes bingo from the ‘other games of chance’ that a casino operating licence authorises its holder to provide.
Against this background and following consultation with a wide range of bingo industry stakeholders, the Commission considers there are three fundamental principles of bingo. These principles are:
- bingo must be played as an equal chance game
- bingo must involve a degree of participation and
- bingo games must have a clearly defined end point.
Further information regarding the Commission’s view of each of these principles is set out in the following paragraphs. Online Bingo must be played as an equal chance game
In order for a game to be classed as ‘bingo’ it must meet the Act’s definition (in section 8) of ‘equal chance gaming’ (as opposed to casino gaming). Thus, it: a) must not involve playing or staking against a bank, and b) must be a game in which the chances are equally favourable to all participants in the sense that each ticket or chance has the same probability of success as any other.
The Commission sees no objection to players in bingo being able to select some, or indeed all, of their numbers provided there is a mechanism to ensure that each player nevertheless has a unique set of numbers and the game therefore remains equal chance. We also consider that fixed odds bingo games are acceptable provided they are structured to ensure there is no banker’s interest.
The Commission has produced a note addressing what it considers constitutes a banker’s game and how equal chance gaming can be distinguished from it. This can be found at Annex A. Bingo must involve a degree of participation
To distinguish an online bingo game from a straight lottery, a player must be required to participate in order to be successful. Participation could, and traditionally does, take the form of human interaction with the game, ie: players actively marking their cards and/or claiming to have won. Alternatively, as is often the case in modern bingo formats, especially when played on-line, by means of bingo machines or hand-held devices, technology can be used to act as the participant’s agent in playing out the game which the player has initiated. In this way participation can be made up of a combination of activity taking place both within the mechanic of the game and by the player’s own actions.
Bingo games where the winning numbers are pre-selected are acceptable, provided that those numbers are subsequently called or displayed. 2 Gambling Commission Advice note – what constitutes bingo? Bingo must have a clearly defined end point
A fundamental element of a game of online bingo, as with any game, is that it needs to end at a predetermined designated point or time. This end point needs to be appropriate, realistic and clearly communicated to players. The period within which a player is able to claim a prize should be factored into the timeframe of the game; determining who has won is part of the game.
In June 2009 the Commission published a document entitled Key characteristics of bingo, which had particular relevance to bingo played on bingo machines and which bingo industry stakeholders have said they found helpful. A copy of that document, as updated and revised in the light of more recent discussions with such stakeholders, is reproduced at Annex B.
The Commission has, of course, separately set technical standards and equipment requirements for remote and non-remote bingo respectively with which, as a condition of their licences, operators must comply
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BONUS ACCOUNTS – GENERAL TERMS
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