New Zealand has published draft requirements that would require licensed online-casino operators to independently test games and random-number generators before launch, then continuously monitor their performance and the wider technology supporting gambling controls.
The Department of Internal Affairs released its Discussion Draft Testing and Monitoring Requirements on Sept. 24. Casino.com reported that the proposal is intended to demonstrate both that games are fair and that technology continues to operate as intended after it enters the market.
Licence applicants would have to maintain a register of every game and random-number generator they propose to offer. Games, including live-dealer titles, and RNGs would need testing by an approved independent laboratory, while operators would remain accountable even where technology is supplied by a third party.
The draft would permit recognition at market entry of testing performed to certain standards accepted by the UK Gambling Commission or Ontario’s Alcohol and Gaming Commission. But material changes that could affect game fairness would require further testing before they were deployed.
Laboratories would be expected to verify that each game’s theoretical return to player is calculated correctly and aligns with its rules, prize tables and underlying mathematics. Tests would compare expected RTP with results from a statistically significant volume of simulated or actual play.
The proposed obligations would continue after a title goes live. Operators would need to monitor actual RTP against the theoretical figure on an ongoing basis, potentially examining stake levels, bonus features, jackpots and other components separately where aggregate performance could conceal discrepancies. A material discrepancy could create a reporting obligation.
Continuous technology monitoring would also cover incidents affecting a platform’s security, integrity, availability or correct operation. The systems in scope include identity and age verification, self-exclusion registers, customer limits, breaks in play and other harm-minimisation measures.
The draft adds a technical layer to the Online Casino Gambling Act 2026, its regulations and the statutory minimum standards that took effect on July 8. As covered in July, the regime is intended to shift a market historically served by offshore providers into a licensed framework.
Those existing minimum standards already require platforms to maintain and check self-exclusion registers before account activation and at login. They mandate enforceable time, deposit and spend limits, including at least a 24-hour wait before a customer may raise or remove a limit, and require accessible breaks in play, time-outs and alerts.
The standards also prescribe game-operation safeguards. Results must be settled under the applicable game rules; a player must take a separate, deliberate action to begin a new round; and at least 2.5 seconds must elapse between rounds. Platforms must display theoretical RTP as a percentage, while RNGs and game results must be shown to be acceptably random through statistical analysis or generally accepted testing methods.
For live-dealer gambling, the minimum standards require commercial-casino-quality equipment and controls including video surveillance to record dealer activity and protect integrity. They also bar compensated-game behaviour, require cryptographically secure software pseudo-RNGs, and impose information-security controls based on ISO/IEC 27001:2022, alongside PCI DSS requirements for payment providers.
The regime addresses a gap identified in the government’s 2024 regulatory impact statement, which found that offshore online-casino services were not captured by the existing gambling framework. The statement said use of overseas gambling websites rose from about 8,700 people in 2010 to about 132,000 in 2020, while presentations to gambling services linked to online gambling more than doubled from 435 in 2018 to 941 in 2022.
The testing and monitoring requirements remain a discussion draft and may change before they are finalised.
