Guidance on game types
Several gambling suppliers/licence holders contact the Danish Gambling Authority when they want to offer a new type of game.
The Danish Gambling Authority would like to emphasise that we cannot pre-approve games, but only provide guidance on our interpretation of the rules or a given type of game. Thus, it is the game supplier and the licence holder themselves who must assess whether a game may be supplied and offered with their respective licence(s).
The Danish Gambling Authority regularly supervises games offered on the Danish market. Therefore, game suppliers/licence holders will receive a letter of consultation if the Danish Gambling Authority identifies games that is deemed to fall outside the scope of the respective licence.
The technical assessment
When a game supplier or licence holder uploads a game in the Danish Gambling Authority's game portal, an assessment is made solely of whether the game complies with the technical requirements.
Thus, as a general rule, a legal assessment is not made as to whether a game can be offered legally in Denmark.
The purpose of the game portal is to ensure that all games comply with the technical requirements.
These requirements are set out in "SCP.07 Requirements for games" in the Danish Gambling Authority's certification programme for betting and online casino. Although it is possible to test and inspect a game according to a specific game category in accordance with the requirements of the certification programme, this does not necessarily mean that the game may be offered on the Danish market. Therefore, it is important that the game supplier/licence holder also has a legal assessment made of the given game.
It is also noted that licence holders should always contact the Danish Gambling Authority if they are in doubt about how data for a given game should be reported.
Combination games
If you have a licence for online casino, it is possible to offer combination games.
A combination game is a game where the chance of winning is based on a combination of skill and chance. It is the gambling operator and the licence holder themselves who must assess whether a game can be categorised as a combination game, but it is the Danish Gambling Authority's assessment that the skill element must not be illusory.
An example of a game type where the Danish Gambling Authority has seen versions that can be considered a combination game is "Slingo". In these versions, we have determined that the skill element is sufficient for the game to be a combination game. The player must place so-called "wilds" on their game board and thus make strategic choices that help generate the result, which is deemed to constitute a sufficient element of skill. The Danish Gambling Authority points out that the choice must be a mandatory part of the game in order to constitute the skill element.