Gaming is firmly in its algorithmic era. A chatbot answers a player’s complaint, a fraud model flags unusual deposits, and another system helps identify signs of gambling harm, amongst a lot of other things.
A 2026 study sampling 83 gambling companies worldwide found that more than 80% used generative AI, yet almost a third reported having no established responsible AI practices. Meanwhile, the EU AI Act is a horizontal regulation and not an operational manual. Compliance with it alone does not come close to settling every question of responsible AI use.
Malta’s voluntary AI Gaming Charter (the “Charter”) aims to address this gap by translating the broader principles into the sector’s daily decisions in a pragmatic manner. Published jointly by the Malta Gaming Authority and Malta Digital Innovation Authority, the Charter, whilst creating no new legal obligations, complements the EU AI Act and existing gaming rules. Informed by a sector-wide survey, licensee interviews and a targeted consultation, the Charter covers internal AI systems as well as those that interact directly with players, underpinned by the core tenet that an AI tool need not speak to a player to affect one.
The Charter addresses these issues through a set of practical expectations, including meaningful human oversight, the assessment and mitigation of bias and other risks, and the information provided to people affected by its use.
One of the Charter’s most useful distinctions is the one it draws between a human merely being present somewhere in the decision-making process and a human exercising meaningful oversight over what the system is doing. The word ‘meaningful’ carries particular weight here, given that a decision does not become genuinely “human” merely because an employee, perhaps at the end of a long automated chain, presses a green button. If the person reviewing an AI recommendation lacks the understanding or authority to question and overturn it, they become little more than a wrapper around the system.
The Charter thus calls for oversight proportionate to the risk. A human final sign-off does not inherently reduce the scrutiny warranted where AI materially influences the result.
Systems designed without explicit reference to protected characteristics can still reproduce or amplify patterns of unequal treatment through the data they utilise. Fairness is not established by declaring a model to be neutral.
For higher-impact AI systems that materially influence player-facing or player-impacting decisions, operators should document the fairness objective relevant to a particular decision, explain why they chose it, consider which groups may be affected and test and monitor the outcome across different populations and circumstances.
A system used to flag possible gambling harm or perhaps suspicious activity may be valuable, but skewed flags can have tangible effects on individuals. The Charter therefore calls for continued monitoring of outcomes to identify and address emerging bias or discriminatory patterns.
Transparency means giving people materially affected by an AI-supported decision meaningful information about the system’s role and the outcome, where required or appropriate. It does not require publishing source code or revealing the logic that helps detect fraud and money laundering. The aim is an explanation people can use, while preserving the controls that keep gaming operations secure.
One of the more salient tasks for any licensee aiming to align its practices with the Charter is to establish an AI inventory. This involves mapping the systems bought, built and used across the organisation, which include any instances of ‘shadow AI’ adopted informally by teams and tools embedded in third-party products. Further, identify who owns each use case, what data it handles and whether it can affect players or regulated outcomes. From there, set proportionate policies, assign risk ownership and take practical steps to build staff AI literacy, so those using AI know when its output deserves challenge.
For any additional information or assistance, please contact us at info@gtg.com.mt
Author: Dr J.J. Galea