Malta sets out voluntary AI safeguards for licensed gambling operators

The Malta Gaming Authority (MGA) and Malta Digital Innovation Authority (MDIA) have published a voluntary framework governing the use of artificial intelligence by Malta-licensed gambling companies.

The AI Gaming Charter provides sector-specific guidance for systems used in certain areas. These are player protection, fraud detection, anti-money laundering, customer support and operational decision-making. It does not introduce additional legal obligations but is intended to help licensees apply existing legislation to gambling-related uses of AI.

Licensees encouraged to map their AI systems

Companies adopting the charter are encouraged to maintain an inventory of the AI systems they develop, procure or deploy. Operators should identify whether they act as a provider or deployer under the EU AI Act. This is because their responsibilities will depend on their role and the risk classification of the technology.

The framework covers customer-facing and internal systems. However, it recommends proportionate controls based on each tool’s potential impact.

Administrative tools and coding assistants may require lighter oversight. Systems affecting players, regulatory compliance, player protection or gambling integrity should be subject to stronger governance and monitoring.

Licensees are also encouraged to nominate staff from areas such as compliance, data or technology to oversee implementation of the charter.

Human oversight required for sensitive decisions

The framework places human oversight at the centre of its recommendations. This is particularly important when  AI informs decisions capable of significantly affecting players. This includes account restrictions, gambling harm interventions and other player-protection measures. In these circumstances, technology should support, not replace, human judgement.

Operators should establish escalation procedures and maintain records explaining how higher-risk systems are used. Regular testing should also determine whether tools remain accurate, reliable and suitable for their intended purpose.

“Our role as a regulator is not to stand in the way of innovation, but to help create the certainty and confidence needed.” — Charles Mizzi, chief executive of the Malta Gaming Authority

Players should know when AI is being used

The charter recommends that customers are told when they are interacting with an AI-powered system. AI-generated or manipulated content, including deepfakes, should also be disclosed in line with the transparency provisions of the EU AI Act.

However, the MGA distinguishes between information provided to regulators and information made publicly available. Operators would not be expected to expose proprietary algorithms or security-sensitive data unnecessarily. Companies should also document the source and quality of data used by their systems. They are encouraged to monitor results for bias while following GDPR principles including data minimisation, accuracy and purpose limitation.

Environmental impact enters AI debate

Environmental sustainability also features in the guidance. This reflects concerns about the energy required to train and operate AI models. Licensees are advised to investigate suppliers’ energy practices, consider carbon emissions during procurement and use appropriately sized models rather than unnecessarily resource-intensive systems.

Research included in the charter found that adoption remains uneven across Malta’s gambling sector. Some companies are still testing AI. Others have reached minimum viable product stage in areas including responsible gambling modelling, fraud detection, KYC, payments and player acquisition.

The MGA said the framework had been developed through surveys, discussions with licensees and an industry consultation. It will act as a common reference point as AI becomes more widely embedded across regulated gambling operations.