A live dealer studio is a regulated premises before it is a product. The decision to open one belongs to the operator adding live dealer capability under an MGA or UKGC licence and to the supplier that must show a regulator the physical room, the cameras, the games and the procedures behind the table. Approval is assessed on evidence, not on the software integration alone, and the studio cannot go live until that evidence is complete.
For a studio building a live dealer product, a platform operator adding live tables, or a compliance lead assembling a submission, the useful deliverable is a requirements pack that separates what the licence obliges from what the studio must build. The two live in different places: the regulator states the standard, and the studio has to demonstrate it.
What UKGC RTS 17 requires from a live dealer studio
The Gambling Commission sets out its expectations for remote live dealer operations in its remote gambling and software technical standards. RTS 17 for live dealer studios, last updated in January 2021, is short, but every clause describes something a regulator can walk in and inspect. Its Aim 17A states the principle the rest of the section serves: live dealer operations must be fair and independently auditable.
The equipment clause is about the room itself. Tables, wheels, cards and croupier equipment must be of commercial casino quality, because a studio that films a game is running a casino game, and the physical articles are part of its integrity. A studio that treats the table as a film set has not met the standard.
The people clauses are equally concrete. Staff must be responsible for monitoring the integrity of the operation, and gambling must be supervised by staff who oversee the dealer activity rather than leaving a table unattended on camera. Croupiers must be adequately trained through documented procedures, so the training record is part of the submission and not an internal formality.
The surveillance and control clauses follow from that. CCTV must record all dealer activity, secure areas and equipment must be protected with access controls, and game logs must be maintained and collated so they can be analysed for trends over time. RTS 17 is not asking a studio to invent a monitoring regime; it is asking it to prove the regime already runs and leaves a record.
None of this overlaps with the testing of an RNG game. A live table’s fairness question is different from a certified paytable, and the two routes are documented separately — the casino game certification submission guide covers the laboratory side, which is a related but distinct piece of work.
What MGA requires before a live studio can go live
The Malta Gaming Authority takes the opposite editorial approach: instead of stating a standard and letting the licensee interpret it, it publishes a list of documents a licensee must submit before a new live studio is approved. An operator adding a live casino stream under an MGA licence follows the prior approval requirements and applies through the Licensee Portal using the ‘Technical – New Games’ form, paying a €1,000 fee.
The submission is a defined set of ten documents:
- The location of the studio together with a floor plan.
- A letter from the gaming or government authorities confirming the MGA can inspect the premises.
- A documented procedure for immediate MGA inspector access to the studio.
- All technical infrastructure, including connectivity, described as built.
- A description of the primary gaming server and its replication procedures.
- Real-time replication of live casino data to a Maltese data centre, so the authority holds a live mirror rather than a periodic export.
- A procedure detailing the game data that is available to players.
- A document outlining dealer-to-player interaction, including the responsible gaming and anti-collusion mechanisms that govern it.
- Documentation of all games and their rules.
- A submission of the studio’s general procedures.
Read that list as a design brief, not a filing chore. The live-mirroring clause means the data path is part of the application, the floor plan means the room is drawn before it is furnished, and the game-rule documentation means the catalogue is fixed before a table is opened. The documents force decisions that are hard to make late.
The ongoing audit obligations
Approval is the start of supervision rather than the end of it. The MGA publishes a Live Studio Audit Checklist that maps the areas an inspector will examine once the studio is operating, and the categories read as a standing operational calendar:
- Premises — CCTV, access controls and fire suppression as physical facts about the building.
- Gaming area — CCTV coverage and recording retention, plus the server room as a controlled space.
- Open and close of tables — the card and ball procedures that are followed at the start and end of a live session, with the recording of that process.
- Card games — storage, shuffling, scanning and the decommissioning of cards.
- Roulette — wheel levelling, statistics and the destruction of balls.
- Training room — the space and record where croupiers are trained.
- Responsible gaming — the procedure when a player presents a gambling problem, and how chat is moderated.
- Employees — due diligence, training and rotation.
A studio that only builds for the go-live inspection will fail the second one. The card decommissioning, ball destruction and staff rotation items are recurring tasks, and the audit expects them to have been happening between inspections, evidenced by records rather than by a policy on a wall. This is also where responsible gaming stops being a platform feature and becomes part of a live studio’s engineering, which is why the operator’s own responsible product design requirements and the studio’s chat-moderation procedure need to meet rather than contradict each other.
What the operator must confirm about the studio before integrating
A platform operator can stream a table long before it can defend the product. Before integrating a live dealer studio, the operator should be able to confirm four things from the studio’s own records rather than from a sales conversation.
First, that the studio holds or sits under a licence that covers the market the operator is serving, since an MGA studio and a UKGC studio are not the same product. Second, that the physical and surveillance requirements are met as described in RTS 17 or the MGA checklist, with CCTV coverage, access control and game logs that a regulator can inspect. Third, that the technical documentation — servers, replication, live mirroring and the player-facing data path — matches what the operator is actually connecting to. Fourth, that the responsible gaming and anti-collusion procedures exist and are operational, because a reported problem at a table is a shared exposure.
The integration is the easy part; the evidence pack is what makes it defensible. To build a live dealer studio that meets these requirements from the room up, talk to Wizards about live dealer development and treat the regulatory documents as the specification.
Frequently asked questions
What is UKGC RTS 17?
RTS 17 is the Gambling Commission’s remote gambling and software technical standard for live dealer studios. Its Aim 17A requires live dealer operations to be fair and independently auditable, and its clauses cover commercial casino quality equipment, trained croupiers, staff supervision, CCTV of all dealer activity, access controls and maintained game logs.
How many documents does the MGA require for a new live studio?
The MGA prior approval requirements list ten documents for a new live studio, from the location and floor plan through technical infrastructure, server replication, real-time data mirroring to a Maltese data centre, player-available game data, dealer-to-player interaction procedures, game rules and the studio’s general procedures.
Does a live dealer studio need the same certification as an RNG game?
No. A live dealer studio is assessed as a regulated premises with physical equipment, cameras and operational procedures, while an RNG game is tested as a software build with a certified paytable. The two are documented through different routes, though an operator adding live tables may need both.
What does the MGA live studio audit cover after launch?
The MGA Live Studio Audit Checklist covers premises and CCTV, the gaming area and server room, open and close of tables, card storage and decommissioning, roulette wheel levelling and ball destruction, the training room, responsible gaming and chat moderation, and employee due diligence, training and rotation.
Who is responsible for a studio’s compliance, the operator or the supplier?
The regulator assesses the premises and the licensee that offers the games, but the studio must demonstrate the physical, technical and operational requirements. In practice the supplier holds the evidence and the operator carries the licence obligation, so the studio’s records are what a regulator inspects.
