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Spillemyndigheden (Danish Gambling Authority) — Standards Explorer
All 61 Danish standards, organised by theme
A searchable, filterable index of Denmark's remote-gambling rulebook, drawn from Spilleloven (Consolidation Act 1182/2025), Executive Orders 682 and 684 of 11 June 2025 on online casino and online betting (as amended by BEK 1827 of 29 December 2025), Spillemyndigheden's Standards Compliance Programme (SCP), the AML Act (1463/2025) and the DGA's operator guidelines. Standards tied to EO 682 and EO 684 carry per-standard verbatim provenance blocks citing retsinformation.dk. Standards are grouped by theme, tagged editorially, and deep-linkable.
Editorial summary, not legal advice. Every card on this page is a plain-English summary of the regulator's own rule, cross-checked against the primary source. Always verify against the published text before filing, launching, or advising.
The four statutory purposes of Spilleloven — moderate consumption, youth and vulnerable protection, fair and transparent play, and crime prevention — and the licence, age and credit rules that anchor every downstream obligation.
9 standards9 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Offering gambling in Denmark without a DGA licence
Onboarding or transacting with under-18 customers
Extending credit to players or accepting third-party credit deposits
Spilleloven (Consolidation Act 1182/2025) 9
§ 1
Statutory purposes of the Gambling Act
RG CriticalPlayer Rights
Section 1 sets out the four statutory purposes against which all operator conduct is measured: (1) keep gambling consumption at a moderate level; (2) protect young people or other vulnerable persons from being exploited through gambling or developing an addiction to gambling; (3) protect players by ensuring games are offered in a fair, responsible and transparent manner; and (4) ensure public order and prevent gambling from serving as a support for crime.
Requirements
Align internal policies and governance with the four statutory purposes (§ 1)
Demonstrate that product, marketing and RG decisions trace back to one or more § 1 purposes
Treat § 1 as the interpretive lens when applying downstream duties (§§ 26, 33, 34, 35, 36)
Reflect the four purposes in staff training, onboarding and supplier due-diligence materials
§ 14
Licence requirement for online casino and betting
Player RightsGame Design
The offering or arranging of games in Denmark requires a permit from the Danish Gambling Authority (§ 3). Betting permits are granted under § 11 and online casino permits under § 18, each for up to five years at a time. Game suppliers to § 11 or § 18 licensees must themselves hold a § 24 a permit. Applicants (and, for companies, beneficial owners and management) must also satisfy the fit-and-proper conditions of §§ 26, 28 and 29.
Requirements
Hold a valid permit before offering or arranging games in Denmark (§ 3)
Use a § 11 permit for betting and a § 18 permit for online casino; renew at least every 5 years (§ 11(2), § 18(2))
Source games only from § 24 a licensed game providers, or self-provide under § 18(5) / § 11(6)
Satisfy fit-and-proper conditions for the applicant and, for companies, for beneficial owners and the management/board (§§ 26, 28)
Demonstrate the ability to carry out gaming activities in an economically and professionally sound manner (§ 29)
Notify the DGA immediately of significant changes to licence conditions (§ 29(3))
§ 26
Minimum age 18
RG CriticalBonus & Ads
Section 34 prohibits receiving bets from, or otherwise communicating participation by, persons under 18. A narrow exception in § 34(3) permits contributions from persons aged 16+ for land-based lotteries and class lotteries under §§ 6 and 8. Separately, § 26(1)(1) requires operator-side applicants to be at least 21 — this is an operator fit-and-proper condition, not a player age.
Requirements
Block account creation, deposits and play for anyone under 18 (§ 34)
Do not 'communicate' under-18 participation in games (e.g. targeted promos, referrals, account links) (§ 34)
Apply the narrow 16+ carve-out only to § 6 / § 8 land-based lotteries and class lotteries (§ 34(3))
Ensure marketing communication design and media selection are not targeted at children and young people under 18 (§ 36(3))
Ensure operator applicants, beneficial owners and management are at least 21 years old (§ 26(1)(1), § 28)
§ 36
Prohibition on operator credit
RG CriticalPlayer Rights
Section 35 prohibits a licensee from granting the player credit for participation in games. Stakes must be funded from the player's own already-deposited balance; structures that advance play against a future deposit, unsettled cashback or third-party finance are inconsistent with this statutory rule.
Requirements
Do not grant players credit for participation in games (§ 35)
Require cleared, player-funded deposits before stake is accepted (§ 35)
Do not advance stake against a future deposit, pending withdrawal reversal, or unsettled cashback (§ 35)
Decline third-party payment instruments that effectively extend credit on the player's behalf (§ 35)
Train payments, VIP and CRM staff on the § 35 no-credit rule and audit bonus/cashback mechanics against it
§ 36
Marketing of games — fairness, no under-18 targeting, no celebrity misrepresentation
Bonus & AdsRG CriticalPlayer Rights
Section 36 sets five cumulative marketing rules: the chance of winning must be presented correctly and in a balanced way; games must be produced as an entertainment offer; neither communication design nor media selection may target children and young people under 18; celebrity endorsements must not falsely imply that gambling contributed to the celebrity's success; and content must not imply that gambling solves financial problems or confers social acceptance.
Requirements
Present odds and chance of winning correctly and in balance — no 'too good to miss' framing (§ 36(1))
Position games as entertainment, not as income or investment (§ 36(2))
Avoid creative, talent, channels and placements targeted at under-18s (§ 36(3))
When using famous personalities, do not imply their success is linked to gambling (§ 36(4))
Do not imply participation solves financial problems or brings social acceptance (§ 36(5))
Pre-clear campaigns against the five-point § 36 test and retain evidence for DGA inspection
§ 46 / § 47 / § 49 a
DGA supervision, inspection powers and injunctions
Player RightsRG Critical
The Danish Gambling Authority supervises compliance with the Act, rules made under it, and individual licence terms (§ 46). Inspectors may, upon proper identification and without a court order, inspect licensee and game-provider premises and technical facilities, books, accounting material, correspondence and other documents — whether on paper or electronic media (§ 47). The DGA may issue injunctions requiring unlawful matters to be put in order or to cease immediately or within a specified period (§ 49 a); non-compliance with a § 49 a decision is a ground for licence revocation under § 44.
Requirements
Keep all gambling-related books, records, correspondence and technical logs available for DGA inspection in paper or electronic form (§ 47)
Grant DGA inspectors on-site access on proper identification without requiring a court order (§ 47)
Treat DGA § 49 a injunctions as immediately binding and track remediation against any specified deadline
Route § 46 / § 49 a correspondence to a named compliance owner and escalate to the board
Recognise that non-compliance with a § 49 a injunction is a ground for revocation under § 44
§ 63 a
Public register of fines and convictions
Player RightsAffiliate Rules
Section 63 a requires the Danish Gambling Authority to publish fines, convictions and partial convictions (or summaries thereof) for violations of the Act and regulations issued under it, naming the company or personally owned enterprise concerned. Publications remain on the DGA website for 5 years.
Requirements
Anticipate that any fine or conviction under the Act will be publicly named on the DGA website for 5 years (§ 63 a(1)–(2))
Track incidents that could lead to § 63 a publication and escalate through the board and investor-relations processes
Prepare holding statements and player communications for potential § 63 a publication events
Include § 63 a exposure in enterprise risk and reputational-risk registers
§ 65
Prohibition on payment processing and communication with illegal operators
Affiliate RulesPlayer RightsRG Critical
Section 65 prohibits the payment processing of stakes and winnings to and from an illegal gaming provider, as well as the transmission of information on a communication network to an illegal gaming system. Licensees, payment partners and affiliates operating in the Danish market must ensure their commercial and technical arrangements do not route bets, winnings or traffic to unlicensed providers.
Requirements
Do not process payments of stakes or winnings to or from an illegal (unlicensed) gaming provider (§ 65)
Do not transmit information on a communication network to an illegal gaming system (§ 65) — covers affiliate linking, APIs and redirects
Screen affiliate, payment and marketing partners against the DGA illegal-operator list before onboarding and on renewal
Include § 65 compliance warranties in affiliate, PSP and aggregator contracts
Monitor for pass-through / relay arrangements that would effectively connect Danish players to unlicensed sites
§ 59
Criminal penalty for unlicensed offering of games
Affiliate RulesPlayer Rights
Section 59 criminalises the intentional or grossly negligent offering, arranging or supplying of games in Denmark without a permit under the Act, with a sanction of a fine or imprisonment for up to six months. This establishes personal criminal exposure for officers of unlicensed operators and is the backstop to the § 3 permit requirement.
Requirements
Do not offer, arrange or supply games in Denmark without a valid permit (§ 3, § 59)
Treat 'supplying' broadly — B2B game supply into the Danish market requires a § 24 a permit
Escalate any product, feature or geo-expansion that could be construed as an unlicensed Danish offer to legal before launch
Document the due diligence used to conclude an activity falls outside § 2 scope, to rebut gross-negligence allegations
Note that § 59 exposure is in addition to § 63 a public publication of any resulting fine
B
Theme B
Executive Order on online casino (EO 682/2025)
The operational rulebook for DGA-licensed online casino operators under Executive Order No. 682 of 11 June 2025 (as amended by BEK 1827 of 29 December 2025), covering registration, electronic ID, player funds, on-screen clock, deposit limits, monitoring, self-exclusion, sales promotions, closure payouts and the 3-second minimum game-execution rule for § 18(3) permits.
13 standards13 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Opening accounts without electronic-ID verification at the § 7 triggers
Pre-filling deposit limits or denying the daily / weekly / monthly choice under § 21
Commingling player funds with operating capital in breach of § 11 non-offsetting-account duty
Exceeding the DKK 1,000 sales-promotion cap or the 10x wagering ceiling in § 29
Delaying closure payouts beyond the 5 working days required by § 31
Executive Order 682/2025 — Online casino (verbatim-audited 2026-04-18) 13
EO 682 § 2
Customer registration and identity verification
RG CriticalPlayer Rights
To participate in an online casino, a player must be registered as a customer with the licensee. Only natural persons may be registered. The licensee must obtain the customer's name and social security number (or equivalent) and confirm it with documentation, with the scope of documentation set by risk assessment.
Requirements
Register every online-casino player as a customer before play
Register only natural persons, acting exclusively on their own behalf
Obtain name and social security number (or equivalent) and verify with documentation
Scale documentation depth to a documented risk assessment
Re-identify where previously obtained identity information is in doubt
EO 682 § 5
Gaming account information and 90-day history
Player Rights
The licensee must create a gaming account for each registered player and provide access to the balance, gaming history (bets, winnings, losses), deposits and withdrawals. That information must be available to the player for at least 90 days. Account statements must be provided on request and no inactivity fee may be charged.
Requirements
Create a gaming account for every registered player
Expose balance, bets, winnings, losses, deposits and withdrawals to the player
Keep that information available in-account for at least 90 days
Provide full account statements on player request
Do not charge fees based on account inactivity
EO 682 § 6
Temporary gaming account (DKK 10,000 deposit cap, no payouts)
RG CriticalPlayer Rights
Until identity is verified, only a temporary gaming account may be opened. Deposits into a temporary account may not exceed DKK 10,000. Funds cannot be paid out from a temporary account. If documentation is not submitted within 30 days of request the temporary account must be closed. A temporary account cannot be created for a player listed in ROFUS.
Requirements
Open only a temporary account until Section 2 identity verification is complete
Cap temporary-account deposits at DKK 10,000
Do not permit any payout from a temporary account
Close a temporary account if documentation is not supplied within 30 days
Block temporary-account creation for any player registered in ROFUS
EO 682 § 7
Electronic ID for account creation, new-device login and transactions
RG CriticalPlayer Rights
The licensee must ensure an electronic ID is used when creating a gaming account, on first login from a new device, and when changing registration information. The electronic ID must come from a Danish national identification scheme or a DGA-approved scheme, with a security level of significant or higher. Deposits, withdrawals and changes to the payment instrument must also use electronic ID or strong customer authentication under the Payments Act.
Requirements
Require electronic ID for account creation, new-device login and info changes
Use a Danish national eID or a DGA-approved eID, security level 'significant' or higher
Require electronic ID (or PSD2 strong customer authentication) for deposits and withdrawals
Verify that the electronic ID belongs to the registered player
Reliably identify the player through another means if registered without a CPR number
EO 682 § 11
Player funds held in a non-offsetting bank account
Player RightsRG Critical
Funds held in players' gaming accounts are entrusted funds that must be deposited in a non-offsetting bank account separate from the licensee's own funds, to which only the licensee has access. The funds may only be paid out to the player and must be secured against the licensee's insolvency. The non-offsetting account must at all times hold at least the total amount across all player gaming accounts.
Requirements
Deposit player funds in a bank account that is non-offsetting against licensee debts
Keep player funds strictly separate from the licensee's own operating funds
Only pay player funds out to the player — never to cover licensee obligations
Secure player funds against the licensee's insolvency
Ensure the non-offsetting account balance at all times equals or exceeds total player-gaming-account balances
EO 682 § 17
On-screen clock visible at all times
RG Critical
A clock must be available on the licensee's website to allow the player to monitor the time spent on the game page. The clock must be easily visible to the player at all times.
Requirements
Display a clock on the licensee's website / play surface
Ensure the clock is easily visible to the player at all times
Do not hide the clock behind game overlays, full-screen or auto-play states
EO 682 § 21
Mandatory deposit limit (daily, weekly or monthly — player's choice)
RG Critical
A player must set a deposit limit before gaming can commence. The player must be able to choose whether the limit is daily, weekly or monthly. Apart from an upper cap, the amounts must not be predetermined by the licensee. A player's request to increase a previously set deposit limit may not take effect until 24 hours have passed.
Requirements
Block play until the player has actively set a deposit limit
Let the player choose whether the limit is daily, weekly or monthly
Do not pre-fill the limit value, apart from an upper ceiling chosen by the licensee
Apply any limit-increase request only after a 24-hour waiting period
Apply a limit-decrease request without the 24-hour wait (verbatim text constrains only increases)
EO 682 § 22
Monitoring of gambling behaviour, written internal rules and staff training
RG Critical
The licensee must familiarize itself with the player's gambling patterns and take measures to prevent and stop the development of problematic gambling behaviour and gambling addiction. The licensee must maintain written internal rules and procedures covering duty of care, recording, storage of information about gambling behaviour and player risk assessment. Training and instruction programmes are required for relevant employees. Behaviour and risk-assessment information must be retained for 5 years.
Requirements
Actively monitor gambling patterns and intervene where problem-gambling indicators arise
Maintain written internal rules on responsible gambling, duty of care and recording
Record and store player gambling-behaviour information and risk assessments
Retain gambling-behaviour and risk-assessment information for 5 years
Operate a training and instruction programme for employees involved in player contact or behaviour analysis
Ensure such employees are made aware of and apply the internal rules
EO 682 § 23
Self-exclusion function with 24-hour cooling-off and 30-day minimum temporary exclusion
RG CriticalPlayer Rights
The licensee must provide a function enabling the player to request temporary or permanent exclusion from the licensee's games. A temporary exclusion cannot be less than 30 days, however the player must also have the option of a 24-hour short-term break (cooling-off period). Permanent exclusion closes the gaming account and terminates the customer relationship; the player may not re-register until at least 1 year after account closure. Players who self-exclude must be informed of counselling and treatment options at a Danish treatment centre.
Requirements
Offer an in-client function to request temporary or permanent self-exclusion
Make available a 24-hour cooling-off short break in addition to temporary exclusion
Set temporary exclusion to a minimum of 30 days
On permanent exclusion, close the gaming account and terminate the customer relationship
Block re-registration of a permanently-excluded player for at least 1 year after closure
Inform the self-excluding player of counselling and treatment at a Danish treatment centre
A sales-promotion measure may not have a value or average value of more than DKK 1,000. A deposit or stake requirement to obtain the promotion must correspond to 100% of the awarded promotion value. The wagering requirement may not exceed 10x the value of the deposit plus awarded amount combined. Winnings won through the promotion carry no wagering requirement. Eligible games must contribute 100% toward the play-through. The player must have a minimum of 60 days to fulfil any conditions. If wagering applies, a concrete amount example must be shown in the offer.
Requirements
Cap any promotion's value (or average value) at DKK 1,000
Require deposit or stake equal to 100% of the awarded promotion value
Cap wagering requirements at 10x the combined deposit plus awarded amount
Apply no wagering requirement to winnings won through the promotion itself
Allow the player at least 60 days to complete any wagering conditions
Require contributing games to count 100% toward the play-through
Show a worked wagering-amount example in the offer, in the play currency
EO 682 § 30
Promotions must be offered to at least 100 players on the same terms
Bonus & AdsPlayer Rights
Promotions may not be offered to individual players on terms that differ from those offered to others. They must be offered to all players who play within the same specified amount range or meet another criterion. The range or criterion must be set so that the promotion is offered to at least 100 players. A player's inactivity may not be a selection criterion for promotions.
Requirements
Do not run single-recipient or bespoke promotional offers
Set the segment so that at least 100 players qualify for any promotion
Use consistent terms across all eligible players in the segment
Do not target players based on their inactivity with the licensee
EO 682 § 31
Payout within 5 working days of account closure (no fee)
Player Rights
When closing a gaming account, the licensee must pay the balance from the player's gaming account to the player as soon as possible and no later than 5 working days after closure. No fee may be charged for the closure. Where a temporary account is closed under § 6(2), only deposited funds may be returned; winnings accrue to the licensee. Licensee-initiated closures must carry a reasoned decision with documentation to the player, with a copy to the DGA.
Requirements
Pay the remaining balance to the player within 5 working days of closure
Never charge a fee for closing a gaming account
On § 6(2) temporary-account closure, return only deposited funds; treat winnings as licensee's
Send a reasoned decision with documentation to the player on licensee-initiated closure
Send the DGA a copy of any licensee-initiated closure decision
EO 682 § 35(5)
Minimum 3 seconds between game executions (§ 18(3) permits only)
Game DesignRG Critical
For a permit issued pursuant to § 18(3) of the Gambling Act, the gaming system must ensure that a minimum of 3 seconds elapse between each execution of a given game, where 'execution' means the time from the start of the game until the result is presented to the player.
Requirements
For § 18(3) permits, enforce at least 3 seconds between successive game executions
Measure 'execution' as start of game to presentation of the result
Disable any auto-play or rapid-replay path that would breach the 3-second floor
C
Theme C
Executive Order on online betting (EO 684/2025)
The operational rulebook for DGA-licensed online betting operators under Executive Order No. 684 of 11 June 2025, plus the separate Executive Order 43/2025 on match-fixing. EO 684 shares most of its structure with EO 682 (registration, eID, funds, RG, self-exclusion, promotions, closure) but uses its own section numbering.
11 standards11 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Treating EO 684 as identical to EO 682 and citing wrong section numbers in controls
Missing the 24-hour cooling-off option alongside the 30-day temporary exclusion under § 17
Bonus offers exceeding DKK 1,000 or 10x wagering under § 22
Missing suspicious-bet escalation to the national match-fixing secretariat under EO 43/2025
Executive Order 684/2025 — Online betting (verbatim-audited 2026-04-18) 11
EO 684 § 7
Electronic ID for betting account creation and transactions
RG CriticalPlayer Rights
The licensee must ensure an electronic ID is used when creating a betting account, on first login from a new device, and when changing registration information. The electronic ID must be from a Danish national identification scheme or a DGA-approved scheme with security level significant or higher. Deposits, withdrawals and changes to the payment instrument must also use electronic ID or PSD2 strong customer authentication.
Requirements
Require electronic ID for account creation, new-device login and info changes
Use a Danish national eID or DGA-approved eID at security level 'significant' or higher
Require electronic ID or PSD2 SCA for deposits, withdrawals and payment-instrument changes
Verify that the electronic ID belongs to the registered player
EO 684 § 15
Deposit limit before play (daily, weekly or monthly — player's choice)
RG Critical
For online betting, a player must set a deposit limit before gaming can commence, choosing whether the limit is daily, weekly or monthly. Amounts (apart from an upper cap) must not be predetermined by the licensee, and a request to increase a previously set limit may not take effect for 24 hours.
Requirements
Block betting until a deposit limit is actively set
Let the player choose daily, weekly or monthly
Do not pre-fill the limit value apart from an upper ceiling
Delay any limit-increase request by 24 hours
EO 684 § 17
Betting self-exclusion: 24-hour cooling-off, 30-day minimum, permanent with 1-year bar
RG CriticalPlayer Rights
The licensee must provide a function enabling the player to request temporary or permanent self-exclusion. Temporary exclusion cannot be less than 30 days, alongside a 24-hour cooling-off option. Permanent exclusion closes the account and terminates the customer relationship, with re-registration barred for at least 1 year. The licensee must inform self-excluding players of counselling and treatment at a Danish treatment centre.
Requirements
Provide an in-client self-exclusion function for betting
Offer a 24-hour cooling-off short break in addition to temporary exclusion
Enforce a 30-day minimum for temporary exclusion
Close the account and terminate the relationship on permanent exclusion; bar re-registration for 1 year
Inform self-excluding players of counselling and treatment at a Danish treatment centre
For online betting, promotional offers are subject to the same structural rules as online casino: value capped at DKK 1,000, wagering ≤ 10x, deposit/stake must be 100% of the awarded amount, winnings from the promotion carry no wagering, and the player has at least 60 days to fulfil conditions.
Requirements
Cap betting promotion value (or average value) at DKK 1,000
Cap wagering at 10x deposit plus awarded amount combined
Apply no wagering to winnings won through the promotion itself
Allow at least 60 days to satisfy any conditions
Show a worked wagering-amount example in the offer
EO 684 § 24
Betting account closure: payout in 5 working days, no fee
Player Rights
When closing a betting account, the licensee must pay the balance to the player as soon as possible and no later than 5 working days after closure. No fee may be charged. Where the licensee initiates closure, a reasoned decision with documentation must be sent to the player, with a copy to the DGA.
Requirements
Pay the betting-account balance within 5 working days of closure
Charge no closure fee
Send a reasoned decision with documentation to the player on licensee-initiated closure
Copy the DGA on any licensee-initiated closure decision
Betting-licence holders must identify and assess the risk of being misused for match-fixing. The assessment must be based on the licensee's business model and cover risk factors related to players, betting offers, stakes, payment methods, delivery channels and conflicts of interest. It must be documented and kept continuously up to date. Written policies, procedures and controls (§ 4(1)) and mandatory staff and retailer training (§ 4(2)) operationalise the assessment.
Requirements
Produce and maintain a documented match-fixing risk assessment tied to the operator's business model
Cover players, betting offers, stakes, payment methods, delivery channels and conflicts of interest as risk factors
Update the assessment on a continuous basis, not only at licence renewal
Translate the assessment into written policies, procedures and controls covering risk management, CDD, investigation/recording/notification duties, staff screening and internal control (§ 4(1))
Deliver adequate match-fixing training to employees, betting retailers and retailer staff (§ 4(2))
The licensee must ensure that beneficial owners, board members, executives, persons involved in setting odds, and their close relations do not place bets with the licensee. Where odds-setting is outsourced, the licensee must ensure the supplier does not allow its oddsmakers to bet with the licensee. Separately, persons participating in an event may not be involved in setting odds on that event.
Requirements
Maintain a register of beneficial owners, directors, executives, oddsmakers and their close relations, and block them from betting accounts with the licensee
For outsourced odds-setting, obtain contractual and operational assurance that the supplier's oddsmakers do not bet with the licensee (§ 5(2))
Never involve an event participant in setting odds on that same event (§ 6)
Evidence control effectiveness under § 4 policies and internal control
EO 43/2025 § 8
DGA athlete-watchlist screening and enhanced CDD (EO 43/2025 §§ 7–8)
Player RightsRG Critical
The DGA (Spillemyndigheden) maintains a list of athletes in Denmark who may influence the outcome of a sporting event on which bets are offered, containing name, date of birth, sport and club. At onboarding, licensees must screen new players against the list; after onboarding they must screen on an ongoing basis. Enhanced customer-due-diligence procedures apply where risk is elevated, including where the player is on the list, bets mainly on higher-risk events, is support personnel (coaches, managers, agents, team staff, officials, doctors, other medical personnel, parents), places unusual stakes relative to what is known about them or the event, or where criminal activity is suspected.
Requirements
Screen every new customer against the DGA athlete watchlist at account opening (§ 8(1))
Run ongoing screening against the watchlist for existing customers (§ 8(2))
Trigger enhanced CDD on watchlist hits, high-risk event concentration, support-personnel status, unusual stakes, or criminal-activity suspicion (§ 8(3))
Process watchlist personal data under GDPR Art. 6(1)(e) public-task basis (§ 7(2))
EO 43/2025 § 9
Detection system and mandatory refusal of suspicious stakes (EO 43/2025 §§ 9–10, § 12)
Game DesignPlayer Rights
The betting system must be configured so the licensee is able to identify suspicious betting behaviour linked to match-fixing. The licensee must refuse to accept a stake on a bet where it knows of, or has reasonable suspicion of, match-fixing. Where a bet is under investigation for match-fixing, the licensee must withhold payout if it cannot be ruled out that the player had knowledge of the fix — payout may be released only if withholding would harm an investigation (§ 12). Investigation findings must be recorded and retained for 5 years (§ 11(2)).
Requirements
Design and maintain the gaming system to detect suspicious match-fixing betting patterns (§ 9)
Refuse stakes where match-fixing is known or reasonably suspected (§ 10)
Investigate immediately on knowledge, suspicion or reasonable grounds to suspect match-fixing (§ 11(1))
Retain investigation records for 5 years (§ 11(2))
Freeze payouts during match-fixing investigations unless release is necessary to avoid harming the investigation (§ 12)
Investigate on receipt of DGA alert information and decide on stake refusal (§ 13)
EO 43/2025 § 14
Immediate notification of match-fixing suspicion to the DGA (EO 43/2025 § 14)
Player RightsRG Critical
The licensee must immediately notify Spillemyndigheden (the DGA) where it knows of, suspects, or has reasonable grounds to suspect that a bet or event has or has had a connection to match-fixing. The duty applies even where the bet(s) were not placed or carried out. Notification must be filed digitally in Danish or English and must include a description of the factual circumstances together with supporting documentation.
Requirements
File a notification to the DGA immediately on knowledge, suspicion or reasonable grounds to suspect match-fixing (§ 14(1))
Notify even where the bet was not concluded (§ 14(2))
Submit digitally in Danish or English, with facts and supporting documentation (§ 14(3))
Do not rely on a 'national match-fixing secretariat' as the recipient — BEK 43/2025 designates Spillemyndigheden
Licensees must operate a special, independent and autonomous channel through which employees can report breaches, or potential breaches, of the executive order committed by the licensee — including by employees, beneficial owners, board members, executives and persons involved in setting odds. Reports must be capable of being made anonymously. The scheme applies to licensees with more than five employees and must be in place no later than three months after the sixth employee is hired. Employees and former employees must not suffer adverse treatment or consequences for reporting; non-disclosure agreements must preserve the right to report to public authorities; personnel handling reports are bound by confidentiality.
Requirements
Stand up an independent, autonomous whistleblower channel supporting anonymous reports (§ 15(1))
Apply the scheme once headcount exceeds five, within 3 months of the sixth hire (§ 15(3))
Prohibit retaliation against reporting employees or former employees (§ 16(1))
Ensure any NDA clause carves out the right to report to public authorities (§ 17(1))
Bind staff handling reports to confidentiality (§ 18)
The DGA's technical rulebook, refreshed in February 2025 — RNG, base platform, game requirements, SAFE data warehouse, TamperToken and, from 1 January 2025, a separate B2B supplier licence for any company providing games to Danish-licensed operators.
6 standards6 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Launching games or platform changes without current SCP certification
Gaps or tampering in the SAFE data feed to the DGA
Unlicensed B2B supply into the Danish market
SCP technical certifications 6
SCP.01.00
Random Number Generator (RNG) requirements
Game Design
Random Number Generators used for casino games must be independently certified to the DGA's statistical and security requirements before go-live. From 2026, recertification is triggered by changes affecting compliance rather than an automatic annual cycle.
Requirements
Use a certified RNG that meets the DGA's statistical requirements
Submit test reports from an accredited testing laboratory
Document entropy sourcing and reseeding behaviour
Recertify on any change that affects compliance, per the 2026 policy
SCP.02.00
Base platform requirements
Game DesignPlayer Rights
The operator's base platform — covering player-account handling, transaction ledgers and session management — must meet the DGA's baseline set out in SCP.02.00 (February 2025 edition).
Requirements
Maintain a single identifiable player account with no duplicates
Keep an immutable transaction log for all wagers, wins and transfers
Use secure, synchronised time across all system components
Apply role-based access controls for all administrative functions
Document disaster-recovery and business-continuity arrangements
SCP.07.03
Requirements for games — online casino
Game DesignRG Critical
Each online-casino game must comply with SCP.07.03 on stake and win display, theoretical return-to-player disclosure, and prohibited mechanics.
Requirements
Publish the theoretical return-to-player for every game
Display stake and win values in real currency without ambiguity
Prohibit features that obscure loss, including misleading near-miss animations
Allow the player to interrupt play at any time without penalty
Recertify on any game change that affects compliance
SCP — SAFE
SAFE data warehouse reporting
Game DesignPlayer Rights
Operators must transmit gambling data — accounts, bets, deposits, withdrawals and exclusion events — to the DGA's SAFE data warehouse on a continuous basis for supervision and reconciliation.
Requirements
Implement the SAFE feed per DGA specification
Reconcile transmitted data against source systems daily
Tag self-exclusion and limit events so SAFE can correlate them
Preserve raw underlying records for DGA inspection
Give DGA continuous access to the SAFE feed
SCP — TamperToken
TamperToken integrity signing
Game Design
Outbound regulatory reports must be signed using the TamperToken mechanism so the DGA can detect tampering and verify provenance.
Requirements
Sign every outbound report with TamperToken per DGA specification
Rotate signing keys on the prescribed cadence
Alert operations on signing failures and remediate before resuming
Preserve signed originals alongside any derivative extracts
B2B licence
B2B game-supplier licence (from 1 January 2025)
Game Design
Since 1 January 2025, suppliers of games to Danish-licensed B2C operators must themselves hold a DGA supplier licence, bringing the supply chain inside the inspection and AML perimeter.
Requirements
Apply for and hold a DGA B2B supplier licence before any supply to Danish operators
Maintain fit-and-proper standards for owners, directors and key functions
Submit to DGA inspection and cooperate on SCP certification for supplied games
Notify the DGA of changes of control or material change to supply scope
E
Theme E
ROFUS — central self-exclusion register
Denmark's distinctive national self-exclusion register, ROFUS, sits at the heart of the responsible-gambling regime and also carries a 'No thank you to marketing' flag that operators must honour across every channel and every affiliate.
3 standards3 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Allowing a ROFUS-excluded player to log in, deposit or play
Direct-marketing to a ROFUS-flagged player via any channel
Affiliates or ad networks breaching the suppression list on the operator's behalf
ROFUS obligations 3
ROFUS — Lookup
Pre-session ROFUS lookup
RG Critical
Before allowing a player to log in or deposit, operators must check the player against ROFUS in real time and block access for any excluded player.
Requirements
Call the ROFUS API on every login and before every deposit
Block login and deposit if the player is excluded
Do not permit workaround accounts that bypass ROFUS
Log every ROFUS lookup with timestamp and outcome
Re-check on return after significant inactivity
ROFUS — Registration
Registration pathway on the operator site
RG Critical
Operators must enable players to register for temporary or permanent ROFUS exclusion directly from their platform, without friction or dissuasion.
Requirements
Expose a visible ROFUS link on all player-facing surfaces
Deep-link to rofus.nu or provide an in-platform equivalent flow
Do not introduce friction, retention messaging or upsell at the exclusion step
Confirm in the player account once the exclusion is registered
ROFUS — Marketing suppression
"No thank you to marketing" compliance
RG CriticalBonus & AdsAffiliate Rules
ROFUS registration also flags a player as opted out of gambling marketing. Operators must suppress all direct marketing to that player and extend the suppression to affiliates acting on their behalf.
Requirements
Suppress email, SMS, push and in-app gambling marketing to ROFUS-flagged players
Check the suppression list before every campaign send
Retain evidence of suppression for regulator inspection
Apply the same suppression to affiliate marketing carried out on the operator's behalf
F
Theme F
Responsible gambling & player protection
DGA label visibility, StopSpillet helpline access, pre-play risk information developed with a recognised treatment centre, and active intervention on high-risk play.
3 standards3 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
DGA label or StopSpillet contact missing from key player-facing surfaces
Pre-play risk information that is generic or not developed with a treatment centre
Failure to intervene on clear high-risk indicators
Responsible-gambling obligations 3
RG — Label
DGA licence label and StopSpillet visibility
RG CriticalPlayer Rights
Licensed operators must display the DGA licence label and contact details for the StopSpillet helpline on every player-facing surface, with links to treatment resources.
Requirements
Show the DGA label on the home page and in the site footer
Surface the StopSpillet number (+45 70 22 28 25) from every page
Link to treatment resources, not only to the operator's own support
Reference multiple treatment centres rather than a single named clinic
RG — Pre-play
Pre-play risk information
RG Critical
Before a player gambles, they must receive information about the 18+ age limit, the risks of gambling and available treatment, prepared in collaboration with a recognised treatment centre.
Requirements
Present the pre-play risk screen before the first real-money action
Develop the content with a recognised Danish treatment centre
Refresh the content on a documented cadence
Retain evidence of the collaboration for DGA inspection
RG — Intervention
Active intervention on high-risk play
RG Critical
The DGA expects operators to actively monitor high-stake or distressed players and to intervene where indicators warrant, escalating to permanent exclusion where needed.
Requirements
Maintain a documented risk-scoring model with reviewable rules
Operate a soft and hard intervention playbook with owner roles
Keep case files of interventions and their outcomes
Escalate to permanent exclusion through ROFUS where indicators warrant
G
Theme G
Anti-money-laundering (Hvidvaskloven)
Gambling operators are obliged entities under the Danish AML Act (Consolidation Act 1463/2025). The DGA supervises AML compliance directly, refreshed its guidance in 2025, and restructured registration through Executive Order 239/2025.
8 standards8 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Onboarding without CDD or ignoring trigger events for enhanced due diligence
Failing to file suspicious-transaction reports to the Danish FIU
Gaps in record retention or audit access for DGA inspection
AML Act obligations for gambling operators 8
AML — Risk assessment
Risk assessment and AML policies
Player Rights
Gambling operators listed in § 1, stk. 1, nr. 19 of the AML Act are obliged entities and must identify, assess and document the firm's ML/TF risk (§ 7) and maintain written AML policies, procedures and controls covering risk management, CDD, investigation/notification, record-keeping, staff screening and internal control (§ 8, stk. 1). All staff including management must receive adequate AML training (§ 8, stk. 6). Separately, Denmark-based operators that offer games in other EU/EEA states — and that do not hold a Danish Gambling Act licence — must register in the DGA's AML register under Executive Order 239/2025.
Requirements
Maintain a documented firm-wide AML/CFT risk assessment and update it on an ongoing basis (§ 7, stk. 1)
Adopt written AML policies, procedures and controls covering risk management, CDD, investigation/notification, record-keeping, staff screening and internal control (§ 8, stk. 1)
Deliver adequate AML training to staff and management, including on relevant data-protection requirements (§ 8, stk. 6)
If Denmark-based and offering games in other EU/EEA states without a Danish Gambling Act licence, register in the DGA's AML register within 14 days (EO 239/2025 §§ 2, 4, stk. 3)
AML — CDD / EDD
Customer due diligence and enhanced due diligence
Player Rights
Gambling operators must carry out customer due diligence when stakes, payouts or both reach EUR 2,000 — whether in a single transaction or in linked transactions (§ 10, nr. 3). CDD covers collecting identity data, verifying it against reliable and independent sources, identifying beneficial owners, recording the purpose of the business relationship and monitoring it on an ongoing basis (§ 11, stk. 1). A temporary gambling account may be opened before verification, but verification must be completed as soon as possible and no later than 30 days after registration (§ 14, stk. 4); if CDD cannot be completed, the relationship must be terminated and a SAR considered (§ 14, stk. 5). Enhanced due diligence is mandatory for higher-risk situations, including customers established in high-risk third countries on the EU Commission list (§ 17) and politically exposed persons, their relatives and close associates (§ 18).
Requirements
Trigger CDD at EUR 2,000 of stakes, payouts or both (including linked transactions) under § 10, nr. 3
Obtain and verify customer ID from a reliable and independent source; identify beneficial owners; record the purpose of the relationship; monitor on an ongoing basis (§ 11, stk. 1)
If operating a temporary account before verification, complete identity verification within 30 days of registration (§ 14, stk. 4)
If CDD cannot be completed, terminate the relationship, halt further transactions and consider filing a SAR (§ 14, stk. 5)
Apply enhanced due diligence, including source-of-funds checks, for high-risk third countries (§ 17) and PEPs, their relatives and close associates, with senior-management approval (§ 18)
AML — Monitoring / STR
Transaction monitoring and STR reporting
Player Rights
Operators must investigate the background and purpose of complex, unusually large or patterned transactions and of any unusual activity lacking an obvious economic or lawful purpose, and must note and retain the results (§ 25). Knowledge, suspicion or reasonable grounds to suspect money-laundering or terrorist financing triggers an immediate SAR to the Hvidvasksekretariat — the Danish FIU located at the National Unit for Special Crime (NSK) (§ 26, stk. 1; § 29). Transactions that have not yet been executed must be withheld until after the SAR has been filed (§ 26, stk. 3). It is prohibited to disclose that a SAR has been filed or is being considered (§ 38).
Requirements
Investigate and document complex, unusually large or patterned transactions and unusual activity without apparent economic or lawful purpose (§ 25, stk. 1)
File a SAR to Hvidvasksekretariatet at NSK immediately on knowledge, suspicion or reasonable grounds to suspect ML/TF (§ 26, stk. 1; § 29, stk. 1)
Withhold execution of any pending suspicious transaction until after the SAR has been filed (§ 26, stk. 3)
Respect the tipping-off prohibition in all internal and customer-facing channels (§ 38, stk. 1)
AML — Records
Record keeping and DGA audit access
Player Rights
Operators must retain CDD records (identity and verification data, copies of ID documents), documentation and records of transactions, and records of § 25 investigations (§ 30, stk. 1); the default retention period under hvidvaskloven is five years. The DGA (Spillemyndigheden) is the AML supervisor for gambling operators under § 65, stk. 1 and may order corrective measures within a set deadline under § 66; reactions (including transfer to police) are published on the DGA website under § 68.
Requirements
Retain CDD identity and verification records, copies of ID documents and records of § 25 investigations (§ 30, stk. 1)
Retain transaction documentation and records for the statutory retention period (§ 30)
Maintain the internal-control function referenced in § 8, stk. 1 to evidence compliance
Cooperate with DGA supervision and with any order issued under § 66; account for publication of reactions under § 68
§ 7 Hvidvaskloven
Firm-wide ML/TF risk assessment (§ 7 AML Act)
Player Rights
Gambling operators must identify and assess their ML/TF risk by reference to the business model, covering customer, product, service, transaction, delivery-channel and geographic risk factors. The assessment must be documented and continuously updated (§ 7, stk. 1).
Requirements
Produce a documented ML/TF risk assessment anchored in the operator's business model
Cover customer, product, service, transaction, delivery-channel and country/geographic risk factors
Keep the assessment current through ongoing updates, not just periodic refresh
§ 35 Hvidvaskloven
AML whistleblower channel (§ 35 AML Act)
Player Rights
Operators must operate an independent, autonomous whistleblower channel allowing staff to report actual or potential breaches of the AML Act, including anonymously (§ 35, stk. 1). Employees and former employees must not be subjected to unfavourable treatment or consequences as a result of having made a report (§ 36, stk. 1).
Requirements
Provide a dedicated, independent and autonomous whistleblower channel for AML breaches (§ 35, stk. 1)
Allow anonymous reporting through the channel
Prohibit retaliation against current or former employees who report (§ 36, stk. 1)
Document whistleblower procedures within the written AML policies (§ 8, stk. 1)
§ 47 / § 78 Hvidvaskloven
DGA AML supervision and penalties (§§ 47, 78 AML Act)
Player RightsAffiliate Rules
Spillemyndigheden is the AML supervisor for gambling operators and may order corrective measures within a set deadline (§§ 65-66). AML reactions and police referrals are published on the DGA website, naming the legal or natural person concerned (§ 68, stk. 1). Intentional or grossly negligent breaches of core AML duties — including §§ 7, 8, 10, 11, 14, 17, 18, 25, 26 and 30 — are punishable by fine; particularly serious or extensive intentional breaches may carry up to 2 years' imprisonment (§ 78, stk. 1-2).
Requirements
Cooperate with Spillemyndigheden as the AML supervisor (§ 65, stk. 1)
Comply with any corrective order issued under § 66 within the deadline set
Account for public naming of AML reactions on the DGA website (§ 68, stk. 1)
Recognise that intentional or grossly negligent breaches of §§ 7, 8, 10, 11, 14, 17, 18, 25, 26 and 30 carry fines, or up to 2 years' imprisonment for serious intentional breaches (§ 78, stk. 1-2)
BEK 239/2025
Cross-border DGA AML register (EO 239/2025)
Player RightsAffiliate Rules
Denmark-based game providers that offer games in other EU/EEA states and do not hold a Danish Gambling Act licence must register in the DGA's AML register (EO 239/2025 §§ 1-2). Registration is electronic via the DGA form and must be filed within 14 days of obtaining a foreign licence or starting operations abroad; information must be kept current, with changes notified within 14 days. Breach of § 2 and § 4, stk. 3 and 4 is punishable by fine (§ 5, stk. 1). The EO entered into force on 1 July 2025.
Requirements
Confirm whether the operator is in scope: based in Denmark, offering games in another EU/EEA state, without a Danish Gambling Act licence (EO 239/2025 § 1)
Register in the DGA's AML register within 14 days of foreign authorisation or start of operations (§ 4, stk. 3)
Provide all § 4, stk. 1 data, including management and beneficial-owner details per § 4, stk. 2
Notify the DGA of any change within 14 days (§ 4, stk. 4)
H
Theme H
Marketing & advertising
How Danish licensees may promote their products — fair odds representation, audience protection, the DKK 1,000 bonus cap with 10x wagering ceiling, required disclosures in every ad, and operator responsibility for affiliates acting on their behalf.
5 standards5 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Exaggerating winning chances or framing gambling as a path out of hardship
Targeting under-18s or vulnerable audiences through creative, channel or media choice
Bonus promotions that exceed the DKK 1,000 cap or the 10x wagering ceiling
Marketing obligations 5
MKT — Fair odds
Fair representation of winning chances
Bonus & Ads
Advertising must present winning odds in a correct and balanced manner and cannot depict gambling as a solution to financial or social problems.
Requirements
Do not exaggerate winning odds or frequency
Do not frame gambling as improving lifestyle or solving debt
Do not use celebrities as winners or social-status proof points
Frame gambling as entertainment rather than income
MKT — Audience
Audience protection: under-18s and vulnerable persons
Bonus & AdsRG CriticalAffiliate Rules
Marketing must not target under-18s through messaging or media selection, and must not appeal to vulnerable persons.
Requirements
Vet channels, creators and placements for under-18 audience share
Avoid cartoon characters, youth-culture references and teen-coded aesthetics
Suppress sends to ROFUS-flagged players across all channels
Apply the same audience rules to affiliate briefs and creatives
MKT — Bonus caps
DKK 1,000 bonus cap and 10x wagering ceiling
Bonus & Ads
Promotional offers are capped at DKK 1,000 in value, with wagering requirements no higher than 10x and a minimum 60-day completion window. Key terms must be visible alongside the offer.
Requirements
Cap individual bonus value at DKK 1,000
Set wagering requirements no higher than 10x and not applied to promo winnings alone
Allow at least 60 days to complete wagering
Disclose eligibility, exclusions and win caps clearly next to the offer
Offer promotions to at least 100 eligible players, not single-recipient drops
MKT — Disclosures
Required disclosures in every advertisement
Bonus & AdsAffiliate Rules
Every advertisement must state the 18+ age limit, the StopSpillet helpline and a reference to ROFUS, alongside clear operator or licensee identification.
Requirements
Include the 18+ age-limit mark in every creative
Mention StopSpillet as the independent help resource
Reference ROFUS as the self-exclusion route
Identify the operator or licensee clearly
Apply the same disclosures to affiliate placements
MKT — Affiliates
Affiliate oversight
Affiliate RulesBonus & Ads
Operators are responsible for marketing carried out on their behalf by affiliates; the same content, audience and disclosure rules apply to affiliate output.
Requirements
Maintain written affiliate agreements that bind partners to DGA rules
Pre-approve affiliate creatives and placements
Monitor affiliate output on an ongoing basis
Take down non-compliant content promptly on detection
Publish a code of conduct for affiliate partners
I
Theme I
Complaints, dispute resolution & enforcement
How player complaints move through the operator, Spillemyndigheden and the National Tax Tribunal, and how DGA's public naming of rulings and fines from 1 July 2024 changes the reputational stakes of non-compliance.
3 standards3 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Lacking a documented complaints procedure or missing DGA escalation signposting
Non-cooperation with DGA inquiries
Being publicly listed among the DGA's ruled-against operators
Complaints and enforcement obligations 3
Complaints — Operator
Operator internal complaints procedure
Player Rights
Licence holders must publish a documented complaints procedure and handle complaints within a reasonable time, retaining a complaints log for DGA review.
Requirements
Publish a plain-language complaints procedure on the operator site
Acknowledge and resolve complaints within stated service levels
Keep a complaints log with timestamps and dispositions
Signpost escalation routes when a complaint is not resolved
Complaints — DGA / Tribunal
Escalation to the DGA and National Tax Tribunal
Player Rights
Players dissatisfied with the operator may complain to Spillemyndigheden on licensing or regulatory matters, and DGA decisions may be appealed to the National Tax Tribunal (Landsskatteretten).
Requirements
Inform players of the DGA complaint route and contact details
Cooperate fully and promptly with DGA inquiries
Inform players of the right to appeal DGA decisions to Landsskatteretten
Publish complaints contact details alongside support channels
Enforcement — Public listing
Public listing of rulings and fines (from 1 July 2024)
Player Rights
Since 1 July 2024, court rulings and fines against licensed operators are published on the DGA site for five years.
Requirements
Treat public listing as a reputational sanction, not only a fine
Reflect rulings in integrity disclosures to counterparties
Factor the register into supplier and partner due diligence
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