Malta Gaming Authority launches voluntary AI Gaming Charter
The Malta Gaming Authority (MGA) has introduced a voluntary framework for how licensed gaming companies should develop, deploy and oversee artificial intelligence, following an assessment that found AI adoption across the sector remains uneven.
Developed with the Malta Digital Innovation Authority (MDIA), the AI Gaming Charter sets out principles covering transparency, data governance, human oversight, non-discrimination and stakeholder engagement. The framework is intended to complement existing legislation, including the EU AI Act, rather than introduce additional legal or regulatory obligations.
The Charter follows an MGA exercise involving sector-wide surveys, discussions with gaming licensees and a dedicated consultation process. The Authority’s research found that operators are already using AI in areas such as operational optimisation, data analytics, customer support, fraud detection, AML and responsible gambling, while adoption is more limited in functions including dynamic odds setting, risk management, regulatory reporting, player acquisition and onboarding, and payments.
AI adoption is ahead of governance
The MGA study points to a gap between the use of AI and the formal governance structures surrounding it.
Only a minority of operators reported having a formal AI strategy or roadmap, while such strategies were still being developed across most companies surveyed. Technical infrastructure was generally viewed as mature or adequate, but practices such as data traceability, documentation, AI-specific risk assessments and incident response were less consistently established.
The study also found that only a small number of organisations disclose their use of AI to customers or obtain explicit consent for automated processing. The MGA characterised the sector as having “technical readiness for AI” that was “relatively positive”, while describing the overall approach to AI implementation as “mixed and cautious”.
The findings are based on voluntary industry participation, so they provide an indication of current practices rather than a comprehensive measurement of every MGA licensee.
What the Charter asks operators to put in place
The Charter places particular emphasis on knowing where AI is being used and who is responsible for it.
Licensees adopting the framework are encouraged to maintain an inventory of their AI systems, recording information such as each system’s purpose, ownership, risk classification, deployment context and lifecycle status. They are also encouraged to conduct AI impact assessments covering potential effects on individuals, groups and society.
For systems with a greater potential impact on players, including those involved in responsible gambling, fraud detection, AML, KYC and account restrictions, the Charter calls for stronger controls. These include testing and validation, human oversight, ongoing monitoring and mechanisms for intervention where necessary.
The framework also addresses transparency towards players. Operators are encouraged to make clear when customers are interacting with AI, while the Charter warns against “AI washing” — overstating the role or capabilities of an AI system. Its approach is that AI should support established procedures and professional judgement rather than remove human responsibility from decision-making.
Operators that choose to adopt the Charter are encouraged to appoint internal points of contact from areas such as compliance, data, technology or AI. The framework also calls for ongoing AI literacy and refresher initiatives.
Charter sits alongside EU AI rules
The MGA and MDIA have positioned the Charter as sector-specific guidance rather than a new layer of binding regulation. It does not create new legal or regulatory obligations for licensees and is intended to work alongside existing European requirements, including the EU AI Act.
The Charter also maps its principles against the EU AI Act, providing operators with a way to relate the sector-specific guidance to the broader European framework. The mapping itself does not establish a presumption of conformity with the EU AI Act.
MGA CEO Charles Mizzi said the initiative reflects a joint effort by regulators, industry and technology specialists to encourage responsible and transparent AI use.
“Our role as a regulator is not to stand in the way of innovation, but to help create the certainty and confidence needed for innovation to flourish responsibly,” Mizzi said.
MDIA CEO Kenneth Brincat said that trust would be central to wider AI adoption and that organisations need practical mechanisms for identifying where AI is being used, managing associated risks and maintaining accountability and human oversight.
The Charter is voluntary, but the MGA is expected to continue engaging with licensees around its implementation and future development. The framework therefore gives Malta’s gaming sector a common reference point for AI governance without changing the underlying legal obligations already applying to operators.
