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Malta’s AI Gaming Charter: A Comprehensive Guide for Licence Holders

By jili tutorial · September 22, 2026

Malta’s AI Gaming Charter: A Comprehensive Guide for Licence Holders

Overview: A Voluntary Framework for Responsible AI Adoption

Malta has officially launched its long-anticipated AI Gaming Charter, providing gambling licence holders with a voluntary code of conduct designed to ensure transparency, accountability, and fairness in the use of artificial intelligence. Developed jointly by the Malta Gaming Authority (MGA) and the Malta Digital Innovation Authority (MDIA), the Charter was first hinted at during the SBC Summit Malta with a target publication date of 2026. It represents the culmination of extensive research and stakeholder consultation, and it sets out clear expectations for operators who wish to integrate AI into their systems while safeguarding player interests.

This guide expands on the Charter’s core principles, explains the context behind its creation, and offers practical advice for licence holders looking to align their AI governance with the new standards.

Background: Why the Charter Was Created

The MGA’s AI Study: Key Findings

Before drafting the Charter, the MGA conducted a comprehensive study on AI usage within the licensed gaming sector. The findings revealed a mixed landscape:

The study concluded that while technical readiness for AI remains relatively positive, the overall response indicates a mixed and cautious position towards both implementing and using AI. This caution, combined with the uneven governance maturity, underscored the need for clear, sector-specific guidance.

The Charter’s Core Mission

The MGA and MDIA designed the Charter to ensure that technological progress does not come at the expense of player safety or integrity. It aligns responsible data governance with human oversight, providing a practical framework to mitigate the risks of AI adoption while encouraging innovation.

Detailed Guidelines for Licence Holders

1. Calibrating AI Governance According to Impact

Operators must assess the potential impact of their AI systems on players and adjust their internal governance structures accordingly. The Charter draws a clear distinction between:

Practical example: An AI that recommends a deposit limit based on a player’s historical behaviour is higher-impact and should be subject to regular fairness reviews, while an AI that optimises server load balancing is lower-impact.

2. Transparency: Disclose AI’s Role, Purpose, and Limitations

Whenever a user interacts with an AI system, operators must clearly disclose:

Disclosures should be prominent, understandable, and available at the point of interaction — not hidden in terms and conditions.

3. Maintaining Fairness: Catalogue Objectives and Monitor Equitable Treatment

To safeguard fairness, operators are expected to:

Context: Fairness in AI is not just about avoiding discrimination — it also means ensuring that the AI’s decisions are consistent and predictable, especially in areas like responsible gambling interventions where inconsistency could harm vulnerable players.

4. Data Security: Embed Privacy by Design

Operators must integrate privacy protection and GDPR compliance by design into their AI infrastructures. This means:

Example: An AI used for fraud detection should access transaction data only, not a player’s full browsing history, and should anonymise data where possible.

5. Human Oversight: Ultimate Accountability Lies with People

A critical pillar of the Charter is maintaining human supervision across AI decision pathways. Key requirements:

Why this matters: Even the most sophisticated AI can make errors or become biased. Without human oversight, a single flawed model could harm thousands of players before the problem is caught. The Charter positions human judgement as the final safeguard.

6. Collaboration with Regulators: Workshops, Feedback, and Self-Assessment Tools

The Charter is voluntary, but operators are strongly encouraged to work closely with both the MGA and the MDIA through:

This collaborative approach helps regulators stay informed about real-world implementation and allows operators to receive tailored guidance.

Putting the Charter into Practice: A Step-by-Step Approach

Step 1: Inventory Your AI Systems

Create a comprehensive list of all current and planned AI applications. Classify each one as low, medium, or high impact based on its potential effect on players. This inventory will form the foundation of your governance framework.

Step 2: Perform a Governance Gap Analysis

Compare your existing policies and procedures against the Charter’s requirements. Identify gaps in transparency, fairness, data security, and human oversight. For example, if you use AI for customer support but haven’t disclosed its limitations to players, that’s a gap.

Step 3: Develop an AI Fairness Policy

Document your fairness objectives for each AI system. Define how you will monitor for bias and what actions you will take if unfair treatment is detected. Consider using fairness metrics like statistical parity or equal opportunity.

Step 4: Strengthen Data Protection

Ensure that data used for AI training and inference complies with GDPR. If you haven’t already, conduct a DPIA for each high-impact AI system. Implement data anonymisation and pseudonymisation where feasible.

Step 5: Establish Human Oversight Procedures

Define which decisions the AI can make autonomously and which require human approval. For high-impact applications, mandate a human-in-the-loop (HITL) workflow. Document escalation paths and train staff accordingly.

Step 6: Engage with Regulators

Contact the MGA and MDIA to arrange a workshop or request a self-assessment toolkit. Use these resources to validate your governance framework and address any blind spots early.

The Role of Trust in AI Adoption

As Kenneth Brincat, CEO of the MDIA, stated:

“Trust is fundamental to the responsible adoption of AI. As its use becomes increasingly embedded across the gaming sector, organisations need practical ways to understand where AI is being used, manage the associated risks and ensure that accountability and human oversight remain firmly in place.”

The Charter translates these principles into practical, sector-specific guidance, combining the MDIA’s expertise in AI governance with the MGA’s deep understanding of the gaming sector. For licence holders, this represents a valuable opportunity to build trust with players, regulators, and the wider public while harnessing the benefits of AI.

Conclusion: A Roadmap for Responsible Innovation

Malta’s AI Gaming Charter is more than a set of guidelines — it is a roadmap for integrating AI into gaming operations in a way that prioritises safety, fairness, and integrity. By following the Charter’s principles, operators can move beyond the “mixed and cautious” position identified in the MGA study and embrace AI with confidence.

Key takeaways:

The Charter is voluntary, but the expectations it sets are likely to become benchmarks for the industry. Adopting them early will not only reduce risk but also position your operation as a trusted leader in responsible AI use.