Malta’s AI guidance flags human oversight alongside gambling innovation

The Malta Gaming Authority (MGA), in partnership with the Malta Digital Innovation Authority (MDIA), has unveiled a new AI Gaming Charter aimed at advising on the use of artificial intelligence technologies within Malta’s gambling industry. 

Presented at a launch event this week, the voluntary framework seeks to offer practical, sector-specific guidance that complements existing legal frameworks such as the European Union’s Artificial Intelligence Act (EU AI Act) and the General Data Protection Regulation (GDPR).

Within the document, human oversight is highlighted as a key concern for the regulator, as was the fast-paced nature of AI innovation.

Charter’s purpose

The Charter endeavours to translate legal and ethical expectations into industry-relevant practices. 

These cover the deployment of AI in applications ranging from customer-facing chatbots to fraud detection, anti-money laundering (AML) systems and responsible gambling initiatives.

While the Charter does not introduce new legal obligations, it outlines detailed recommended practices grounded in key themes, including transparency, human oversight, data governance, fairness and non-discrimination, system robustness and environmental sustainability. 

It encourages licence holders to maintain inventories of AI systems and identify their roles as providers or deployers under the EU AI Act. It also encourages the application of a risk-based approach.

The document references MDIA tools like the EU AI Act compliance checker and clarifies reporting duties to market surveillance and data protection regulators in case of serious AI-related incidents.

The key provisions 

Transparency and disclosure

The Charter recommends that players must be able to recognise when they are interacting with AI-driven systems. It requires disclosure of AI-generated content, including deepfakes, in alignment with Article 50 of the EU AI Act. 

It distinguishes between information to be shared with regulators versus the public, protecting proprietary algorithms and security-sensitive data from unnecessary exposure.

Human oversight

A central tenet is that AI should support, not replace, human judgement, especially in sensitive operations like account restrictions or interventions related to gambling harm. 

For higher-risk AI systems, operators are expected to maintain detailed logs with clearly defined escalation procedures and conduct regular validation exercises.

Data governance and privacy

The Charter reinforces GDPR principles such as data minimisation, purpose limitation, accuracy and retention management. Operators should document the origins and quality of AI training data and proactively address bias.

Environmental sustainability

The Charter recognises the energy-intensive nature of AI model training and operation. 

It recommends due diligence on energy practices among suppliers, increased efficiency in model deployment and incorporating carbon footprint considerations into development decisions.

Underpinned studies

A sector study included in the Charter reveals uneven adoption of AI, with many companies at proof-of-concept stages or focused on back-office optimisation rather than critical player-facing applications. 

“The data also indicates that a number of organisations are using AI at Minimum Viable Product stage, particularly in areas such as responsible gambling behavioural modelling, fraud detection and AML, recommendation engines, player onboarding and KYC, payments, human resources and player acquisition,” says the study.

“This suggests that, across the sector, some gaming licensees have moved beyond early experimentation but are still testing practical deployment before wider rollout.” 

Another recent study by The Playa, in collaboration with Gaming Operations Academy and WarriorLab, found that VIP account managers are overreliant on legacy systems. 

According to that study, VIP managers welcomed AI for prioritising their workload but suggested they remained cautious about delegating a final judgment to opaque automated systems.  

Around 38% expressed concern that adopting AI might reduce the personal, human touch in VIP management.  

‘Not to stand in the way of innovation’

The Charter seeks to address this gap with accessible guidance to foster the responsible, proportional use of AI.

Charles Mizzi, chief executive of the MGA, described the Charter as a balancing act: “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.” 

MDIA CEO Kenneth Brincat highlighted the importance of trust and accountability, stating that the Charter “translates these principles into practical, sector-specific guidance”.