January-December 2024

We managed a total of 311 cases during first six months of 2025, of which 72 were submitted by players against MGA licensed operators that we officially act as ADR for (meaning that we have greater powers to enforce rulings) and 239 cases informally against operators for whom we do not act as a formal ADR.

Compared to 2024, this represents a 19% increase in ADR cases managed and a 22% increase in non-ADR cases.

To show the outcomes of complaints we are going to break the complaints into two pie charts – ADR Complaints and Non-ADR Complaints, as there are some substantial differences between the two groups:

From the above we can see:

Resolution: We are FAR more successful at securing a positive outcome for the player (Resolved) when they complain about an operator that we act as ADR for. We successfully resolved 23.6% of all cases accepted by this service when acting as ADR vs only 11.0% when acting unofficially.

Found Against the Operator: Where we have been acting officially as an ADR, we have had a 100% compliance rate with our rulings, meaning that we did not have to conclude any of these cases as Found Against the Operator (where we support the player’s claim but cannot get the operator to take appropriate action to resolve the case). When acting informally, this ruling outcome is one of the most frequent, representing 16.3% of all claims.

Year-on-Year Changes: Comparative to 2024 the most notable changes in ruling rates has been a pronounced increase in the Abandonment rate, for non-ADR claims, rising by over 10% whislt for ADR complaint the rate remained stable. Given the rise in complaint volumes, it seems likely that our user demographics are shifting and non-ADR complaints are being submitted by players who may not be as committed to following the complaint process.

How much money did we recover for players in the first half of 2025?

The gap between the money recovered via ADR complaints and non-ADR complaints is far bigger so far this year. Given the significantly higher Abandonment rate we’ve seen with Non-ADR complaints over the first half of this year, this is understandable.

However the total money recovered does not paint the full picture. The divergence in success rates between ADR and Non-ADR complaints becomes far more apparent when we look at average amount recovered per complaint:

The average funds returned when players submit a complaint to us has decreased slightly for ADR claims compared to 2024, and has diminished significantly for non-ADR complainants. However the same overall trend exists year-on-year, that being that players recover far more money on average when their complaint is against one of our ADR clients.

So, did we favour players or operators more often?

Counter intuitively, we rule in favour of players more often when we are acting informally. Why does this happen?

We do tend to favour the player far more often when dealing with complaints informally because i) there are more questionable practices engaged by operators in weaker licensing systems and ii) more operators simply refuse to discuss complaints, resulting in a default ruling in favour of the player.

What does this mean? It means that despite supporting the player’s claim more often when we manage complaints informally, we’re far less successful at recovering money for players.

Some notable operators and complaints over the first half of 2025:

- Betiex – During management of a complaint against Betiex, it came to our attention that this operator carries terms stipulating that they will not consider any complaint older than 3 days. Beyond the clearly predatory nature of this term, the case in question also involve the operator blocking the players ability to contact their team, thereby restricting the player from raising the complaint within the aforementioned time window.

- Goalbet – During a claim relating to the settlement of a hockey bet, it came to our attention that Goalbet had two entirely contradictory terms in their rules regarding the settlement of hockey bets. One that stated that only regular time would be considered, and one stating that overtime would always be included. The operator chose to enforce the term that favoured themselves to avoid paying the player.

- Golden Panda – This operator has refused to pay a player due to the player depositing from a joint bank account in the player’s name, asserting that this was a 3rd party payment method. Given that the player was named on the account, this payment method clearly belongs to the player and as such cannot legally be considered a 3rd party payment method.

- Nitrobet – During our review of a case against Nitrobet, we encountered a situation where a live chat agent blatantly ignored clear markers of harm that should have resulted in intervention to prevent further access to gambling. More than this, the agent actively encouraged this player to engage in higher risk playing behaviour to recover lost money. Clearly predatory behaviour, explicitly exploiting vulnerability.

- Spinme.Club – The operator made a substantial deduction from the players withdraw to pay “German tax”, despite not holding a German gambling license and not being subject to tax in this jurisdiction.

How often do operators comply with the rulings we give?

Over the course of the first six months of 2025 every ruling we have issued as an ADR has been complied with. This is in line with compliance rates from 2024.

When acting informally only 65% of our rulings were complied with. Our leverage to enforce our rulings is substantially weaker when acting informally, meaning far fewer of the complaints where we support the player actually result in the player recovering money.

On average how long did the complaint management process take?

Why are we quicker when acting unofficially? We’re not. The lower average complaint length is a direct result of us closing many of these complaints faster because the operators involved are non-responsive. We close these complaints after approximately 21-28 days of trying to contact the operator without success. With so many of the cases in this group not receiving a response, these low figures drag the average down.

For both ADR and non-ADR complaints, we have seen a slight increase in the time taken to manage complaints in comparison to 2024. We would attribute this to time spent train news team members.

We understand it can be very frustrating waiting while a claim is managed, and it is our objective to ensure that your claim is managed as quickly as possible. But each claim is individual and some are far more complex than others. Where we have to contact regulators, payment providers, software providers etc, the length of time it takes to conclude a claim tends to rapidly inflate. Nevertheless, these cases represent only a small fraction of the claims we manage.

Over the course of the first six months of 2025 we’ve had 4 ADR complaints (5.6%) and 8 non-ADR complaints (3.3%) take longer than 90 days to conclude.

What do the complaints we receive relate to? Where we accept a complaint they fall into one of eight categories:

i) Problems with bonuses
ii) Opening more than one account
iii) Problems with a payment to or from an operator
iv) Problems with KYC and other security procedures
v) Basic breakdown in communications
vi) Responsible gambling
vii) Retro-active term enforcement
viii) Problems with the technical function of some aspect of the website or games

Breaking down complaints again in two groups we see:

In both sets Payment Problems and Security (generally verification issues) are the top two most common complaint types. These complaint types are closely intertwined as the most common reason for a delay in payment is incomplete verification. As such there is overlap between these groupings. If these two groups are considered together, both data sets have similar results.

There are some differences between the data sets in the categories of Bonuses and Multi-Accounting, with ADR complaints showing a higher frequency of Bonus related complaints and fewer Multi-Accounting issues, whilst non-ADR complaints include more Multi-Accounting issues and fewer Bonus issues. This is understandable as instances of multi-accounting are almost exclusively related to players opening more than one account to avail themselves of bonuses that they are not entitled to receive. When looked at in conjunction, these two categories represent approximately the same proportion of complaints across both data sets.

We consider a complaint abandoned when a player stops responding to our request for additional information or documentation relating to their claim. The rate of abandonment can be seen below:

We migrated our service to our new platform in the middle of February which has improved email notifications for complainants. This appears to have had a substantial impact on Abandonment rates, with ADR complaint Abandonment rates decreasing by 5% year-on-year, whilst non-ADR rates decreased by 9%.

As can be seen above we decline a higher proportion of complaints when we are managing the case informally. The reasons for this are simple – these complaint are primarily against weakly licensed or unlicensed gambling operators. These gambling operators more frequently ignore national licensing requirements and are subject to no responsible gambling standards. As much as we would like to help these players, there are a higher proportion of claims in this group where our intervention would make no practical difference.

When we decline to take a case on, we do so for a variety of reasons. When acting as an ADR we cannot simply decline any complaint. It has to fall into clearly defined criteria before we decline it. When working unofficially, we do look to work to the same criteria as often as possible, but do allow for a few additional grounds for declination. We will detail below:

- The player hasn’t completed the operator’s internal disputes system (ADR) – generally, we do not decline cases for this reason, but we will direct the player to revert to the operator and allow for more time for the operator to act on the case, and return to us if they are still experiencing issues.

- The complaint is of a frivolous or vexatious nature (ADR) – This tends to be complainants who are persistent in communications that are rude, abusive or antagonistic in nature.

- Where another ADR service, court or regulatory agency has already reviewed the case (ADR) – This is self-explanatory. Much like a court, you cannot simply keep re-submitting your claim until you get the answer you want.

- Where the complaint is older than 12 months (ADR) – We do show some leeway in this and will, at our team’s discretion, review claims that are older. But the older a claim is the harder it is to obtain the necessary evidence to support it.

- Where the claim value is less than €10 (ADR) – Again we will at times set this restriction aside, but generally claims that are of this low a value have an extremely high abandonment rate and are not an effective use of this service’s times and resources.

- Where we have reasonable grounds to believe one or both parties has misled this service (ADR) – The ADR service requires good faith. Where one or both parties looks to engage in wilful deception it substantially impedes the function of this service. We reserve the right to decline to investigate a case further where we have reasonable grounds to believe one or both parties have misled our team.

- Where the workload involved in managing a complaint would impair the service’s ability to function (ADR) – Some claims involve more work to verify the claims that we can reasonably undertake. These cases are few and far between, but we do retain the right to reject claims on this basis.

- Where the claim is not appropriate for review by an ADR (ADR) – Generally where the issue relates to licensing, or lack thereof, or where the claim relates to a disputed financial transaction that is more appropriately managed by the polices or payment provider.

- Weak license responsible gambling claim (non-ADR) – Where the player’s complaint relates to responsible gambling protections against an operator who holds no license, or a license that requires licensees to provide no viable protections to players.

- Ambiguous claims (non-ADR) – Where there’s sufficient reason with the complaint submission and evidence we’ve reviewed to reasonably conclude that the player may have been involved in non-compliant activities.

- Repeated claims against weak licenses (non-ADR) – Where a player persistently chooses to play with weakly licensed operators, ignoring our warnings about doing so, we will stop accepting similar claims from them.

- Operator already offline (non-ADR) – Where the claim relates to an operator who has already closed down and as such cannot be reached to discuss the matter.

Here's how the declined complaints broke down for ADR and Non-ADR complaints:

- Maximum Bet Terms – Max bet terms continue to be a problem representing 6% of all claims that were ruled Found for the Operator and over $10k worth of claims.

Whilst these rulings are technically correct – in each case the player has failed to comply with the terms and conditions of the bonus that they agreed to – this service cannot support the continuance of the circumstances that cause these complaints to arise.

The blunt reality is that these terms can and should be enforced automatically. Other licensing regimes require that these terms are enforced automatically and by allowing this loophole to persist, regulators create a situation where licensees effectively free-roll players, allowing violations to go unchecked where the player loses, but voiding any winning promotional play.

- Self-Exclusions – One of the most frequent type of complaint occurring relates to Responsible Gambling policies and specifically the language surrounding the MGA self-exclusion system. Where the majority of the world views a “self-exclusion” as a responsible gambling based account closure, within the MGA system a self-exclusion is not always considered to relate to gambling addiction. Under the Malta license players have to actively tell the operator at the time that they self-exclude that they are excluding due to reasons related to addiction before a self-exclusion would be treated as a problem gambling issue.

This is counter intuitive to users who expect that when they self-exclude, they will be recognised at using tools to manage gambling addiction. This is especially significant when the heightened emotional state of a self-excluding player is taken into consideration.

Alongside this, under the MGA licensing regime, a self-exclusion applies only to the url that it is requested at, unless the player has actively instructed the licensee to carry over the self-exclusion, or the player has directly stated that they exclusion is due to gambling addiction. Players naturally expect that where they request a self-exclusion, it will be applied to all properties that the licensee operates.

This type of dispute not only represents a large proportion of the overall case load but is ethically challenging to defend. These are vulnerable players that as an industry we should be working to protect.

- High Risk Activity – Over the last six months we have seen continued high volumes of high risk activity, specifically originating in one Eastern EU country and one Western EU country. There is strong evidence to indicate that there are large numbers of accounts being registered that are being operated by people other than the person identified in the account information and that the name on the account is being used to allow a 3rd party to access welcome incentives that they are not entitled to.

This activity has been observed moving from group to group within the industry, generally targeting one group until such times as they have exhausted the proxy identities being used or the licensee takes steps to limit the value of the promotional incentives being offered. This activity has been observed both at our ADR clients and non-ADR clients, though admittedly our insight into their activity at non-ADR properties is more limited, and has over the time period worked through the better licensed systems and seems to be moving on toward Curacao licensed operators.

We cannot suggest any direct solution to this issue other than licensees restricting these countries from receiving promotional incentives or waiting for the attention of the parties who are directing this activity to shift to the unlicensed markets.

- Source of Wealth checks - The increased levels of high risk activity detailed above is resulting in higher levels of enhanced due diligence being engaged, specifically Source of Wealth checks, with the intention being to establish exactly how the account holder came to be the legal owner of the funds put into play.

These checks are resulting in higher levels of frustration for users, but they are also proving very effective in identifying situations where the person named on the account is neither the person operating nor funding the account.

Again we have no direct solution to this particular issue.

- Account Activation Scams – Over the last six months we have observed patterns that convince us that a new type of scam is being deployed in the unregulated space. The pattern is as follows: The player has engaged with an unlicensed gambling operator, often sharing key graphical similarities to other operators receiving similar complaints. The player has experienced an abnormally big win. The player tries to withdraw, and is then informed that they have to make a deposit to activate the account. These deposits can range from $100 right up to $1000. Whilst these deposits may seem large, they appear contextually small compared to the life changing sum that the player has supposedly won. If the player makes this payment, they’re then told they need to make another deposit to activate the payment method.

From what we’ve seen, even where players do make these deposits they are never paid the winnings. It is our strong suspicion that the games in question are rigged to make huge wins certain and that these casinos are set-up with the sole purpose of defrauding players of their ‘activation deposits’.

Our ADR Official – Duncan Garvie - continues to maintain their membership of the Chartered Institute of Arbitrators (CIArb) and has in the last 12 months become a member of both the International Ombuds Association and the International Council for Commercial Arbitration.

Our ADR Official attends quarterly meetings with the GamShield group – a collective of compliance personnel, regulatory representatives and other industry bodies who participate in gaming protection. This ensures that we retain an up-to-date knowledge of the challenges facing the sector and the various approaches being taken to address said challenges.

Our ADR Official maintains a position as a Trustee for the responsible gambling focused charity BetBlocker, a group that support tens of thousands of users on a daily basis. They have daily input to the user support function of the charity. This ensures that our ADR Official has extensive experience engaging with and supporting those experiencing gambling addiction. This creates transferrable experience that is invaluable in the management of responsible gambling related complaints.

Over the last six months our ADR Official has been engaged in delivering training to a new Dispute Resolution Official, with the intention of submitting them to the relevant regulatory authorities for consideration of approval at the end of the year, or once they have one thousand claims worth of experience, whichever comes first.

We maintain an open door policy with any other ADR working within the industry and sustain a positive relationship with some of the most significant entities in the field. Most notably we continue to work closely with the Malta Gaming Authority, who are currently still sustaining a notable presence in terms of dispute review, both consulting on open cases where regulatory guidance is appropriate and offering feedback where our input is sought on other complaints the regulator is reviewing.

We have found the Consumer Affairs Council’s biannual meetings with all ADRs to be a constructive and useful forum.

We are also at the preliminary discussion stages of a cooperation between a collective of UKGC approved ADRs to consider how to manage social responsibility claims moving forward.

We are currently in the process of expanding our team through a collaborative approach to training, helping to ensure best practice is sustained. As more Dispute Resolution Officials reach qualified status, we will be able to process more claims faster.