Gambling Reporting Obligations and Compliance in the Czech Republic

The operation of gambling activities is among the most strictly regulated business sectors in the Czech Republic. Whether you are a casino operator, a gaming room owner, or an online gambling provider, you have a legal obligation to report specific data to the Czech supervisory authorities. In this article, we will outline exactly what you are required to report, which channels to use, and the consequences of failing to submit data correctly. This guide focuses on practical obligations, technical details, and the risks that our Prague-based legal team helps clients navigate.

What is reporting and why regulators monitor it so closely

Data reporting to regulators is an obligation for every operator running gambling activities in the Czech Republic based on a license. This involves the continuous, automated transmission of information regarding games, bets, deposits, winnings, and participants into the central information system of the Ministry of Finance (AISG).

The Ministry of Finance and the Czech Customs Administration place extraordinary emphasis on reporting; in practice, this means an obligation to ensure remote access to your data. Any error in reporting or its absence is classified as an offense under the Czech Gambling Act.

Regulators insist on reporting for one simple reason: they need an overview of how the gambling market functions. The data allows them to monitor whether operators are complying with legal limits, whether illegal operations are occurring, and whether players are correctly registered under Czech law.

Who must report and what is reported

Every legal operator must report, regardless of whether they operate a single gaming room, a network of casinos, or online gambling. This obligation applies to all license holders. The scope is defined by Decree No. 10/2019 Coll. and includes:

• Participant registration data (player identification, age, and identity verification).
• Financial data and gaming data (bets accepted, winnings paid out).
• Data on self-limitation measures (set limits on bets, losses, and gaming time).
• Operational and technical data (identification of gaming devices, business locations).

Data is sent electronically in a strictly defined format and structure, usually in XML/CSV format according to specifications. It is sent automatically in daily intervals as "daily batches." This is not a matter of manually filling out forms, but a direct data transfer between the operator's server and the AISG system.

Technical side of reporting and current requirements

Operators must constantly monitor the Technical Specifications of the information system issued by the Ministry of Finance. The operator's systems must be able to communicate with the Czech state administration interface flawlessly.

Any change in infrastructure must comply with the law and approved documentation. If an operator uses an outdated communication protocol or fails to respect current validation rules, the data will not be accepted.

If the system does not function correctly, the operator risks sanctions. According to Section 123 of the Czech Gambling Act, failure to fulfill the obligation to provide data can result in a fine of up to CZK 50,000,000.

Experts from the ARROWS law firm in Prague regularly assist operators with the legal aspects of system setup and communication with the regulator. We know what is checked and how to prevent sanctions. If you are unsure whether you are meeting all obligations, contact us at office@arws.cz.

MicroFAQ: Reporting Basics

1. Do I have to report data even if I only have one gaming room?
Yes. The size of the operation does not affect this obligation. Every operator must report data on all their gambling activities to the AISG system to the extent set by the decree.

2. What is the deadline for sending data?
Data is usually sent in daily batches for the previous gaming day (the "business day"). The law and technical specifications set exact times by which the batch must be sent and confirmed.

3. What happens if I don't send the data on time?
The absence of reporting is immediately visible in the AISG system. The Czech Customs Administration or the Ministry of Finance will record this outage. This can lead to the initiation of an audit and subsequent administrative proceedings for the imposition of a fine.

Practical fulfillment of reporting obligations

If you operate a gambling activity, reporting takes place depending on the type of game, but the basic principles remain the same. For land-based gaming rooms or casinos, the player must register upon entry, and you must verify their identity and age.

Data about the player and their gaming activity is recorded in the operator's central system, which generates a data string once a day and sends it to AISG. This also includes a real-time check to see if the player is listed in the Register of Excluded Persons (RVO).

For online gambling, remote identification and identity verification take place during online registration. All transactions are logged, and the system automatically generates reports sent to the Ministry's servers. Here, enormous emphasis is placed on the accuracy of timestamps and financial flows.

A specific feature of fixed-odds betting is that the evaluation of a bet may occur long after it was placed, and the system must correctly pair the deposit with the payout of the win. Data on accepted bets, tickets, and results are reported.

In all cases, your IT system must be certified and capable of communicating with AISG. If the system rejects a report due to an incorrect format or invalid data, the operator is obliged to rectify the error immediately and resend the data.

Many operators make the mistake of ignoring error messages and correcting them only weeks later. During an audit, data discrepancies then appear, which is treated as a breach of the obligation to provide complete and truthful information under Czech legislation.

MicroFAQ: Practical aspects of reporting

1. Where can I find the documentation for reporting?
The AISG Technical Specifications, methodological guidelines, and operating rules are available on the website of the Ministry of Finance in the Gambling section. This documentation is crucial for your software developers.

2. Can I have a custom system developed?
Yes, but the system must undergo a professional assessment and certification by an authorized person (testing laboratory). Responsibility for the functionality of reporting always lies with the gambling operator, not the software provider.

3. What are the most common data errors?
Duplicate records, incorrect date and time formats, wrong game codes, discrepancies between player records and financial flows, or reporting data that does not correspond to the actual balance on player accounts.

Data reporting and player identification

A critical point of reporting is the correct identification and registration of players. The Czech Gambling Act sets a strict ban on participation in games for persons under 18 years of age and persons listed in the Register of Excluded Persons (RVO).

Your system must ensure that a user account is established for every player before they are permitted to play and that a check has been performed in the RVO (Register of Excluded Persons). A check is an active query to the register, while reporting is the retrospective submission of data; both processes must function flawlessly under Czech law.

If you permit play to a person listed in the RVO, you are committing one of the most serious administrative offenses. Fines can reach up to 50 million CZK, and there is a risk of license revocation.

Our attorneys in Prague from the ARROWS law firm assist operators with auditing registration processes and setting up internal regulations. We know where the risks are hidden. If you have doubts about your process settings, write to us at office@arws.cz.

Identity Verification – KYC in Gambling

In both online gambling and brick-and-mortar casinos in the Czech Republic, the KYC (Know Your Customer) process is essential. The operator must identify and verify the player's identification data. During an inspection, the Czech supervisory authority verifies whether the data sent in reporting matches the documents you have stored.

Insufficient identification has two legal dimensions: a violation of the Czech Gambling Act and the AML Act. Violations can lead to high sanctions; in extreme cases under the AML Act, these can exceed 100 million CZK.

Responsibility for the accuracy of identification lies with you. Even if you use external identity verification services, you remain responsible before the Czech regulator.

AML and Reporting – Two Sides of the Same Coin

Gambling operators are considered "obligated persons" under the Czech AML Act. This entails the obligation to perform client identification and due diligence, monitor transactions, and evaluate risk. Suspicious transactions must be reported to the Financial Analytical Office (FAÚ).

Reporting data, such as deposits, withdrawals, and bets, are key inputs for AML monitoring. If your reporting system shows high deposits for a player without an obvious source of income, you should take notice.

Our Czech legal team at ARROWS performs AML compliance audits and prepares the mandatory System of Internal Principles for operators.

How Suspicious Transactions are Reported

If a system or employee detects a suspicious transaction, such as an attempt at money laundering, you must notify the FAÚ without undue delay. The report is submitted electronically or via another secure method defined by the FAÚ.

An important rule is the prohibition of "tipping off." You must not inform the client that they have been reported to the FAÚ or that an investigation is underway. Violating this confidentiality is in itself a serious offense under Czech legislation.

How Reporting is Inspected – Practical Insights

Inspections are carried out by the Customs Administration of the Czech Republic and the Ministry of Finance. The first question is often whether the data in the AISG matches the reality in the gaming room. Officials will pull the data you reported even before the inspection and compare it with the data in your system.

Furthermore, an RVO and identification check takes place, where selected players are randomly verified. They check when they were registered, whether an RVO query was performed, and whether you have copies of their IDs. Finally, AML documentation and the System of Internal Principles are reviewed.

If the data does not match—for example, a player is in the gaming room but not in the report, or financial flows do not correspond—it is recorded in the protocol. Subsequently, administrative offense proceedings are initiated.

Typical Errors During Inspections

Our Prague-based attorneys represent operators in administrative proceedings, and we frequently encounter errors such as reporting outages or formal errors in XML/CSV files. Play without registration in gaming rooms, missing AML documentation, or transaction time discrepancies are also common.

If you are preparing for an inspection or one is already underway, the ARROWS law firm in Prague will provide legal representation and help minimize the impact of any identified deficiencies.

MicroFAQ: Inspections and Sanctions

1. Can I check if I am on the inspection plan?
Inspection plans are not public. Inspections can be announced or unannounced. The Czech Customs Administration also performs "mystery shopping" (undercover play).

2. What is the fine for a reporting error?
Czech law sets an upper limit of 50 million CZK. The actual amount depends on the severity, duration, and consequences. For systemic errors, fines commonly range from hundreds of thousands to millions of crowns.

3. Can I have my system checked preventively?
Yes, we recommend it. A legal and procedural audit will reveal weaknesses before the Czech authorities do.

Practical Tips for Secure Reporting

Whether you are a small operator or a large network in the Czech Republic, follow these rules:

• Archiving and Backup: Keep sent data and confirmations of receipt by the AISG system. The burden of proof is on you.
• Regular Training: Employees must know their obligations regarding identification, RVO, and AML. The obligation to train is directly imposed by the Czech AML Act.
• Internal Control: Implement an internal control system that regularly verifies whether data is sent correctly and on time.
• Supplier Contracts: If an external company provides your reporting, contractually manage liability for software defects and damages.
• Process Documentation: Have written procedures for internet outages, system failures, and manual mode procedures.

Our attorneys in Prague prepare internal guidelines and conduct training for clients. Contact us at office@arws.cz.

Legal Deadlines and Terms

Reporting is a continuous obligation; when you launch a new game, the obligation to report arises immediately. Changes to the gaming system that impact reporting are subject to an approval process or notification obligation under Czech law. If incorrectly sent data is discovered, corrective reporting must be performed without undue delay.

Under the Czech Gambling Act and the AML Act, you must store identification data and transaction data for a period of 10 years from the termination of the business relationship or the execution of the transaction.

Conclusion

Reporting data to regulators is not merely an administrative task, but a fundamental condition for the legal operation of gambling games in the Czech Republic. Data within the AISG system serves as a mirror of your business for the Czech state administration.

Underestimating this agenda can lead to liquidating fines or the loss of your license; therefore, the correct setup of processes is crucial.

Our Prague-based attorneys at ARROWS law firm specialize in Czech gambling law and compliance and possess a detailed understanding of the regulator's requirements. We are insured for up to 400 million CZK and provide legal certainty for your business operations. Contact us at office@arws.cz to arrange a consultation.

FAQ – Most frequent legal questions regarding gambling reporting

1. What fine do I face if I discover a reporting error myself and correct it?
If you discover the error yourself and actively rectify it before an inspection begins, the Czech administrative authority will take this into account as a mitigating factor during any potential proceedings, or may not initiate proceedings at all. The operator's proactive approach is key.

2. Am I liable for an error caused by a software provider?
From the perspective of Czech administrative law, yes. The operator is the license holder and is responsible for compliance with the law. If the error occurred on the provider's side, you may subsequently seek damages from them in civil proceedings.

3. Is there a reporting exemption for small gaming rooms?
There is no such exemption. The obligation applies to all legal operators in the Czech Republic without distinction.

4. What is the difference between reporting and AML monitoring?
Reporting is the automated submission of technical and financial data to the Czech Ministry of Finance system. AML monitoring is the process of tracking player behavior to detect money laundering and terrorist financing. These are two distinct, though related, obligations under Czech legislation.

5. What should I do if I receive a notice to remedy deficiencies?
Respond immediately. Communicate with the administrative authority, identify the cause, and arrange for a remedy. If you are unsure of the legal procedure, consult a Czech attorney. Passivity is the worst strategy.

Disclaimer: The information contained in this article is for general informational purposes only and serves as a basic guide to the issue. Although we strive for maximum accuracy in the content, legal regulations and their interpretation evolve over time. To verify the current wording of the regulations and their application to your specific situation, it is therefore necessary to contact ARROWS Law Firm directly (office@arws.cz). We accept no responsibility for any damage or complications arising from the independent use of the information in this article without our prior individual legal consultation and expert assessment. Each case requires a tailor-made solution, so please do not hesitate to contact us.

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