How Casino Apps Stay Compliant

March 7th, 2019

by David Quinn

VP of Strategy & Partnerships at Gummicube, Inc.

Many casino apps have to walk a tricky tightrope of compliance. They seek to provide an engaging casino experience, but they also cannot offer real gambling on the App Store or Google Play Store. So how do casino apps remain compliant, and how does this impact their App Store Optimization strategy?

Store Guidelines

First, it is important to understand where the Apple App Store and Google Play Store stand on gambling apps. Section 5.3 of the App Store Review Guidelines is dedicated to this, stating:

Gambling, gaming, and lotteries can be tricky to manage and tend to be one of the most regulated offerings on the App Store. Only include this functionality if you’ve fully vetted your legal obligations everywhere you make your app available and are prepared for extra time during the review process. Some things to keep in mind:

5.3.1 Sweepstakes and contests must be sponsored by the developer of the app.5.3.2 Official rules for sweepstakes, contests, and raffles must be presented in the app and make clear that Apple is not a sponsor or involved in the activity in any manner.5.3.3 Apps may not use in-app purchase to purchase credit or currency for use in conjunction with real money gaming of any kind, and may not enable people to purchase lottery or raffle tickets or initiate fund transfers in the app.5.3.4 Apps that offer real money gaming (e.g. sports betting, poker, casino games, horse racing) or lotteries must have necessary licensing and permissions in the locations where the App is used, must be geo-restricted to those locations, and must be free on the App Store. Illegal gambling aids, including card counters, are not permitted on the App Store. Lottery apps must have consideration, chance, and a prize.

On Google Play, the restrictions are even stricter. Gambling apps are only permitted in the UK, Ireland and France, and have a lengthy list of restrictions and requirements. Outside of those, gambling apps simply aren’t allowed.

“For all other locations, we don't allow content or services that facilitate online gambling, including, but not limited to, online casinos, sports betting and lotteries, and games of skill that offer prizes of cash or other value.”

Yet there are still plenty of apps on both stores that provide casino games, following the rules and guidelines while still providing a casino-style experience.

Prizes & Money

One key factor to remaining on the App Store and Google Play Store is how real money is used. There are a few important steps to follow for this.

First, if the game does not offer real money prizes or simulates gambling, that should be stated clearly and upfront. It’s certainly possible to create an app that simply replicates games without asking for or offering any money, and in those cases, it should be clear right from the start.

If users can win money or prizes, it cannot be through any kind of betting or gambling – this must be made clear in the description. This may seem strange for a casino app, but it is necessary for the app to be allowed on the stores. For example, some casino apps award winners with extra entries into sweepstakes or giveaways rather than directly converting in-game currency to and from actual cash rewards. Even then, the giveaways themselves must be made very clear in the app description, and lottery apps “must have consideration, chance, and a prize.”

The games and the money prizes should be kept distinct as well. For instance, an app can offer raffles with monetary prizes, and it can offer games like slots or blackjack, but those must be separate aspects. If it seems as though the app uses casino games to award monetary prizes, it violates the store policy and is likely to be removed.

Any in-app purchases must be kept distinct from any app currency used for gambling as well. While apps can offer in-app purchases, if users can spend money to increase their chances or odds of winning, the app will be at risk. Similarly, while users can earn extra coins or chips through activities like watching video ads, that cannot be a requirement or the only way to receive them.

Be Clear

To avoid rejection, apps with casino games should make it very clear in their creatives and description that they are following all the guidelines. This indicates tothe stores and users that the app is not designed for gambling, rather it offers casino-style games and it also happens to offer prizes in an unrelated manner.

This requires carefully designing the creative sets to keep the categories distinct. An app can have a screenshot talking about winning prizes and a screenshot about playing games, but it can in no way have a screenshot that connects playing games to winning prizes.

Similarly, the description should be written in such a way that it keeps the concepts separate. Feature sections in the description are essential for this; if there’s a section for prize giveaways that’s kept distinct from the section about the various casino games, it has a better chance of being approved than if both were included in a single feature list. If a user can win real money or prizes, the description must make it clear and obvious that it is not through betting or gambling. Even if the app itself is technically following the guidelines, having a description that uses language that conflates casino gameplay and real prizes may result in the reviewer interpreting the game as offering it and flag the app.

One should focus on the separation of games and prizes. Users like playing games and like winning prizes, but if they play games in order to win prizes, the App Store will take issue with it.

Perhaps most importantly, there are three important things every casino app legally needs to state in their descriptions:

This game is intended for an adult audience.
This game does not offer “real money gambling” or an opportunity to win real money or prizes.
Practice or success on social casino gaming does not imply future success at “real money gambling.”

App Store Optimization

The key to staying compliant while appealing to users lies in App Store Optimization. ASO includes understanding how the App Store and Google Play Store index apps, so casino game apps can appear in search results for the games they offer while staying within the store’s guidelines. Even if an app cannot include certain gambling terms in the description, it can still rank for them in searches by including them in the App Store’s hidden keyword bank at a lower risk of violating the policies.

Designing engaging creatives and a well-written description are also major components of ASO and are essential to making it evident to users and the stores that the app is compliant with every guideline for gambling games. Explaining upfront how games and giveaways work within the guidelines of the stores can improve its chances of success.

It’s important to understand and follow every guideline to work with the stores. If an app is removed, it will have to begin indexing and ranking for keywords anew once it’s restored. This can be avoided with proper App Store Optimization and an understanding of how an app - even a casino app – can stay compliant with the rules.