The Malta AI Gaming Charter on the Ethical and Responsible Use of Artificial Intelligence (the “Charter”) has been jointly announced by the Malta Gaming Authority (“MGA”) and the Malta Digital Innovation Authority (“MDIA”). The initiative was unveiled at the SBC Malta Conference held in April and confirms Malta’s continued willingness to address emerging technological developments within its gaming regulatory perimeter. Since its inception in 2004, the MGA has consistently positioned itself at the forefront of technological change, supported by the legislator’s deliberate choice to keep the principal gaming legislation technology neutral. The Malta AI Gaming Charter represents the latest step in that trajectory, with a specific focus on the use of artificial intelligence (“AI”) in regulated online gaming.
Scope and Purpose of the Charter
Artificial intelligence is no longer a forward-looking consideration for gaming operators. AI systems are already embedded across day-to-day operational functions, including fraud detection, responsible gambling tools, customer service chatbots, marketing personalisation, and compliance monitoring. The technology is delivering measurable operational outputs across the sector. The regulatory question is therefore no longer whether operators should adopt AI, but how its deployment should be managed in light of game evolution, responsible gaming obligations, data protection requirements, ethical considerations and broader consumer protection objectives.
The MGA and the MDIA have described the upcoming Charter as voluntary and principles-based and have indicated that it will be designed to complement existing legal frameworks, including the EU Artificial Intelligence Act (the “EU AI Act”). The Charter is intended to provide sector-specific guidance tailored to the operational realities of the online gaming industry, rather than to introduce a new layer of binding obligations. The MGA has been clear that adherence to the Charter will not constitute a regulatory obligation for licensees, and that the instrument is intended to operate alongside, rather than in substitution of, the existing regulatory framework applicable to AI deployment.
Developing the Malta AI Gaming Charter through Consultation
One of the defining features of the initiative is the manner in which the Charter is being developed. The MGA has signalled a clear intention to involve industry stakeholders in the design of the Charter itself, with the objective of ensuring that resulting guidance reflects how AI is being deployed in practice and the direction in which industry use is evolving. On 8 May 2026, the MGA officially announced the launch of a targeted consultation process. The Charter is therefore not expected to emerge from a regulator operating in isolation, but rather from a structured engagement between the regulator, operators, and other interested parties.
The collaborative approach adopted by the MGA is significant for two reasons. First, the voluntary nature of the instrument gives operators meaningful space to engage constructively. Rather than having principles imposed on a top-down basis, the consultation process provides an opportunity for licensees to shape guidance that reflects operational realities and existing compliance investments. Second, alignment with the EU AI Act is, in practice, unavoidable for any operator of scale. The EU AI Act introduces a risk-based approach to AI regulation, with substantive obligations for both providers and deployers of AI systems. Sector-specific guidance from the MGA that maps coherently onto that framework offers licensees a structured basis on which to translate horizontal EU obligations into the operational context of regulated gaming.
Strategic Considerations for Licensees
For MGA licensees, the consultation phase of the Malta AI Gaming Charter represents an opportunity to influence the form and content of the instrument before its finalisation. Operators are well placed to identify use cases that may benefit from clarification, areas where overlap with the EU AI Act may produce uncertainty, and practical thresholds that should be reflected in the eventual text. Early engagement is likely to be more effective than reactive compliance once the Charter has been finalised, particularly given the cross-cutting nature of AI deployment across operational, marketing, compliance, and responsible gaming functions.
Operators should also consider the Charter in the context of their broader AI governance posture. Even where adherence to the Charter remains voluntary, the principles it embodies are likely to inform supervisory expectations over time and may form a useful reference point for internal policies, vendor due diligence, and board-level reporting on AI risk. Documenting AI use cases, classifying them by risk in line with the EU AI Act, and ensuring appropriate human oversight are steps that will support compliance with the horizontal EU framework regardless of the final shape of the Charter.
Outlook
Malta’s gaming sector has historically built its reputation by anticipating regulatory developments rather than reacting to them. The AI Gaming Charter is consistent with that approach and provides the industry with an opportunity to do the same. The consultation period offers a defined window within which licensees can contribute to the design of sector-specific AI guidance, while simultaneously preparing for the operational obligations arising under the EU AI Act. Operators that engage early with the Malta AI Gaming Charter, and that integrate its emerging principles into existing AI governance frameworks, will be best positioned to manage regulatory expectations as both the Charter and the wider EU framework continue to develop.
How Promethean Can Assist
Promethean advises gaming operators and technology providers on the regulatory, corporate, and governance dimensions of the Malta AI Gaming Charter and the wider EU AI framework. Our team can support licensees in preparing consultation submissions to the MGA, reviewing existing AI use cases against the risk-based requirements of the EU AI Act, and developing internal governance frameworks aligned with both instruments. For further information on how the Malta AI Gaming Charter may affect your operations, please contact us.
