Skip to content
iGaming Times

Choose your emails

Which emails would you like?

Independent industry intelligence in your inbox. We will email you a link to confirm the emails you ticked, and every email carries a one-click unsubscribe link. Each list can be left on its own.

Lesson 4 of 7 · 16 min

RFPs, Licensing and the Regulatory Path to Live

State lottery and government RFPs and how they score, the fourth National Lottery licence as a six-year case, supplier licensing in Great Britain, Malta, New Jersey, Pennsylvania and Ontario, certification, integration and a realistic forecast.

Fact-checked 5 October 2026 by iGaming Times editorial team · 23 sources

In this lesson

  • Describe the stages, scoring and commercial requirements of a public lottery RFP using published examples
  • Write a tender response that scores against an evaluation matrix
  • Compare supplier licensing and registration requirements across five regulated markets
  • Explain why certification is per market and per product
  • Build a sales forecast that dates first revenue from the latest regulatory, certification and integration gate

A signature is not revenue

In most software markets a signed contract means revenue starts soon. In regulated gambling it means the real work has started. Between the signature and the first invoice sit any combination of a public procurement process, the supplier's own licence or registration in the market, certification of every game or system by an approved test house, technical integration with the operator, and the operator's own regulatory approvals for a new supplier. Each has its own owner and its own clock, and the longest one decides the date.

Sales forecasts in this industry go wrong in a predictable way: the deal is forecast to close in the quarter it is signed and to earn from the following month, when the binding constraint is a registration that has not yet been filed. This lesson walks through the gates in order, using published regulatory and procurement documents, and ends with a method for building a forecast that survives contact with them.

The operator's side of licensing (applying for its own licence and building the compliance function) is covered in Market Entry and Licensing. This lesson is about what the supplier needs, and how a seller plans around it.

How public procurement works

State lotteries, government-owned operators and some regulators buy through formal procurement. The process is public, rule-bound and slow, and it rewards sellers who read the documents like lawyers.

The Virginia Lottery's iLottery request for proposals, issued in 2026, is a good current example. The RFP sets a contract term of five years with three three-year renewals, so a winning bidder could hold the contract for 14 years. The timetable ran from issue on 25 June 2026, through two rounds of written questions, to proposals due on 23 September 2026, with the award estimated for the second quarter of calendar 2027. That is roughly a year from issue to award, before any implementation begins.

Three features of that document matter to anyone selling into a lottery:

Price is a small part of the score. The evaluation awards 4,260 points in total, of which pricing carries 430, about a tenth. Meeting minimum requirements, solution capability, strategic recommendations, case studies and small-business participation carry the rest. A bid that wins on price and loses on case studies loses.

The commercial model is specified for you. Bidders must propose a percentage of net gaming revenue for eInstant sales, and that percentage must cover geolocation, payment processing and other system costs. The Lottery publishes its own planning assumptions, including an estimated eInstant payout rate of 89 per cent of gross sales and promotions at 10 per cent of GGR, which tells bidders exactly how their percentage will translate into income.

Commitment is secured with bonds. Bidders must provide both a proposal bond and a protest bond, the latter to discourage frivolous challenges to the award.

Delaware's 2023 procurement for an internet wagering system shows a different weighting. Its RFP scored proposals out of 500 points, 400 for the technical proposal and 100 for pricing, required prices to be quoted "as a percentage of Net Gaming Revenue, carried to four (4) decimal places", and stated that "TBD pricing is not allowed". It ran from issue on 12 January 2023 to proposals due on 17 February and vendor presentations in March, and the contract covered an implementation period plus five years of production with five optional one-year extensions. Successful vendors had to post a fidelity bond of US$5 million for the primary vendor. The document also states plainly that "neither the lowest price nor highest scoring Proposal will necessarily be selected for negotiations".

Government buyers outside the United States work in similar ways. Ontario Lottery and Gaming Corporation posts its procurement opportunities on the MERX public tenders service and notes that vendors may need to register with the provincial regulator. In the European Union, state lottery companies publish tenders in the Official Journal. A 2025 Svenska Spel tender for identity verification software on its retail terminals, published on TED, weighted quality at 65 per cent and price at 35 per cent, and received a single tender. A single bidder is more common than outsiders assume: specialist requirements, bonds and local registration narrow the field before anyone prices.

Writing a response that scores

A public tender response is marked by an evaluation panel against published criteria, often by people who have never met the bidder. Several practices raise scores.

Answer the question asked, in the order asked. Evaluators score against a matrix. A response that reorganises the material to tell the supplier's own story makes the evaluator hunt for answers and loses marks for things it actually does.

Treat mandatory requirements as pass or fail. A missing bond, an unsigned form or a late submission can disqualify a technically superior bid before it is read. Delaware's RFP, for example, disallows protests about errors in the solicitation that were not raised in writing at least ten calendar days before proposals were due. A compliance checklist owned by one named person, completed before anything else, is the cheapest insurance a bid team can buy.

Use the clarification rounds. Written questions are the only chance to influence the buyer's assumptions before pricing. In Virginia's 2026 process, the Lottery's second addendum answered a bidder who pointed out that the published deposit assumption of 27 per cent of eInstant sales did not match the Lottery's own figures by updating it to 22 per cent, and removed first-party games from the eInstant pricing in response to another question. Good questions change the commercial basis of a tender.

Prove, do not claim. Case studies, reference sites and performance data from comparable lotteries or operators carry weight; adjectives do not. Where an RFP scores case studies, as Virginia's does, they deserve the same effort as the technical solution.

Price the specification, then show the options. Bid exactly what was asked for at a defensible price. Where the buyer permits alternatives, offer them separately, so the compliant bid is never compromised.

When procurement takes years

The competition for the fourth UK National Lottery licence is the extreme case, and every seller targeting government business should know its outline.

The Gambling Commission launched the competition on 28 August 2020, saying the preferred applicant would be announced in September 2021. It was named on 15 March 2022, at the start of a legal standstill period to be followed by a 22-month transition. The incumbent and its technology partner challenged the decision in court, which automatically suspended the award; the Commission was able to formally award the licence in September 2022, after those appeals were withdrawn and the suspension lifted. The licence took effect on 1 February 2024. Claims by another unsuccessful bidder ran on: the High Court dismissed them in April 2026, and on 30 July 2026 the Court of Appeal refused that bidder permission to appeal, almost six years after the competition was launched.

The lesson for suppliers is not that government business is to be avoided. It is that the timeline of a large public contract is set by its legal process, not by the buyer's enthusiasm, and that a supplier attached to a bidder (as a platform or content partner) is tied to that bidder's fate for the whole period.

Supplier licensing: the gate before revenue

Most regulated markets license or register the suppliers of gambling products as well as the operators. The requirements differ by market, by product and by what the supplier actually touches.

Great Britain. Under the Gambling Act 2005, a person commits an offence if, in the course of a business, they manufacture, supply, install or adapt gambling software without an operating licence. The Gambling Commission explains that this means software that accepts and records gambling transactions and determines results, not general tools such as analytics or CRM. A studio needs a remote gambling software licence, whose fees are banded by gross gambling yield, and a studio that hosts its games for other operators' customers may also hold a host licence. The Commission's published processing time for an operating licence application is 16 weeks, an average for complete applications that it says is not guaranteed. A change of control takes 12 weeks, which matters in lesson five.

Malta. The Malta Gaming Authority issues a critical gaming supply licence, which it describes as a business to business licence, with a one-off application fee of €5,000 and annual fees for a critical gaming supply licence of €25,000 to €35,000 depending on revenue. Its application process runs through fit and proper checks, a review of funding, a business plan review and a technical review followed by a system audit; after the technical review the applicant has 60 days to complete its live environment.

New Jersey. Suppliers of internet gaming software or systems need a casino service industry enterprise licence, and the Division of Gaming Enforcement's instructions say such enterprises must be licensed "prior to conducting any business" with casino licensees. The same document describes the transactional waiver, a joint petition by the supplier and the casino licensee that allows business while the Division investigates, for an initial period of up to six months. For a seller, the waiver is the difference between revenue this quarter and revenue next year. New Jersey's regulations separately require payment, identity, age verification and geolocation vendors used in internet gaming to be licensed as ancillary enterprises.

Pennsylvania. The Gaming Control Board licenses interactive gaming manufacturers and suppliers. Its fee schedule lists an initial licence fee of US$10,000 for each, against US$1 million for an interactive gaming operator, with separate certification and registration tiers for service providers.

Ontario. The Alcohol and Gaming Commission of Ontario registers gaming-related suppliers. Its guidance says platform providers, game suppliers, customer wallet providers and odds makers are typically registrable, while payment processing without a wallet function and geolocation providers are generally not, the reverse of New Jersey's approach to the same vendors. The AGCO's roadmap to going live sets the order: certify the product with a registered testing laboratory, apply, demonstrate compliance with the Registrar's Standards, and supply only once registered.

The pattern across all five is that the same product is classified differently in each market, so a seller cannot assume that what was needed in one state is what will be needed in the next. Check the regulator's own guidance for each market on the target list.

Certification: per market, per product

A licence lets the supplier trade. Certification lets each product go live. In Great Britain, new games and random number generators can be released only once testing is complete and the report has been provided to the Commission, and the operator taking content from a supplier must still keep its own register of the games it offers.

Test laboratories such as Gaming Laboratories International and BMM Testlabs work to technical standards that regulators adopt in whole or in part. GLI-19, the standard for interactive gaming systems, says it "can be adopted in whole or in part by any regulatory body" and leaves public policy to each jurisdiction. Sports wagering systems fall under a separate standard. In practice this means a game certified for one market usually needs a further certificate, sometimes a different return-to-player configuration and sometimes additional testing, for the next. A studio with 200 games entering a new market faces 200 certification decisions, and its sales team should know which titles will be ready on launch day and which will follow.

Technical integration

Integration is the gate sellers most often underestimate because it looks like the operator's job. Content usually connects through a remote game server and the operator's wallet, either directly or via an aggregator; a platform or sportsbook replaces systems the operator already runs and requires data migration. The operator schedules integration work against its own roadmap, which is full. The detail of these integrations is in iGaming Platform and Technology.

Three practical habits shorten this gate. Agree the integration route (direct or through an aggregator the operator already uses) in the commercial negotiation, not after it. Name a technical owner on both sides before signature. And put the integration timetable in the contract with dependencies on both parties, so a slipped date can be discussed as a shared problem rather than a supplier failure.

Building a forecast that reflects reality

The method is to forecast the date of first revenue as the latest of the gates, then ramp revenue from that date.

Here is a hypothetical example. A slot studio already licensed in Great Britain signs a content agreement in January with an operator live in Great Britain, Ontario and New Jersey. The planning assumptions below are illustrative, not regulator timelines; the studio should replace each with its own experience and the regulator's published guidance.

Market Supplier licence status Certification Integration Earliest realistic revenue
Great Britain Held Existing certificates for most titles Via an aggregator the operator already uses, about 6 weeks Late February
Ontario Registration needed, application not yet filed Lab certification required before registration Same integration Not before registration, so plan for H2 at the earliest
New Jersey Licence needed, application not filed Lab certification for New Jersey Same integration After a transactional waiver is granted, so plan for Q3

A forecast that books the whole contract value from February overstates the first year badly. A better forecast books Great Britain from late February at a ramped rate, and books Ontario and New Jersey as separate line items with their own dates and probabilities, each tied to an action (file the registration, petition for the waiver) that the sales team can track. Weight each line by both the probability of the commercial close and the probability that each gate opens on time.

When the market moves under you

Regulatory risk does not end at go-live. At the time of writing in October 2026, Brazil's Secretariat of Prizes and Bets states on its own authorisation page that Provisional Measure 1.394 of 25 September 2026 prohibited the operation, offer and advertising of fixed-odds betting across Brazil, less than two years after the regulated market opened. Suppliers that had built pipelines around Brazilian operators now face contracts whose customers may lose the right to operate. The practical lessons for sellers are to keep any single new market to a share of the forecast the business could lose, and to make sure contracts deal with the loss of a customer's licence, which lesson five covers.

Key terms

Request for proposals (RFP)
A formal public procurement document setting out requirements, evaluation criteria, timetable and contract terms for bidders.
Proposal and protest bonds
Sureties a bidder posts to guarantee its proposal and to discourage unwarranted challenges to an award.
Casino service industry enterprise licence
New Jersey’s licence for suppliers of gaming-related goods and services, required before doing business with casino licensees.
Transactional waiver
New Jersey permission, sought jointly with a casino licensee, for a supplier to do business while its licence application is investigated.
Gaming-related supplier
Ontario’s registration category for suppliers such as platforms, game studios, wallet providers and odds makers serving the regulated market.

Key takeaways

  • In regulated gambling a signature starts the work; the longest of procurement, licensing, certification and integration decides when revenue starts.
  • Price can be a small share of a lottery tender score: about a tenth of the points in Virginia’s 2026 iLottery RFP.
  • The same product is classified differently by each regulator, so licensing must be checked market by market.
  • New Jersey’s transactional waiver can let a supplier trade while its licence application is investigated, which can move revenue forward by quarters.
  • Keep any single new market to a share of the forecast the business could lose: Brazil prohibited fixed-odds betting by provisional measure in September 2026.

Sources

The legislation, regulator material and research this lesson was checked against.

  1. Virginia Lottery RFP 13179MG: iLottery System, Services and Support, Virginia Lottery, accessed 2026-10-05
  2. Virginia Lottery iLottery RFP Addendum 2, Virginia Lottery, accessed 2026-10-05
  3. Delaware State Lottery RFP FIN23001-IWSSS: Internet Wagering System and Services Solution, State of Delaware, accessed 2026-10-05
  4. Procurement, Ontario Lottery and Gaming Corporation, accessed 2026-10-05
  5. Contract award notice 805867-2025 (AB Svenska Spel), Tenders Electronic Daily, Publications Office of the European Union, accessed 2026-10-05
  6. Fourth National Lottery licence competition launched, Gambling Commission, accessed 2026-10-05
  7. Allwyn named preferred applicant for fourth National Lottery licence, Gambling Commission, accessed 2026-10-05
  8. Fourth National Lottery licence formally awarded to Allwyn, Gambling Commission, accessed 2026-10-05
  9. Fourth National Lottery licence begins with Allwyn as new operator, Gambling Commission, accessed 2026-10-05
  10. Court of Appeal refuses TNLC permission to appeal, Gambling Commission, accessed 2026-10-05
  11. Gambling Act 2005, section 41, legislation.gov.uk, accessed 2026-10-05
  12. Remote gambling software licence, Gambling Commission, accessed 2026-10-05
  13. Licence application processing times, Gambling Commission, accessed 2026-10-05
  14. Game Providers and Back Office (B2B licences), Malta Gaming Authority, accessed 2026-10-05
  15. Guidance Note: Application Process, Malta Gaming Authority, accessed 2026-10-05
  16. Instructions for Filing an Application for a Casino Service Industry Enterprise License, New Jersey Division of Gaming Enforcement, accessed 2026-10-05
  17. N.J.A.C. 13:69J: Casino service industry enterprises, New Jersey Division of Gaming Enforcement, accessed 2026-10-05
  18. License, Registration, Certification, Permit and Application Fees, Pennsylvania Gaming Control Board, accessed 2026-10-05
  19. Internet Gaming Suppliers Application Guide, Alcohol and Gaming Commission of Ontario, accessed 2026-10-05
  20. Prospective Gaming Related Supplier Roadmap to Going Live in Ontario, Alcohol and Gaming Commission of Ontario, accessed 2026-10-05
  21. Testing strategy for compliance with remote gambling and software technical standards: procedure for testing, Gambling Commission, accessed 2026-10-05
  22. GLI-19: Standards for Interactive Gaming Systems, version 3.0, Gaming Laboratories International, accessed 2026-10-05
  23. Subsecretaria de Autorização (notice of Medida Provisória nº 1.394/2026), Ministério da Fazenda, Secretaria de Prêmios e Apostas, accessed 2026-10-05

Check your understanding

3 questions · answer them all, then check.

  1. 1. In Virginia’s 2026 iLottery RFP, approximately what share of the total evaluation points did pricing carry?

  2. 2. A studio licensed in Great Britain signs with an operator live in Great Britain, Ontario and New Jersey. What should drive the forecast date for Ontario revenue?

  3. 3. How do Ontario and New Jersey differ in their treatment of geolocation providers?

Sign in to track your progress through the course.

Cookie Preferences

Choose which cookies you want to accept. Essential cookies are required for the website to function properly.

Required

Necessary for the website to function. Cannot be disabled.

Help us understand how visitors interact with our website.

Used to deliver relevant advertisements and track ad performance.

Remember your preferences and settings for a better experience.