SABA has read the media release headed National Gambling Board clarifies regulatory position on Remote Gambling Servers (RGS) dated 27 February 2026, as published on the website of the National Gambling Board (“NGB”). While the document in question is said to have been issued in terms of sections 33 and 34 of the National Gambling Act, No. 7 of 2004 (“the National Act”), it should be placed on record, as a starting point, that sections 33 and 34 of the National Act do not empower the NGB to issue any authoritative statements regarding the prevailing legislative and/or regulatory requirements of the National Act or any other legislation.
The media release, and all the directives which the NGB has recently given to provincial licensing authorities (“PLAs”) are based on a single assumption, which is presented as a fact. That assumption is that remote gaming servers (“as systems designed to facilitate interactive or remote gambling activities”) are being used by licensed bookmakers as a means of offering interactive gambling games, as defined in the National Act, for play by the public, which is outlawed by section 11 of the National Act. In amplification of this position, the NGB cites the definition of “interactive game” contained in the National Act, which is “a gambling game played or available to be played through the mechanism of an electronic agent accessed over the Internet other than a game that can be accessed for play only in licensed premises, and only if the licensee of any such premises is authorized to make such a game available for play”. As a result, only if it can be demonstrated that licensed bookmakers in South Africa are indeed offering interactive games (as defined in the National Act), can it properly be said that they are in contravention of the National Act, and that these business operations are unlawful.
The truth of the matter is that licensed bookmakers throughout the country do not offer interactive games as a matter of law. This is because an interactive game is defined in the National Act as being a gambling game, and section 6(2) of the National Act expressly provides that a bet or wager entered into by a bookmaker is not a gambling game. It follows that if a bet or wager offered by a bookmaker is not a gambling game, then it also cannot be an interactive game. There is accordingly no legal basis for the contention that bookmakers anywhere in the country are making interactive games available for play by the public, or that their operations are unlawful when in reality, what they are offering are fixed odds contingency betting, as they are entitled to do in terms of the National Act. This being the case, it is likewise incorrect to contend that remote gaming servers are unlawfully being used as a platform by bookmakers to offer interactive games to the public.
It is also stated in the NGB media release that “the scope of technical standards that are applicable only to lawful gambling systems do not cover RGS” and that “the South African National Standard SANS 1718-4:2018 (Edition 3) applies only to Wagering and Record Keeping Systems (WRS) and as such does not provide for the testing or certification of RGS as standalone systems”. These remarks, which appear to be aimed at founding the conclusion that remote gambling servers cannot lawfully be tested in South Africa, are presented without the necessary context, and are based on certain fallacious assumptions, which are explored below.
The media release assumes that the use of Remote Gaming Servers is indicative of interactive gambling. This assumption evinces a misunderstanding of modern gambling system architecture. A Remote Game Server is not a gambling activity in itself. It is a software architecture component used to host game logic, outcome determination or event processing functions within a regulated gambling system. Remote Game Servers form part of a distributed system architecture and are not visible to, or directly interacted with by, the player participating in a wager. Remote Game Servers are commonly used in regulated gambling environments worldwide to host game logic and outcome processing functions within distributed gaming architectures, and their use is not in itself indicative of interactive gambling.
From a technical architecture perspective, sportsbook platforms operate in exactly this manner. Sportsbook systems used by licensed bookmakers in South Africa rely on remote server infrastructure to host wagering logic, market management and outcome processing. Sportsbook platforms are lawful in South Africa and are certified under SANS 1718-4:2018, which governs wagering and record keeping systems used by licensed bookmakers. From a systems architecture perspective, the server infrastructure supporting a sportsbook platform performs the same functional role as a Remote Game Server within a distributed gaming architecture. Despite the use of remote server infrastructure, sportsbook platforms have never been classified as interactive gambling under the National Gambling Act 7 of 2004, because the wager is linked to an external contingency or event rather than a remotely executed gambling game.
The presence of a remote server therefore does not determine the regulatory classification of the gambling activity. That classification must instead be determined by the nature of the wager and the manner in which the player participates in the event. It follows that licensed bookmakers in South Africa are not in contravention of the National Act, as contended in the media release. SABA believes that the interests of fairness and accuracy demand, firstly, that the betting public should be placed in an informed position regarding the provisions of the applicable law, and secondly, that the legitimate operations of licensed bookmakers should not unjustifiably be portrayed as being in defiance of the law.
SEAN COLEMAN
CHIEF EXECUTIVE OFFICER
Founded in 1951, the South African Bookmakers’ Association is the leading voluntary association for bookmakers and represents the interests of its members in the gambling industry.
