The requirement has been known for two years. Compliance rates across the gambling sector suggest it has not been treated with corresponding urgency.
Every script running on a payment page must now be inventoried, authorised, and documented in real time. For a standard e-commerce site, that scope is manageable. For an online gambling platform carrying affiliate tracking tags, advertising pixels, and analytics tools on the same pages that process deposits, the scope is substantially more complex.
Marketing and affiliate teams have operated payment pages as a distribution point for tracking infrastructure. That practice is now a security obligation and an audit target. The two functions most likely to experience friction are payments operations, who carry the compliance burden, and marketing, who face a new approval gate before any script can run.
Gambling operators licensing in the UK, Malta, and Gibraltar face an additional layer: these regulators incorporate payment card security compliance into technical licensing audits. Non-compliance is not just a card processing risk. It is a licensing risk.
The operators in the most exposed position are those who built affiliate tracking infrastructure on payment pages without separating it from payment processing scripts. The work to separate them is not trivial on legacy platforms, and the risk of losing acquiring relationships during remediation is material.
The standard has been in full force for over a year. The window for treating this as a future project is closed.
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