What Auditors Want: WLA Level 4 Certification

Key insights from digitalRG’s webinar with the World Lottery Association

Achieving Level 4 certification under the World Lottery Association Responsible Gaming Framework represents one of the most advanced stages of responsible gaming implementation for lotteries. At this level, organisations must demonstrate not only that policies exist, but that responsible gaming principles are embedded across their operations.

In February 2025, digitalRG hosted the webinar “WLA Level 4: What Auditors Want”, bringing together industry experts and auditors to discuss how Level 4 certification is assessed and what organisations should expect during the audit process.

The session featured Luca Esposito Poleo, Executive Director of the WLA, alongside experienced independent auditors Sarah Ramanauskas and Mike Randall, who shared practical perspectives on how Level 4 audits are conducted and what organisations should prepare when pursuing certification.

Below are some of the key themes discussed during the webinar.

Certification as Evidence of Commitment

One of the central messages of the webinar was that Level 4 certification focuses on demonstrating real-world implementation.

While earlier levels of the framework concentrate on establishing policies and processes, Level 4 requires organisations to show that responsible gaming measures are actively implemented in practice.

As highlighted during the discussion:

➝ "Certification matters because it transforms commitment into evidence.”

For lotteries, this means demonstrating that responsible gaming initiatives are not only planned, but embedded into day-to-day operations.

The Role of the Independent External Audit

A key requirement for Level 4 certification is the independent external audit.

Unlike earlier stages of the framework, which rely more heavily on self-assessment, Level 4 requires an external review conducted by an independent auditor. This audit evaluates whether the organisation’s responsible gaming activities align with the framework and whether the evidence provided supports the submission.

The audit plays an important role in ensuring the credibility and consistency of the certification process.

Understanding the Difference: Auditor vs Independent Assessment Panel

The webinar also clarified the difference between the external auditor and the Independent Assessment Panel.

The auditor conducts the independent review and evaluates the evidence provided by the organisation. The Independent Assessment Panel then reviews the full submission, including the auditor’s report, before determining whether the organisation meets the requirements for Level 4 certification.

Understanding these roles helps organisations better navigate the certification process.

A Constructive Approach to Auditing

Another important point raised during the discussion was that the Level 4 audit should be viewed as a constructive process.

Auditors aim to assess evidence objectively while also helping organisations understand how their responsible gaming practices align with the framework. In many cases, the audit can provide valuable insights that support the continued development of responsible gaming programmes.

Evidence as the Foundation of Level 4

Collecting and presenting clear evidence is an essential part of the Level 4 certification process.

Organisations must demonstrate how responsible gaming policies are implemented across their operations, supported by documentation and examples of relevant initiatives.

While this process requires preparation, it also helps organisations better understand and strengthen their responsible gaming activities.

Common Challenges Organisations Face

The webinar also highlighted some common challenges organisations may encounter when preparing for Level 4 certification.

These can include aligning responsible gaming strategies with measurable outcomes, ensuring that initiatives are properly documented, and coordinating responsible gaming activities across different departments.

Recognising these challenges early can help organisations prepare more effectively for the certification process.

Preparing for a Level 4 Certification Audit

For lotteries considering Level 4 certification, preparation is an important step.

Engaging with auditors early, maintaining clear documentation, and ensuring responsible gaming principles are embedded throughout the organisation can all help support a smoother audit process.

A Rigorous but Valuable Process

Achieving Level 4 certification requires significant preparation, but it also strengthens organisational practices.

By gathering evidence, reviewing internal programmes, and undergoing independent verification, lotteries can demonstrate their commitment to responsible gaming in a credible and transparent way.

Access the Full Insights and Webinar Recording

A more in-depth Insights article, including detailed explanations of the audit process and additional takeaways from the discussion, is available to digitalRG Premium members.

Premium members can also access the full webinar recording, featuring insights from the World Lottery Association and experienced independent auditors.

To find out more about membership and how digitalRG can support your organisation with tools, templates, and expert-led insights, contact hello@digitalrg.com or book time for a chat here: www.calendly.com/silverfish/15min.