ANJ sets stricter evidence guidance for online gambling fraud in France

France’s Autorité Nationale des Jeux (ANJ) has issued a new practical guide aimed at helping licensed operators handle suspected player fraud with greater consistency and stronger evidentiary support. Published on 31 August 2026, the guidance explains how existing legal and regulatory requirements should be applied when operators consider measures affecting player accounts or balances. It does not introduce new legal obligations. Instead, it provides a more detailed compliance framework for situations where fraud has to be established and documented.

ANJ clarifies the purpose of the new guidance

The ANJ describes the document as a soft-law instrument designed to address recurring questions from operators concerning fraud committed by players using online accounts. The regulator said the guide was developed following consultation with licensed operators and discussions with the gaming ombudsman.

Its central objective is practical. Operators are expected to assess cases individually, collect sufficient evidence and determine what action is appropriate under the existing legal framework. The guide also reviews relevant French case law to illustrate the level of proof that may be expected when an operator’s decision is challenged.

This distinction is important for the online gambling sector. The ANJ is not presenting the document as a new set of statutory duties. Rather, it is seeking to improve the way operators apply rules that are already in force, particularly when fraud allegations could affect a player’s account, wagers or funds.

Stronger focus on evidence rather than suspicion

One of the most significant features of the guidance is its emphasis on evidence. The ANJ states that operators need sufficiently probative elements to establish fraud. A suspicion or isolated technical signal may not, by itself, provide an adequate basis for a major account decision.

The guide refers to evidence reviewed in previous disputes and highlights the value of multiple indicators considered together. Depending on the circumstances, this can include account activity, connection records, device information and timing data. Such material can contribute to what may be described as “converging indicators” when several pieces of evidence point toward the same conclusion.

For operators, the practical implication is that fraud detection cannot be viewed solely as a technical exercise. Detection systems may generate alerts, but the resulting case must also be documented in a way that can withstand regulatory review or a legal challenge.

The guide covers several forms of player fraud

The official guide sets out a non-exhaustive typology covering identity fraud, payment-related fraud, abusive banking repudiation, fraud involving games and “money dumping”. The document also addresses sporting manipulation within its treatment of gaming fraud. This is more precise than describing the guide simply as a list of six standalone fraud categories.

Identity-related fraud includes situations such as falsified documents, intentional alteration of identity information, identity misuse, account sharing and multiple accounts where fraudulent intent has been established. The ANJ also considers attempts to bypass identity verification, including circumstances involving underage persons or individuals subject to voluntary exclusion or self-exclusion.

Payment fraud is another major area because licensed operators must ensure that funds are linked to an appropriate payment account. Where the operator cannot establish the necessary relationship between the player’s verified identity and the payment account, the treatment of the balance can be affected.

The guide also deals with abusive bank repudiation and gaming-related fraud. In poker, this can include collusion and the use of prohibited automated assistance. The document notes that collecting sufficient evidence can be difficult in these cases and therefore underlines the importance of a detailed record of the relevant circumstances.

Account closures require a documented basis

The guidance has particular relevance for account closures. The ANJ explains that operators may take action where fraud has been properly characterised under the applicable legal framework. At the same time, it expects operators to distinguish deliberate fraudulent conduct from circumstances that may result from a simple input mistake or another non-fraudulent explanation.

This is especially relevant to identity information. The guide expressly encourages operators to exercise discernment when determining whether incorrect information reflects fraudulent intent or merely a material error. That approach can help limit disputes in cases where an automated compliance process might otherwise treat every inconsistency as evidence of misconduct.

The ANJ also states that players whose accounts have been closed for established fraud cannot simply open another account with the same operator without restriction. The circumstances and duration have to be assessed according to the nature and extent of the fraud while remaining within the applicable legal framework.

Player balances receive specific treatment

The treatment of funds is another central element of the guide. French rules require operators to ensure that a player’s available funds are returned to an appropriate payment account associated with that player.

Where identity fraud means that the operator cannot reliably confirm the identity of the account holder or the ownership of the payment account, the ANJ states that the balance may have to be placed in reserve rather than transferred. The guide also provides distinctions for multiple accounts and situations where the legitimate identity of a player can still be established through another account.

The approach is designed to avoid treating every balance connected to a disputed account in exactly the same way. Instead, operators are expected to examine the circumstances surrounding the funds and apply the relevant legal provisions to the specific case.

Technical safeguards are also part of the compliance picture

The guidance places attention on account takeover risks and technical safeguards. In this context, the ANJ refers to existing technical requirements that include two-factor authentication for financial withdrawals and changes to banking information.

The objective is not simply to prevent unauthorised access. Strong authentication can also provide an additional layer of evidence when an operator is reconstructing account activity following a suspected compromise.

For compliance teams, this reinforces the importance of preserving reliable technical records. Device information, connection activity and transaction histories may become important when determining whether suspicious behaviour reflects genuine fraud, account compromise or another explanation.

Poker, money dumping and sporting manipulation

The guidance also addresses more specialised forms of conduct. In poker, the ANJ considers situations involving collusion and prohibited assistance tools. The regulator explains that contractual mechanisms may allow certain illegitimate winnings to be redistributed where the circumstances and supporting evidence justify such action.

The document separately discusses “money dumping”, including cases where funds may be transferred between players under circumstances covered by the guide. Depending on the facts, the ANJ sets out recommendations on reversing affected transactions before accounts are closed.

Sporting manipulation receives separate attention as well. Where manipulation has been established and the relevant evidence is sufficient, the guide indicates that bets connected with the manipulated competition may be cancelled. However, the remaining legitimate balance should generally be returned to the account holder unless there is a further basis for treating that balance as fraudulent.

Contract terms must remain proportionate

The ANJ also discusses contractual penalty clauses that operators may use in response to established fraud. While such clauses may have a legitimate contractual purpose, the regulator highlights consumer protection rules concerning disproportionate financial penalties.

Operators are therefore encouraged to define clearly which contractual breaches may trigger an indemnity and how the amount is calculated. Where a penalty is based on a percentage of a balance, deposits or stakes, the ANJ recommends using an absolute maximum as well.

This part of the guidance may be particularly relevant to future disputes because a clause that appears broad or punitive may receive greater scrutiny if its financial impact is difficult to justify in proportion to the actual loss.

What the guidance means for online gambling operators

The publication gives French operators a clearer framework for dealing with suspected player fraud without suggesting that every suspicious account should automatically be closed or every disputed balance should be withheld.

Instead, the emphasis is on documented reasoning. Operators will need to ensure that fraud detection systems, KYC processes, contractual terms and technical security controls work together. Evidence should be preserved in a form that allows the operator to explain how a conclusion was reached and why the resulting action was appropriate.

The ANJ’s wider compliance work in 2026 also shows that the regulator is paying close attention to the quality of operators’ control systems. The fraud guide therefore fits into a broader regulatory approach focused on demonstrable compliance rather than policies that exist only on paper.

A more evidence-led compliance environment

For the French online gambling market, the guide represents a significant clarification of how operators should approach fraud-related disputes. Its message is measured rather than punitive. Fraud controls remain necessary, but decisions affecting players should be supported by evidence and applied with care.

The emphasis on case-by-case analysis may also help create greater consistency across the market. Instead of relying on general suspicion or isolated technical indicators, operators are being encouraged to build complete evidentiary records and align their decisions with applicable law, contractual terms and established judicial principles.

Ultimately, the ANJ’s approach points toward a more disciplined compliance environment in which fraud prevention and player rights must be considered together. For operators, the priority is not simply detecting unusual behaviour. It is being able to demonstrate clearly why a case meets the relevant standard and why the response taken is legally and contractually justified.

Conclusion

The ANJ’s new guidance provides French online gambling operators with a more detailed roadmap for handling player fraud while maintaining a clear distinction between existing legal duties and regulatory recommendations. Its strongest message is the need for reliable evidence, careful case assessment and proportionate action.

As online gambling systems become increasingly data-driven, technical records are likely to play a greater role in fraud investigations and account disputes. Yet the guidance makes clear that technology alone is not enough. Decisions should be supported by a coherent body of evidence and applied within the boundaries of French law and consumer protection principles.

For operators active in France, the publication is therefore more than a reference document. It is a practical reminder that strong fraud controls must be matched by strong documentation, transparent contractual rules and defensible decision-making. That combination will be increasingly important as regulatory expectations around integrity, player protection and compliance continue to evolve.

FAQs

What is the ANJ’s new player fraud guide?
The ANJ’s new guide explains how licensed operators should apply existing legal and regulatory requirements when identifying, documenting and responding to player fraud.

Does the ANJ guide create new legal obligations?
No. The ANJ states that the guide does not create new obligations. It is intended to support compliance with rules that already apply to licensed operators.

What types of fraud does the ANJ guide cover?
The guide covers identity fraud, payment fraud, abusive banking repudiation, gaming-related fraud and money dumping. Sporting manipulation is also addressed within the guide’s treatment of fraud involving games and betting activity.

What evidence can operators use to establish suspected fraud?
Depending on the case, operators may rely on multiple forms of information including account records, device data, connection information and transaction activity. Several indicators considered together can strengthen the evidentiary basis.

Can an operator close an account because of suspected fraud?
Account closure should be based on an established case of fraud and the applicable legal and contractual framework. The ANJ emphasises the need for sufficient evidence rather than suspicion alone.

Can a gambling operator withhold a player’s balance?
The treatment of a balance depends on the nature of the fraud and the applicable law. In certain identity-related cases, funds may need to be placed in reserve when the operator cannot verify the identity of the player or payment account.

Does the guidance apply to all gambling activity in France?
The guide applies to offers involving online player registration and player accounts. It does not apply to gambling activity conducted solely through physical distribution without online registration.

Does the guide cover hacked player accounts?
Yes. The ANJ addresses account takeover and explains that the treatment of funds can depend on whether transactions occurred and whether the operator contributed to the loss through a failure.

Does the guidance apply to poker fraud?
Yes. The guide covers issues including poker collusion and the use of prohibited automated assistance. It also discusses the evidentiary challenges associated with identifying these activities.

Why is evidence important for gambling operators?
Evidence helps operators demonstrate that a fraud-related decision was based on identifiable facts rather than an unsupported allegation. This can be particularly important when an account closure, bet cancellation or balance decision is challenged.