The development of the Open Banking vNext ecosystem has led to the emergence of Variable Recurring Payments (VRP) technology.
For the iGaming industry, especially when working with high-income clients (VIPs and high rollers), this tool opens a new deposit management format. The solution combines the convenience of automatic payments and a seamless user experience, and compliance with strict regulatory requirements, as well as AML standards.
Variable Recurring Payments in iGaming
Variable Recurring Payments (VRP) are an Open Banking mechanism for recurring payments whose amounts and timing can vary within pre-agreed limits. In iGaming, the Technology Is Particularly Relevant for:
-
VIP customers -
high rollers -
recurring high-value deposits -
payment flows subject to strict AML and Responsible Gambling controls
Its core value is reducing repeated payment authentication while maintaining clear limits and transaction controls. The VIP Payment Friction Problem
Traditional cards and basic PISP payments may require repeated Strong Customer Authentication (SCA). This Can Involve:
-
switching to a banking app -
entering SMS codes -
confirming with Face ID or biometrics -
approving individual high-value transactions
The source material cites research indicating that stronger SCA requirements can increase incomplete payments by around 37%. How Commercial VRP Works
- With Commercial VRP, the customer completes full SCA once when connecting a bank account
- A cryptographically protected Consent Token is then created
The Token Defines:
- maximum amount per transaction
- aggregate daily, weekly, or monthly limits
- consent expiration date
Two Types of VRP
Sweeping VRP
- transfers between accounts owned by the same person
- commonly used for savings and money management
- typically more tightly standardized
Commercial / Non-Sweeping VRP
- payments from a consumer to a commercial merchant
- potentially applicable to iGaming operators
- governed through agreements between banks and PISP/TPP providers
VRP vs Direct Debit
Direct Debit
- relies on clearing cycles
- settlement may take days
- can involve payment recalls and cancellations
VRP
- near-real-time processing
- can work with Faster Payments and SEPA Instant
- uses direct bank API connectivity
- removes parts of the traditional card-processing chain
- may reduce payment costs
Two-Layer Limit Architecture
Hard Limits
-
stored within the Consent Token -
represent the absolute ceiling -
changes require renewed SCA
Soft Limits
-
controlled by the operator’s Risk Engine -
can be reduced dynamically -
operate in real time below the bank-authorized maximum
Regional Implementation
United Kingdom
- credit cards are prohibited for gambling
- VRP can provide an alternative account-to-account deposit route
- real-time control is a major advantage
Malta
- implementation must align with European payment regulation
- transaction-data processing must also comply with GDPR
Sweden
- payment flows need to account for self-exclusion frameworks such as Spelpaus
- user status must be checked before transactions are authorized
Offshore Jurisdictions
- direct bank API access may be more limited
- implementation can depend on cross-border TPP/PISP infrastructure
VRP and Source of Funds
Combining AISP + PISP Functionality Allows an Operator to:
- initiate payments
- analyze verified account information
This Can Support:
- bank account ownership matching
- KYC cross-checking
- liquidity assessment
- transaction-history analysis
- identification of recurring legitimate income
- automated financial profiling across 180–365 days
Automated SoF Scoring
Account Ownership
Bank details can be matched against the registered KYC profile
Affordability
The system can monitor available funds and potential overdraft exposure
SoF Scoring
Historical transactions can be analyzed for dividends, business income, salary flows, and other legitimate sources of funds
This can reduce reliance on manual PDF statements and additional documents. Technical Security
Key Mechanisms Include:
- FAPI 2.0
- mutual TLS
- cryptographic certificates
- bank-side authentication
- isolation of sensitive financial credentials
The operator does not directly handle PINs or similar bank authentication data. VIP Payment Experience
Benefits Include:
-
fewer payment steps -
faster deposits -
transparent limits -
personalized payment journeys -
documented customer consent -
lower risk of payment disputes
VRP enables a Tiered Deposit Experience with payment corridors adapted to individual VIP profiles. VRP Integration Process
A Typical Deployment Includes:
- selecting a PISP/TPP provider
- API integration
- connecting the operator Risk Engine
- Sandbox testing
- pilot deployment for selected VIP users
- final approval
- full-scale rollout
Why Failover Matters
A resilient architecture should support: VRP → Standard PISP → Alternative Payment Method.
This maintains conversion and customer experience when a specific bank does not support VRP. Key Regulatory Risks
Self-Exclusion
When GAMSTOP, OASIS, or another exclusion mechanism is triggered, the operator needs to: block the player account, stop pending payment requests, cancel relevant VRP permissions or flows
Internal Limit Breaches
If the operator initiates payments beyond customer-configured internal limits, liability can shift to the platform
Fraud Liability
A Consent Token demonstrates authorization, but it does not remove the operator’s AML, Responsible Gambling, or internal-control obligations The Future of VRP in iGaming
The Next Stage Is Integration With:
- ISO 20022
- AI analytics
- behavioral scoring
- AML
- Responsible Gambling
- automated payment orchestration
AI Systems Could Assess in Real Time:
- VIP financial profiles
- transaction patterns
- behavioral changes
- signs of financial stress
- appropriate payment limits
Key Takeaways
- VRP enables recurring payments without requiring full SCA for every transaction
- The Consent Token defines transaction caps, aggregate limits, and validity periods
- iGaming implementations should combine bank-level Hard Limits with operator-level Soft Limits
- AISP + PISP infrastructure can automate parts of Source of Funds assessment
- VRP can reduce payment friction for VIP players but requires deep AML and Responsible Gambling integration
- Bank coverage remains uneven, making PISP failover essential
- In the longer term, VRP is likely to become part of AI-orchestrated payment infrastructure for iGaming
For a detailed consultation on the issues of connecting and customising financial gateways for
gaming projects of any kind, please contact
2WinPower specialists.
A Problem of Outflow in the VIP Segment: Wrong Payment Routines
In high-value marketing, the value of attracting and retaining clients is much greater than when working with massive traffic. At the same time, regulatory compliance checks remain one of the main drivers of churn among solvent users.
Traditional financial instruments — bank cards and basic Open Banking PISPs — create additional transaction load on players. Under heavy regulation, almost every major operation requires repeated SCA (Strong Customer Authentication).
For someone in an emotional state, the need to constantly switch to a banking app and enter SMS codes, confirm confirmations, or scan Face ID can negatively affect the user experience.
Research by Nuapay, a division of EML Payments Limited (ASX: EML), found that implementing enhanced authentication procedures increases the average number of incomplete payments by 37%.
The shift to more seamless services has a direct impact on loyalty retention. This is confirmed by the University of British Columbia (UBC) study on consumer behaviour and the Pain of Paying phenomenon.
The authors concluded that the more complex, visible, and routine the process of parting with money is, the higher the psychological barrier that prevents people from completing a transaction. Conversely, the automation and seamless integration of transfers into the interface help mitigate this obstacle and reduce the cognitive load on players.
Standardised Open Banking has already proven its effectiveness. According to global reports from the Cambridge Centre for Alternative Finance (CCAF), the conversion rate for successful authentication in mature consumer-directed finance infrastructures consistently exceeds 90%.
This advantage over traditional card acquiring was achieved through the direct integration with the banking API. Commercial VRPs expand this model for regular transactions and virtually eliminate the payment routine.
Commercial VRP Mechanics: an Alternative to Direct Debit
Variable Recurring Payments is the next stage in the development of the Direct Debit infrastructure. The technology is more compatible with the demands of the real-time digital economy.
Unlike traditional solutions, where processing occurs during clearing cycles lasting up to several days, VRP enables transactions to be processed almost instantly. Delays in the traditional model also increase the risk of chargebacks and settlement cancellations.
The tool has a different basis and supports quick request processing via Fast Payments and SEPA Instant.
In the Open Banking vNext ecosystem, it is important to distinguish between 2 types of VRP:
- Sweeping. Automatic transfers between profiles of the same owner. For example, the available funds can be sent from checking to savings accounts. This format is strictly regulated and is usually provided to users for free.
- Non-Sweeping/Commercial. Transactions from a private individual to a commercial merchant, including iGaming operators, as payment for goods or services. This is an instrument, the parameters of which are determined by agreements between banks (ASPSP) and third-party providers (PISP/TPP).
The interaction between casino owners and financial institutions is based on a long-term consent model. Customers undergo full SCA bank authentication only once, during the initial linking of their checking accounts to the platform. After this, a unique, cryptographically protected Consent Token is created.
This product allows the PISP gateway to initiate transactions directly from the client's bank account without re-verification. Funds are debited instantly, without the need to involve a long chain of intermediaries — card schemes, acquiring banks, and processing centres. Interchange fees are also reduced.
To protect both parties, some restrictions are built into the Consent Token's parameters, and they must be confirmed by VIP clients:
- maximum per-transaction amount — the largest sum of money for a single debit;
- cumulative limit for the selected period — day, week, or month;
- expiration date — a fixed period after which the token is automatically cancelled and requires repeated verification.
Flexible Restrictions and Control within Responsible Gaming
The integration of autopayments into the entertainment platform is connected with strict RG standards. Provision of high rollers with an uncontrolled channel for instant balance replenishment is a direct path to regulatory sanctions and the risk of licence revocation.
Therefore, the VRP architecture on the operator’s side must support a dynamic (flexible) limits model.
The parameters fixed in the Consent Token cannot be changed without the players going through the SCA procedure once again.
Therefore, it is recommended to build a two-tier restriction system:
- acquiring boundaries act as an absolute maximum (Hard Limits);
- the casino’s internal risk engine algorithms are superimposed over these restrictions and function as Soft Limits, allowing entrepreneurs to manage transactions in real time.
Open Banking and Gambling: Regulatory Differences among Regions
The geography of VRP implementation in the entertainment industry directly depends on the maturity of local fintech norms.
Compliance with Open Banking vNext standards and rules established by gambling commissions in different jurisdictions creates various models of technology adoption:
- The United Kingdom. The country has a complete ban on the use of credit cards to place bets. VRP effectively replaces them, providing instant transaction verification and real-time compliance control.
- Malta. The state has implemented the single PSD3European regulation, which enshrines the status of “Conditional Payments”. The document also requires compliance with the GDPR when sending the history of users’ money transfers via API aggregators.
- Sweden. The region demands that the payment token be integrated with the Spelpaus public self-exclusion system. Before authorisation, each VRP request is verified via the registry.
- Offshore jurisdictions such as Gibraltar. Direct access to the banking API is limited. The implementation of the described tool is only possible through cross-border TPP hubs with licences valid in the UK and the EU.
How VRP Simplifies Checks of the Sources of Funds

For VIP departments, confirmation of the legal origin of money (SoF) often becomes a churn risk. The need to manually provide notarised copies, certificates, or bank statements in PDF format often drives high rollers from entertainment portals.
VRP reduces this burden through a combined request model (AISP + PISP). During the SCA authentication, clients consent not only to make payments (PISP) but also to grant access to their account analytics (AISP — Account Information Service Provider).
This scheme allows the operator's compliance architecture to receive verified banking data in real time, such as:
- Comparison of the account holder. Personal details are automatically checked against the KYC information provided during registration. This eliminates the participation of third parties or corporate accounts and reduces the risk of fraud.
- Solvency and liquidity. Monitoring algorithms track the player’s current balance and prevent transactions that could lead to an overdraft.
- Automated SoF scoring. Instead of verifying the documents manually, the risk engine studies transactional history for 180–365 days.
This combined analysis identifies consistent financial patterns, such as dividends, payments from public companies, and income from legitimate businesses. Based on this data, a client’s solvency index is formed.
Compliance with the FATF Travel Rule
Since VRPs are, by their nature, direct interbank transfers (A2A), entrepreneurs are required to follow these recommendations.
When processing large transactions exceeding the established threshold (usually up to $3,000), the payment API request is complemented by the extended data of the sender.
The casino platform transmits structured information in the transaction package:
- the customer’s registration address;
- unique identifier (End-to-End ID);
- national ID (passport or tax code).
This data is recorded in the operator's AML module and can be used for the audit conducted by regulators.
Technical Security and Protection of Clients
The stability of VRP systems is based on the Financial-grade API (FAPI 2.0) open banking standards. The architecture of interaction between the entrepreneur’s server, TPP gateway, and banking Application Programming Interface precludes the use of vulnerable authorisation protocols.
Built-in security measures are:
- mTLS (Mutual TLS). Data exchange is carried out via two-way transport-layer encryption with the mandatory application of cryptographic certificates from a qualified provider (QWAC/QSealC).
- The isolation of information. Operators do not interact with sensitive payment details, such as account numbers, PIN codes, etc. All authorisation processes are performed in a secure banking environment.
On top of the VRP payment layer, online casino owners must implement a comprehensive anti-fraud monitoring system.
VIP Services as a Guarantee of a Seamless Experience
The installation of VRP makes it possible to rethink the architecture of loyalty programs for high rollers. Specifically, Tiered Deposit Experience is being created. It is linked to the user's actual financial profile.
Entrepreneurs create personalised payment corridors with flexible limits for each transaction.
This UX model offers several advantages:
- demonstration of operational transparency;
- increased trust among VIP customers;
- reduced legal risks for operators: gamblers cannot claim that charges happened without their consent.
How VRP Is Implemented in the Payment System of Casino Owners
The integration of Variable Recurring Payments into an already existing betting infrastructure requires coordinated actions of technical, product, and legal teams.
The end-to-end deployment process usually includes the following steps:
- selection of a PISP/TPP provider;
- API installation and configuration of connection with the risk system;
- testing the module in an isolated sandbox environment;
- pilot launch on a limited sample of the target audience;
- final approval of the solution and scaling within the operating model.
The transition from traditional card acquiring to the new architecture is associated with several risks. The main challenge is the uneven level of support for Commercial VRP from banks across jurisdictions.
For example, in most EU countries, Premium API coverage is still significantly lower than the level in the UK.
It is recommended to create backup scenarios (failover for standard PISP payments) in advance. This ensures a stable user experience in cases where the client's bank temporarily does not support automatic deductions.
Risks and Regulatory Restrictions of VRP in the iGaming Niche
Automated settlements in the online casino sector increase the legal burden on entrepreneurs, especially in 2 important areas:
Interaction with Self-Exclusion Systems
When a trigger is activated through national registries (for example, GAMSTOP in the UK or OASIS in Germany), operators are obligated not only to block the account but also to immediately cancel all active payment inquiries.
However, the PISP does not have direct access to the self-exclusion lists, so full responsibility for the correct handling of such events falls on business owners.
Delays in the transmission of commands to the financial gateway and subsequent deductions may be considered by regulators as a violation of rules for protecting vulnerable users. In these cases, sanctions, including licence revocation, are possible.
The Change of Responsibility Where There Is Fraud
Unlike card payments, where limits and chargebacks often result in customers winning a dispute, the VRP model employs a different liability shift.
Since the transactions are confirmed via SCA authentication in the banking app, it becomes extremely difficult to prove unauthorised transactions on the client’s part. Financial institutions verify the fact at the moment of request creation.
A cryptographically signed Consent Token serves as proof of the legitimacy of operations in disputes with regulators and banks. However, if entrepreneurs initiate a withdrawal that exceeds the internal limits set by customers in their accounts, liability shifts entirely to the entertainment platform.
The Main Things about the vNext Gambling Architecture

The integration of payment flows based on artificial intelligence technologies is becoming one of the leading development areas in the online casino industry in the coming years. The transition of banks to the ISO 20022 financial messaging standard allows for the addition of extended metadata to each transaction.
Within this model, leading brands are moving toward AI-based payments.
Neural network systems in real time make it possible to:
- analyse behavioural profiles of high rollers;
- comparison of account data with macroeconomic indicators and market volatility;
- consider the information related to the client's bank account.
Built-in compliance mechanisms become part of the payment flow itself. Next-generation architecture enables detection of signs of the client’s financial stress even before obvious behavioural signals appear. This enables proactive and accurate adjustment of withdrawal limits without degrading the user experience.
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