AI at the Core: Michael Carlton on the Future of 21.com

The world of online casinos is facing a technological shift that goes far beyond simple chatbots. While many established operators struggle to integrate modern features into decades-old systems, Michael Carlton is choosing a radically different path. The founder and CEO of 21.com, who previously spent twelve years at the helm of BetVictor, relies on an architecture designed from the ground up for the era of Artificial Intelligence. Carlton identifies this exactly as the weakness of major players, whose infrastructure often appears inflexible and cumbersome.

The approach of 21.com differs fundamentally from common practice in the iGaming industry. Instead of treating AI as an optional extra, it is firmly anchored in the foundation of the operator. This allows for an agility that Carlton believes will lead to a shift in market conditions over the next two to three years. It is not about quick success in every available jurisdiction, but about proving that a technologically superior model can sustainably win over critical users.

Numbers and facts

Michael Carlton brings significant experience to the project. He is a British-born Chartered Accountant who spent 13 years at EY before joining BetVictor in 1997. There, he led the company's fortunes as CEO from 2002 to 2014. At 21.com, he is now pursuing a growth strategy that initially focuses on a small number of markets. The goal is to become a top-three operator, with Carlton emphasizing that this is defined not just by Gross Gaming Revenue (GGR), but by player satisfaction and trust. He warns that high revenues alone are not sustainable if users do not enjoy using the product or distrust the brand.

Particularly in the area of human resources, the challenge of growth is evident. Carlton notes that a corporate culture is easy to describe with 20 people, but becomes significantly harder to protect with 100 or 200 employees. Therefore, he relies on individual ownership and flat hierarchies to keep bureaucratic hurdles low, which often accompany the scaling of companies.

Background

The technical superiority Carlton refers to primarily concerns overcoming so-called legacy platforms. Many large operators carry old codebases that make adjustments slow and expensive. At 21.com, however, AI is directly integrated into the core operations. This affects four main areas: Personalization adapts the product to the actual behavior of each individual player, rather than funneling all users through the same process. In trading, the technology allows for faster price reactions than purely manual teams. In customer support, automation ensures that simple requests are resolved immediately, giving human employees more time for complex cases.

A particularly important aspect is player safety. Here, AI can detect patterns of concerning behavior earlier and initiate interventions before serious problems arise.

"Because we built without legacy infrastructure, AI isn’t sitting on top of the product as an add-on. Instead, it’s part of how the product was designed from the outset." - Michael Carlton, Founder and CEO of 21.com

Carlton argues that it is much harder to bolt modern payment rails or AI-driven personalization onto a platform that was never built to support them. He sees this technological advantage as the window of opportunity that 21.com intends to use consistently in the coming years.

Why it matters for German players

For German players, the technological development at providers like 21.com is interesting, but the legal framework in Germany remains the highest authority. Since the Interstate Treaty on Gambling 2021 came into force, only providers listed on the whitelist of the Gemeinsame Glücksspielbehörde der Länder (GGL) are allowed to operate in Germany. This regulation carries strict rules: a deposit limit of 1,000 euros per month across all providers applies, monitored by the LUGAS system. Furthermore, the stake limit for virtual slot machines is capped at 1 euro per spin.

Innovative AI solutions in player protection could theoretically benefit German players, provided the operator holds a German license. The early detection of problematic gambling behavior through algorithms complements state control mechanisms. Nevertheless, players should always check whether a provider holds the GGL license, as only there are the strict German consumer protection standards guaranteed. MGA or Curacao licenses do not offer this protection for German customers and are illegal for online slots in this country.

What it means for GGL-licensed casinos

Established German licensees must take a close look at the technological advantage of new competitors. If platforms like 21.com show that AI-driven player protection is more effective than manual controls, regulatory requirements could increase in the future. GGL casinos are already required to report data to LUGAS and OASIS, but internal analysis of player behavior offers room for optimization. The integration of AI could help implement strict German requirements more efficiently without degrading the user experience through excessive bureaucracy. The advantage described by Carlton of an infrastructure without legacy baggage could also become a model for German operators when they modernize their systems for the requirements of GlüStV 2021.