Financial Due Diligence (12 Items)
- Audited P&L for last 3 years with GGR, bonuses, and NGR clearly separated
- GGR by geography/jurisdiction and by player cohort (at least 18 months history)
- Bonus spend as percentage of GGR by month (trend analysis for 24 months)
- Player retention curves for cohorts acquired in each quarter (last 18–24 months)
- Customer acquisition cost (CAC) by channel and player lifetime value (LTV) by cohort
- Tax returns for last 3 years and compliance with all jurisdictions' tax obligations
- Normalised EBITDA bridge showing adjustments for one-time costs and run-rate assumptions
- Payment processor fee structure and blended rate; contracts with all processors
- Marketing spend by channel for last 24 months with attribution to GGR
- Affiliate and traffic agreements; concentration risk (% GGR from top 3 sources)
- Working capital analysis (accounts receivable, payables, inventory — if applicable)
- Off-balance-sheet liabilities (earn-outs, contingent payments, guarantees)
Regulatory & Licensing Due Diligence (10 Items)
- Current gaming licenses and permits by jurisdiction (scan original documents)
- License expiry dates and renewal status for each jurisdiction
- Material change of control provisions in license agreements (can license be transferred?)
- Regulatory compliance history — any warnings, fines, suspensions, or investigations
- KYC/AML procedures, compliance reports, and any regulatory findings on customer vetting
- Responsible gambling program documentation and player spend limits
- Correspondence with regulatory authorities for last 3 years
- Tax compliance in all operating jurisdictions; any pending disputes or audits
- Data protection and GDPR compliance (if operating in EU)
- Anti-money laundering (AML) and counter-terrorism financing (CTF) certifications
Technical & Platform Due Diligence (10 Items)
- Gaming platform provider contracts (term, termination rights, revenue share)
- Core third-party integrations: payment processors, sportsbook feeds, RNG provider
- Service level agreements (SLAs) with critical vendors; uptime history for last 12 months
- Technology architecture: hosting environment, CDN provider, disaster recovery plan
- Cybersecurity infrastructure: fraud detection, bot prevention, DDoS protection
- IT headcount and contractor dependencies (single points of failure?)
- Platform scalability assessment (can it support 2x or 5x GGR?)
- Data storage and backup procedures; any security incidents in last 3 years
- Source code ownership and escrow agreements (if applicable)
- Mobile app presence (iOS, Android); status with app stores
Commercial & Player Base Due Diligence (10 Items)
- Top 20 players by lifetime spend; concentration risk for top player cohort
- Player deposit and withdrawal patterns; chargebacks and refund rates
- Affiliate and traffic source agreements (term, exclusivity, minimum spend, commission rates)
- Promotional partnerships (sportsbooks, tournaments, other platforms) and their contribution to GGR
- Competitive analysis: market positioning vs. peers, pricing strategy, product differentiation
- Customer support infrastructure: headcount, outsourcing arrangements, complaint resolution process
- Player feedback and Net Promoter Score (NPS) — if available
- Content and game offerings: mix of proprietary vs. third-party games
- Bonus strategy and average bonus payout per player (trend over time)
- VIP and high-value player program; retention metrics for top players
Legal & Corporate Due Diligence (8 Items)
- Articles of association, shareholder agreements, and governance structure
- Equity cap table and any outstanding options, warrants, or convertible instruments
- Contracts with material suppliers, partners, or vendors (all >5% of spend)
- Employment agreements with key employees; non-compete and non-solicitation covenants
- Intellectual property (IP) ownership: domain names, trademarks, software
- Litigation history: any active lawsuits, disputes, or threatened claims
- Related-party transactions: loans to founders, affiliate relationships, intercompany deals
- Material contracts reviewed by legal counsel for enforceability and change-of-control language
Operational Due Diligence (8 Items)
- Organisational structure and management team biographies
- Headcount by function (product, engineering, operations, compliance, support)
- Key person risk: founders, CTO, CFO, compliance officer (dependency analysis)
- Contingency plans for critical staff departures or losses
- Standard operating procedures (SOP) documentation for major processes
- Regulatory reporting and submission schedule (monthly/quarterly/annual filings)
- Vendor management: critical dependencies, contract terms, termination risk
- Crisis management and incident response procedures
The Most Commonly Missed DD Items:
Player concentration risk (top 10% of players representing 40%+ of GGR). Bonus trend analysis (bonus spend creeping up as percentage of GGR). Payment processor dependency (single processor handling 60%+ of deposits). Related-party transactions (founder owns affiliate sending traffic, or owns sportsbook providing feeds). Regulatory compliance history (pending license review not disclosed until late in DD).
Prepare these items well in advance. When a buyer asks for them, you want to respond with clean documentation, not scrambling to gather data.
How to Use This Checklist
If you are a seller: Go through this checklist and prepare documentation for every item before you enter a sale process. The items you don't have ready are the ones that will kill your deal or force price renegotiation. A buyer will ask for everything — better to have it ready.
If you are a buyer: Use this as your baseline DD request. Tailor it to your specific needs (if you're not concerned about geographic diversification, skip that item; if platform scalability is critical, add more detail). The items where a seller can't produce clean documentation are red flags.
If you are an advisor: Use this to ensure you're not missing anything. Run through each category, ask the operator what they have and what they don't, and identify the biggest gaps.
Why DD Breaks Down: Common Patterns
In our experience, due diligence fails for three reasons:
Missing or incomplete documentation: A seller can't produce player cohort retention curves because they don't have analytics infrastructure. A buyer spends 3 weeks requesting this, then walks away. Better to identify this gap 6 months before entering a sale and build the analytics.
Misaligned expectations on key metrics: The seller claims 45% NGR margin and 25% Day-30 retention. The buyer's team stress-tests the data and concludes actual sustainable metrics are 40% margin and 18% retention. Suddenly the EBITDA is lower, and they want to renegotiate price down 20–30%.
Regulatory or compliance issues discovered late: In Week 8 of DD, a buyer discovers that your AML/KYC procedures don't meet the acquiring company's standards. The buyer now wants to reduce valuation to account for cost of remediation. Your deal is at risk.
The solution: prepare for DD as if you're going to sell today. Address gaps. Prepare documentation. Validate your financial assumptions with data. When a buyer asks, you respond with clean, professional documentation. That signals you know your business and there are no surprises.
60+
DD Items Tracked
8–12 wks
Typical DD Process
40%
Deals Failing in DD
Note: Working with an advisor? Contact us at contact@bulletapex.com for guidance on any of these items or a guided DD review where we validate your preparedness and identify gaps before a buyer does.