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The stake limit proposals outlined in this consultation response are in line with those intentions. Stake limits for online slots are only one part of the wider package of regulatory and legislative changes which is intended to create an appropriate balance. Similarly, some respondents highlighted concerns around the use of gambling-like mechanisms being applied to non-gambling contexts such as video games and cyrptocurrencies. 23% of respondents highlighted that young people will be discriminated against on the basis of age if a separate lower stake limit is implemented. Some industry respondents highlighted that a single stake limit would be easier to implement than 2 separate limits. Many of the comments and supplementary evidence focused on the positive impact of a stake limit on those either directly or indirectly affected by gambling-related harm.

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Such account-based protections will be further strengthened by proposals for new obligations on operators to conduct checks to understand if a customer’s gambling is likely to be unaffordable and harmful, in the form of frictionless financial risk checks. Around 20% of customers currently choose to stake over £5 on a spin at least once a year (so will be impacted by this measure), but only 0.6% of all spins are over £5. In addition to the formal consultation responses, we also received survey results from 3,898 members of the campaigning organisation 38 Degrees and a petition set up by GWL signed by 12,775 people.

This staking data was included in the consultation to assist respondents in forming their own views. Given the number of respondents to the call for evidence, we have continued to consider their views where relevant to the current consultation. The call for evidence asked 45 questions across the full range of gambling regulation, including online protections, advertising, consumer redress, and land-based gambling. The ‘summary of consultation responses’ including the figures and percentages in each section reflect only the respondents who engaged with each specific question, rather than the overall respondent body. Respondents ranged from industry stakeholders engaged across various stages of the gambling supply chain, stakeholders from charities and campaign groups, other interested organisations such as parliamentary groups and individual members of the public. Following this transition period, if operators are unable to develop solutions to adequately distinguish between customers who are 25 and over and those who are under 25, the expectation is that they will not be able to offer any customers stakes exceeding £2 per spin.

Respondents suggested that multiple definitions in legislation and regulation would cause confusion and technical challenges for the categorisation of games, as well as potentially unintentionally capturing games outside of scope of the limit. Some respondents called for regular reviews of the description to future-proof its relevance to new online gambling products. To ensure the statutory instrument introducing the maximum stake limit is fully effective, we need to ensure a common understanding and also ensure the chosen definitions capture all intended products without driving gambling unintended consequences. The data also showed that very few people stake at high levels for most of their slots gambling.

• We also acknowledge the calls for changes to game design, specifically to slow down the speed of online slots games.
• These respondents suggested that a separate stake limit for young adults would require extensive development by operators and software providers and would be far more complex and costly to implement than a universal limit.
• More than half (52%) of respondents answered ‘Yes’ to the question ‘Are there any additional impact considerations, including on the assumptions in the accompanying impact assessment or on the risk of unintended consequences?
• A frequently expressed opinion amongst industry respondents was to keep the description exactly aligned with the already established and widely understood Gambling Commission definition.

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We acknowledge both the calls for further action to prevent gambling-related harm and the risk of unintended consequences. The impact assessment contains a cost benefit analysis and includes further consideration of the information that was not possible for the consultation stage impact analysis. Similar arguments were made for other groups with protected characteristics who may be more vulnerable to gambling-related harms. However, the majority of these respondents felt that younger people needed to be protected because of their increased risk of harm. More than half (52%) of respondents answered ‘Yes’ to the question ‘Are there any additional impact considerations, including on the assumptions in the accompanying impact assessment or on the risk of unintended consequences? 7) Please indicate if you believe any of the proposals in this consultation are likely to impact persons who share such protected characteristics and, if so, please explain which group(s) of persons, what the impact on any such group might be and if you have any views.

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High-definition video and real-time gameplay create an immersive experience. A more fluid way to play casino games on a smart TV is by casting or mirroring your screen from a smartphone, tablet, or laptop. Several industry respondents provided suggestions for the length of time required to implement stake limits. Many respondents cited evidence showing that young adults may be particularly vulnerable to gambling-related harm and felt that this justified greater protections either in the form of a separate stake limit or otherwise.

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In the Gambling Commission’s participation survey, reporting on data in the year to March 2023, the problem gambling rate for 16 to 24 year olds (1%) was higher than the headline problem gambling rate (0.3%). Respondents who were not in favour of a separate limit raised concerns about some adults being treated differently based only on their age. Respondents also mentioned that younger adults may be less informed on the risks of gambling or may have lower incomes than older adults. It is unclear how many of those who supported consistency in limits for all adults would support a lower limit for young adults if the general limit is to be higher than £2. Our intention is that there will be future opportunities to review and if necessary adjust the limits. The Gambling Commission is also exploring improvements to online harm detection algorithms which will mean other markers of harm are more effectively identified and acted on.

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These respondents raised concerns that lower limits would affect customer enjoyment of online slots and that these customers may migrate to the illegal online market where there are no protections for consumers. Both petition and survey respondents wanted tougher restrictions, with the petition specifically calling for a limit below £2, and changes to slow down games (not in scope of this consultation). Many respondents also felt that £2 was most appropriate as it aligned with the stake limit for B2 gaming machines in bookmakers. When taking into account the content of the free text responses from each of the respondents, 26% of consultation respondents were in favour of a stake limit below £2 and 38% of respondents favoured a limit of £2. By volume, most respondents would support a stake limit at the bottom of, or below, our consultation range for all adults.

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The imposed limit should serve as a maximum stake which customers can choose to stake up to, rather than as a new default which operators drive customers towards, or which is otherwise seen as objectively ‘safe’. We believe these limits will achieve the government’s stated objectives of reducing the risk of gambling-related harm, with a lower risk of unintended consequences and less disruption to the majority of gamblers who do not suffer harm. This extensive selection ensures an engaging and high-quality gaming experience for your audience. Our support team is ready to address any technical issues promptly, including incident management support, system error resolution, and troubleshooting gameplay problems.

This figure is lower than that shown in the table above because some respondents selected £2 (Option 1) but explained in the free text response that they were in favour of a limit below £2. Having worked with the Gambling Commission, we are confident that these games can adequately be captured by the Gambling Commission’s existing definition, although this is ultimately subject to due legal process on interpretation. We welcome stakeholders’ general support for the descriptions proposed in the consultation. Further, since March 2020, the Gambling Commission has been collecting and publishing detailed information from online gambling operators.

We have considered feedback from respondents, including the concerns raised by operators in relation to the proposed description of ‘online slots’ where the proposed wording extended the definition established by the Gambling Commission in 2021. Many of these respondents considered that the proposed description was unclear or open to loopholes and may result in inconsistent application of the stake limit, but did not give specific examples of how it might be circumvented. A few respondents suggested that independent and accredited test houses should be responsible for classifying games rather than operators who may subjectively interpret whether a game meets the slots definition or not. ‘Maximum stake per spin’ means the maximum amount a player can pay or risk per spin or game cycle. While stakeholders broadly recognise online slot-type products as a distinct class of remote casino game and have an intuitive understanding of the key terminology such as stake and game cycle, these terms are not all defined in legislation.

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Online it’s easier for someone to set up an account and avatar, lie about their age, and start gambling. Internet gambling sites provide little in the way of gatekeeping. Casinos have age limit laws, and in some places will not let someone who is overly intoxicated place a bet. This means that it is easier to lose large sums of money very quickly, and not really register. But online, you simply add a credit card and keep charging payments to it. The odds are sometimes lowered, and most of the time, the gambler will win.

This phased approach gives acknowledgement to the development of any technical solutions by operators which may be required for age-based limits. If approved by Parliament, these will impose new licence conditions on remote gambling operators which the Gambling Commission will then be responsible for enforcing. Individual responses included 6 individuals working in gambling or gambling regulation and 3 academics or researchers. Alongside the consultation, we published a consultation stage impact assessment to help inform responses. The purpose of this consultation was to ensure that the government was able to consider the best available evidence, including on the impact of each option, when finalising policy decisions. Following the Department of Culture, Media and Sport’s (DCMS) review of the Gambling Act 2005, the gambling white paper published in April 2023 set out the government’s plans for modernising the regulation of the gambling sector.

This highlighted the overrepresentation of customers identified as high risk among high stakers, although this data could not explore the cause of such overrepresentation. In addition to the views and evidence provided through the consultation, DCMS has considered a wider body of background information to guide decision making. Parts 1 to 4 of this document sets out respondent views and evidence on each section of the consultation before outlining the government response and intended action in each area. During this time, 98 submissions were received, including 4 by email and 94 via our survey platform. In April 2023, DCMS published the white paper on gambling setting out the government’s plans for bringing the regulation of the gambling sector into the digital age.

Question 2 of the section ‘Online protections – players and products’ specifically asked for evidence for or against the imposition of greater controls on online product design, including stake, speed, and prize limits or pre-release testing. This consultation relates to online slots games provided and/or advertised to customers in Great Britain, by operators who are consequently required to hold the appropriate licence from the Gambling Commission. Amp up your online casino, drive player engagement, and increase retention with BetConstruct’s Last Battle loyalty system. Not only do we strive to offer the best online casino experience possible in terms of entertainment, but we have a focus on safety and fairness. This is especially important when it comes to any sort of offer, such as a welcome bonus or ones that may be periodically awarded by the online casino once you’re a member.

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