Online slots stake limit guidance
For instance, many not on gamstop discussed the significant changes to their harm detection systems since the Commission updated its customer interaction requirements and guidance in July 2019, and others mentioned measures like the ban on credit cards in April 2020. Operator responses largely put this in the context of the recent changes which have been introduced through voluntary industry codes or Gambling Commission mandated action. Key evidence as it relates to our policy proposals is discussed in more detail below, but a number of overarching themes emerged across the submissions.
Through developing their policy statements, licensing authorities are able to set out their ambitions for gambling in their area, and this in turn informs how they assess and decide applications for new gambling premises. As set out in detail in section 6.1, licensing authorities have a wide range of existing powers in regards to both gambling premises licensing and planning applications. Applicants must consider what measures the gambling operator can put in place within a GVZ to ensure that specific risks within the zone will not be exacerbated by the operation of the gambling premises.
We will work together with the Department of Health and Social Care and the Gambling Commission, drawing on public health and social marketing expertise to develop a new, evidence-based model for independently developed safer gambling messages. We recognise the risk that online bonus offers can present, particularly for those who are experiencing harm. As part of exploring the potential for regulating these types of draws we will seek further data and evidence to enable us to assess the proportionality and impact, including on the society lottery sector of different regulatory approaches. This means that they are not subject to gambling regulatory oversight, can lack protections for players, and are not obliged to follow the rules on identifying and mitigating gambling-related harms which apply to licensed operators. A particular version of this arrangement we received evidence on is when overseas gambling brands reach an agreement with an existing Commission licensee which they use to advertise and grow their brand in the UK without acquiring a licence themselves. The third-party might benefit in various ways including a profit sharing arrangement, a brand licensing fee which is paid by the gambling operator, or through greater exposure for their business.
By contrast, the largest estimated increase in annual GGY received from arcade operators was in the region of £10m. Cabinet device types are usually the most popular with customers. The majority of industry responses expressed a preference for either Option 1 or Option 3, and were strongly opposed to Option 2. Further details of proposed new operating licence fees will follow in due course.
We want all licensed operators to provide access to the ombudsman to ensure all customers are protected equally. The information that the ombudsman collates through complaints will also help the Commission in planning its enforcement activity and industry to inform processes and support vulnerable customers. The body would adjudicate complaints relating to social responsibility or gambling harm where an operator is not able to resolve these. We will look at how industry, working with all stakeholders in the sector, can create an ombudsman that is fully operationally independent in line with Ombudsman Association standards, and is credible with customers. Between Alternative Dispute Resolution (ADR) providers and the Gambling Commission’s contact centre, approximately 2,000 customer complaints per year relate to social responsibility, gambling harm and safer gambling. As the Commission’s process for requesting datasets from across the sector to support its regulatory purposes reaches a sufficient level of maturity, greater researcher access to this suitably packaged and anonymised data will lead to new areas of — and approaches to — research on gambling.
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For operators, they establish higher compliance standards and greater accountability. The UK operates strict gambling frameworks, with the UK Gambling Commission charged with protecting players & ensuring market integrity. It is important to note that illegal gambling activities may not be safe in the UK.
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We currently estimate that the key proposals we can quantify will lead to between a 3% and 8% reduction in Gross Gambling Yield (GGY) across the gambling sector, with the main decrease being in online gambling (where we estimate a reduction of between 8% and 14% of GGY). It is likely that the proposals will come with costs to the gambling industry, both in terms of upfront delivery cost but also in reduced revenue compared to current levels. Measures in this white paper are designed to increase existing protections against gambling-related harm in a proportionate and targeted way.
Without greater control for consumers, the negative impacts range from nuisance to casual players to exacerbating harm for those struggling with their gambling, who feel ‘bombarded’ by calls to action from operators. Considering the inherent risks of gambling, we believe there is a case to ensure that operators present bonuses in the most transparent language possible. Responses to our call for evidence which called for restrictions on bonuses were chiefly concerned by the risks posed by online bonusing and schemes. For high-end casinos, rewards can take the form of personal concierge services, including dinners, hospitality and events. To prevent individuals showing strong indicators of harm from being encouraged to gamble, the Gambling Commission recently published new requirements on customer interaction which require operators to prevent these customers from receiving any direct marketing or taking up new bonus offers. Measures to drive future research, including greater use of industry data, are outlined at Section 3.5.
Changes to legislation:
In the meantime, we welcome steps by some online platforms to empower individuals to ‘opt out’ of gambling advertising. The Commission will continue to closely monitor practices around online VIP schemes to make sure they are not used to exploit at-risk gamblers. There is good evidence that it can have a disproportionate impact on those who are already experiencing problems with their gambling. Where prize draws are not subject to regulation, we have limited information on the size of the market and the scale of possible gambling-related harm. Government is clear that cryptoassets must not become a vehicle for lower standards in the licensed gambling sector, either in terms of harm prevention or regulatory compliance.
Following the publication of the independent Football Index report, we also committed to looking at whether gambling companies should do more to demonstrate their ability to cover liabilities arising from long term bets, especially if they make up a large proportion of their business. These changes provide greater clarity to applicants that gambling products that could be mistaken for an investment are unlikely to be licensed by the Commission. In response to the recommendations, the Gambling Commission has updated its framework for how it assesses risk so that product novelty is fully considered. Both regulators have taken a number of steps to address points identified in the review, including agreeing to a strengthened Memorandum of Understanding which includes new escalation routes to make sure regulatory impasses and overlaps are identified and quickly overcome. The review set out a range of recommendations for the Gambling Commission and the FCA, including on how they worked together. The review provided a detailed and objective account of the regulatory circumstances around the granting of a licence to BetIndex Ltd, its subsequent suspension and the company’s ultimate financial failure.
- The majority of respondents agreed that premises should adopt voluntary test purchasing as a way to monitor under-18s activity on ‘cash-out’ Category D slot-style machines.
- We recommend choosing casinos that offer medium or high protection.
- There were also specific concerns around the links between sports and gambling, and the use of ‘loyalty’ rewards in a sector with a known addiction risk.
Online casinos enjoy huge popularity in the country and now they are believed to earn twice as much as brick-and-mortar establishments. Since 30 August 2024, remote operators have been required to undertake financial vulnerability checks on their customers once defined net deposit thresholds have been met in rolling 30-day periods. Generally, all betting and gaming products may be offered (albeit, as noted above, offering bets on the National Lottery is prohibited).
This is consistent with the Commission’s rules on transparency, and the regulator will monitor operators’ compliance in this area. However, operators are required to detail the terms of service, which would include the potential to apply account restrictions, in an easy and accessible way. While informal estimates from operators suggest between 0.7 to 3% of active accounts are restricted, operators tend to use ‘restriction’ to refer to a near-complete withdrawal of services rather than the staking factor restriction outlined above, so the real figure is likely to be higher. Operators already provide the account details to all customers wishing to make deposits by bank transfer, so the details themselves are unlikely to be confidential. This will help limit the ways that those who have taken the decision not to spend money on gambling can do so. However, in spite of most users’ expectations, these payments are not covered by most existing opt-in gambling blocks.
The Commission has a broad range of powers that enable it to regulate the industry effectively but there are some small changes that could be made around its ability to investigate operators, including improving the Commission’s responsiveness to changes of corporate control. The Gambling Commission will take a more ambitious approach to enforcement, using data from operators and more specialist staff so it can continue to improve regulation of the industry and keep pace with technological changes. A few submissions to our call for evidence highlighted the esports sector, which is growing fast and has significant appeal to children and young people, and increasingly to betting operators – with GGY from the esports betting sector growing from around £50,000 in March 2019 to over £1.5m in March 2020. Overall, indirect exposure to gambling marketing around sport is high, including among children, and can be particularly challenging for those already suffering gambling-related harms.
Responses from industry advocated for either no increase in the maximum chargeable premises fees or a small increase of 10%. This may include increasing staff numbers, with one licensing authority stating that it would consider dedicating one full-time resource to the enforcement of licensed premises. This was reflected by licensing authority responses in regards to how much the maximum premises fee should be raised by. In response to the questions as to how much annual funding is needed for administration and enforcement of licences, the average amount stated by licensing authorities was £45,000. The majority of licensing authorities advocated for the maximum proposed premises fee increase of 30%. Following analysis, we propose to increase the maximum premises fees chargeable by licensing authorities by 15%.
Progress here will help strengthen the evidence base around gambling and gambling-related harms, and buttress work to increase investment and capacity in the gambling research field. Separately, to support the development of effective treatment interventions, OHID has commissioned the University of Sheffield to calculate harmful gambling treatment needs and demand at local, national and regional levels. Through working collaboratively with NHS and other key delivery partners, including GambleAware, it wants to ensure those experiencing gambling-related harms receive high-quality treatment in a timely manner. It would not be appropriate for the Commission to be responsible for a repository of all data relating to gambling in Great Britain, including on areas such as treatment which fall outside of its remit. Collecting more data will provide rich datasets to assess compliance but will also allow for an increased understanding of consumer behaviour and operator practices which, suitably anonymised, could in turn inform research and understanding of gambling-related harms.
They also noted the cost of refloating machines, which has become more challenging for pubs where cash payments are not taken over the bar. Evidence submitted by the British Beer and Pub Association shows a post-COVID decline in both the percentage of pubs with machines and machine weekly income. While the existing framework has allowed for some innovation in cashless payments, gambling has largely remained cash-based. They are a significant part of land-based gambling, constituting 51% of non-remote Gross Gambling Yield (GGY) in 2022.
A response from an advocacy organisation opposed the introduction of direct debit card payments on the basis that there is evidence that cashless payments result in increased and unplanned spending when compared to cash. One betting shop operator was concerned that allowing direct debit card payments would minimise the interactions a customer has with betting shop staff as their current customer journey requires a certain level of interaction with a staff member. They stated that it would be an unnecessary and disproportionate burden for a low stake and low prize machine.
Under UK law, offering gambling to UK players without a UKGC licence is a criminal offence. Affiliate sites introduce players to gambling operators and must meet the same compliance standards as the operators they promote. Operators found to be in breach of licensing conditions risk suspension or revocation of their permit, heavy fines, and public sanctions by the UKGC. Retailers and operators must confirm a customer is over the minimum gambling age before providing access to any gambling product. Sports betting is legal and well-regulated in the UK, both in physical betting shops and through online platforms. Every operator ranked on our UK casino hub holds a UKGC licence, which is the single most important legality check a player can make.
Operator licence fees are different for 1968 Act and 2005 Act casinos. We do not intend on changing any of the requirements placed on operators for when a variation to a premises licence may be required. The Gambling Commission will also need to be notified of an operator’s projected annual licence fee category based on GGY for the forthcoming licence period, so that the correct fees can be paid. Currently, the Gambling Commission’s guidance to licensing authorities states that an application for a variation of a premises licence will only be required where there are material changes to the layout of the premises. What impact is permitting sports betting expected to have on revenue from non-gambling activities e.g. increased income from sports bars which allow customers to place a bet? If you are a casino licence operator, what impact is permitting sports betting expected to have on the Gross Gambling Yield (GGY) of your casino(s)?
In addition, we recognise that young adults may be particularly susceptible to gambling harm — see section 5.4. We will therefore introduce a stake limit for online slots games which will be fixed for all customers. However, this would rely on robust and reliable ways of identifying those who are and are not at risk of harm from accessing higher stakes. Additionally, a large number of people being flagged as exhibiting risk is not necessarily a bad thing, as it may demonstrate the operators’ proactivity in identifying and investigating signs of risk and potentially intervening. Since the call for evidence closed, we have also been told that 35% of customers stake more than £2 at least once a year.
The financial regulation of gambling is set out mostly in the British Finance Acts and provides for various levels of duty upon different types of gambling. Not regarded as gambling where the element of chance is no more than de minimis. Free-to-enter draws and betting competitions may be exempt if they meet conditions for free draws or prize competitions.
Industry responses stated that in addition to the ability to increase GGY, a central component of increased commercial flexibility for many operators is the ability to remove underused gaming machines. However, to mitigate against gambling-related harm, the reform of the rule also seeks to ensure that a genuine offer of lower staking Category C and D machines remain available for customers. A central objective behind the reform of the 80/20 rule is to enable operators to have greater commercial flexibility over their product offer of Category B, C and D gaming machines.
To further raise standards, a more prescriptive and risk-based model will be introduced, where remote operators are required to investigate the customer’s financial circumstances in response to certain loss triggers to understand if their gambling is likely to be harmful to them. However, while these tools are helpful for many online gamblers, they are not enough to fully mitigate the risks, so there are also a range of obligations on operators to identify and prevent gambling-related harm. All online play is account-based, and recent years have seen significant strides in the development of harm detection algorithms which monitor every aspect of a customer’s gambling to spot signs of risk and trigger interventions without human input. The proportion of people suffering harm might also be identified through other sources such as bank transaction analysis, hospital admission data, and operators’ own harm detection algorithms which flag the customers displaying indicators of harmful gambling. It also gives the Secretary of State the power to update specific provisions (such as the maximum stakes and prizes for gaming machines) and to set licence conditions via secondary legislation. A key concern for some of the land-based sectors is the ban on direct use of debit cards on gaming machines and we recognise that substantial changes are happening to how payments in society are being made.
There are currently only three Small 2005 Act casinos in operation from the eight licences available. No machine to table ratio currently exists for 1968 Act casinos. Casinos with multiple licences at the same physical location could site more than 80 machines under the new regime – it is not clear whether the current rules are clear enough to prevent this situation from arising in practice. Part 1 of Schedule 1 to the Gambling Act 2005 (Mandatory and Default Conditions) (England and Wales) Regulations 2007 sets out a number of mandatory conditions that are attached to all casino premises licences.
The majority of responses were in favour of mandatory limits being a required feature on machines accepting direct debit card payments. We think that the requirements of account verification, transaction limit, and deposit limits, alongside a minimum transaction time will provide appropriate safeguards for these lower stake machines. The pub sector argued that it would be disproportionate, cost-prohibitive and unlikely to be achievable on these types of machines. We are also proposing that this minimum transaction time applies to all machines. Category D machines do not have a committed payment limit.