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Online slots games are already subject to a minimum speed of play of 2.5 seconds per spin (in line with land-based equivalents) as well as other measures designed to strengthen the protections and controls for those who gamble through online slots games. 1) Does the description of online slots we have provided adequately describe the products intended for inclusion in the maximum stake limit’s scope? The Gambling Commission recommended the introduction of stake limits for online slots in its published formal advice to Government in April 2023.

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.

This data covered over 70 billion spins placed during the financial year to March 2023, increasing our understanding of current staking patterns for online slots. This includes academic research, parliamentary reports, and findings from the stake limit cut on B2 machines (fixed odds betting terminals) in 2019. This measure is designed to work together with the wider package of policies in the white paper, including financial risk checks, data sharing on high-risk customers, and making online games safer by design. We will then allow a further 6 weeks for the development of any necessary technical solutions before we expect the lower stake limit of £2 for young adults aged 18 to 24 to be in place. Following the passing of the secondary legislation, we expect there to be a minimum  of 6 weeks’ transition period for operators to introduce a £5 stake limit for all customers. Our reporting and analytics tool, included in our BackOffice, offers comprehensive casino reports and detailed gaming reports.

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Most advocated for a minimum implementation period of 6 months and suggested that a longer period would be required for age-based stake limits. However, we acknowledge that the implementation of a separate stake limit adds a layer of complexity for businesses in making the necessary changes to software. We believe the evidence justifies increased protections for this cohort, including a separate lower stake limit. Some suggested the existing safeguards for this cohort are sufficient (and will be further strengthened via financial risk checks) and that separate stake limits would be disproportionate and largely ineffective.

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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.

Playing online casino games on a smart TV is possible, particularly through web browsers or casting. Playing online casino games on a smart TV depends on how advanced the TV’s operating system is, the browser or app capabilities, and how you control the interface. A few respondents pointed to the blanket EUR 1 stake limit on online slots introduced in Germany in 2020 and expressed concerns about its impact on the German market. However, the intention is that boundary-pushing products (such as those which combine fundamentally slots-type gameplay elements with other games like bingo – for instance the popular ‘slingo’ game) are captured under the definition of slots and subject to the stake limit.

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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Future improvements in voice control, gesture tracking, and app integration may pave the way for more engaging and responsive gaming experiences. These games require constant input, which is not optimal using a TV remote. However, table games and poker may be less suitable due to their interactive nature. Live dealer games also translate well to a big screen.

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This includes a detailed breakdown of staking patterns with leading operators which represent approximately 80% of the online gambling market (but given size and product mix, they may not be fully representative of all online slots providers). We note that distributions may have changed as operators’ algorithms and approaches (including voluntary slots stake limits) have continued to evolve. However, it also found that even players identified as high-risk play mainly at low stakes. To finalise policy details, including the precise level at which a stake limit should be set, the government conducted a public consultation exercise from July to October 2023. In Great Britain, there are currently no statutory limits on the amount people can stake on any online gambling products. This response provides remote gambling operators with clear notice of our intention to introduce stake limits at the specified levels.

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Some noted that many gambling operators already offer additional protections for customers aged 18 to 24 such as restrictions on high-value customer schemes, lower deposit limits, and bespoke social media advertising requirements. Others felt that a two-tier approach to stake limits would only serve to generate further disparity with the land-based sector where the same limits are consistent across all adults. 34% of consultation respondents were in favour of a universal limit of £2 across all adult age groups as the lowest limit within the consultation range. There were a number of views on whether additional protections are needed for young adults and whether a separate lower stake limit should be implemented.

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However, some industry respondents felt that a two-tier limit was still preferable to a universally low limit for all adults, despite the additional implementation challenges. However, some industry respondents were much more supportive of a separate age limit for young adults which recognises the particular risks for that cohort, and aligns with the broader aims of the white paper in protecting vulnerable groups. These respondents argued that a separate limit could be unfairly discriminatory and provide a precedent for discrimination based on other protected characteristics.

The use of smart TVs for gambling is still in its early stages. Some smart TV manufacturers restrict gambling content or block downloads of related apps based on your geographic location. Also confirm that responsible gambling tools are available and functioning. This impacts how easily you can navigate casino sites, especially when placing bets or chatting.

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.

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