Consultation response
Autumn 2023 consultation – Proposed changes to LCCP and RTS: Consultation Response
This response sets out our position in relation to the consultation on the proposed changes to LCCP and Remote Gambling and Software Technical Standards.
Applicable licence categories
The applicable licence categories for remote gambling and software technical standards (RTS) 12 – Financial limits – are “All gambling – except subscription lotteries”. The consultation did not propose any changes to the applicable licence categories, therefore we did not ask a specific question about this issue. However, respondents on behalf of the lotteries sector requested we provide clarity that while subscription lotteries remain exempt, high frequency lottery provision (which is structured and behaves in the same way as other online products such as slots) would continue to be captured, as it currently does under ‘All gambling’.
Our position
Accounts offering high frequency lotteries and instant wins operate a wallet-type account system to fund staking, which is more akin to the majority of online gambling than subscription-based lotteries.
However, we do not consider it necessary to amend the wording of the applicable licence categories, as there is no actual change, and as high frequency (and similar) lotteries and subscription lotteries are defined as part of the RTS definition of terms, and high frequency and instant win lotteries continue to be caught by ‘All gambling’ as they are currently.
Last updated: 4 February 2025
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