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.
Business impacts and implementation
A minority of respondents answered our questions about the direct costs associated with the proposals and issues around implementation, and it is worth noting that some operators would have less distance to travel than others, in order to meet the proposed requirements.
We have considered the impacts on business of the individual proposals throughout the consultation, including consideration of direct impacts (immediate and unavoidable) of the proposed changes, but not necessarily indirect impacts.
A significant number of the consultation proposals constituted codification of existing widespread practice – such as elevations of current remote gambling and software technical standards (RTS) implementation guidance to requirements – and should be considered as having minimal direct impacts. We have also considered the practical aspects of implementing the proposed changes, and the extent of associated developmental work, based on the Gambling Commission’s experience of the implementation of previous changes to the RTS.
Overall, our position is that the proposed new and amended RTS requirements made in this consultation response are proportionate to delivering the policy intent of the 2023 White Paper and our consultation.
The decision whether to use tools or to set financial limits remains that of the consumer, as is currently the case. The direct costs to business are related to implementation of methods to offer consumers tools and to be able to set limits – which is already well established and widespread among the industry. We consider any direct costs associated with these provisions to be proportionate in terms of the benefits to consumers and in the context of the stated policy intent to ensure that systems for setting financial limits work as well as they can for those consumers who wish to use them.
There are 3 areas in which our consideration of the impact on business has informed our decision to adapt or not progress with the original consultation proposals:
- where customers hold more than one account within a group or family
- sending alerts to customers when approaching limits
- sending activity statements to customers.
Our original consultation proposals around the definitions of financial limits and the requirement to offer deposit limits was raised by respondents as an area which may require significant costs and development time. We are due to publish a supplementary consultation on this issue, which will enable a more granular assessment of the costs associated with this specific set of proposals.
In considering the implementation timeframe for the changes set out in this response document, we have considered the length of time needed to make these specific technical changes, and the sequencing and scheduling of other legislative and regulatory changes being implemented by Government and the Commission. In doing so, we have taken into account feedback from industry stakeholders about the IT development required to make the necessary system changes.
With that in mind, we have set an implementation date of 31 October 2025 for the changes set out in this document to come into effect.
Last updated: 4 February 2025
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